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Baked Stuffed Trout, Five Hour Stew and Seafood Quiche recipes: Helen Dollaghan
Helen Dollaghan, food editor of The Denver Post from 1958-1993, selected recipes she felt were the best and published them in this 1987 special section called "30 Years of Rocky Mountain Cooking." Most are recipes that Helen or her readers developed.
Every Friday we'll share several of the recipes from her collection.
Week 2: Baked Stuffed Trout, Five Hour Stew and Seafood Quiche.
An all-time favorite that appeared
in a 1967 daily food column.
Baked Stuffed Trout
1 small green onion, minced
3 smal ribs celery, minced
1 tablespoon butter or margarine
3/4 cup finely chopped,
cooked shrimp
1 tablespoon dried parsley flakes
1 egg, beaten
Juice of 1/2 lemon
1/4 cup half and half cream
Salt and pepper to taste
Cracker crumbs
1 large trout, cleaned,
boned or unboned
Lean bacon strips
Saute onion and celery in butter until onion is soft. Toss with
shrimp, parsley, egg, lemon juice, cream, salt and pepper. Add
just enough cracker crumbs to hold mixture together. Loosely
stuff trout with mixture, allowing it to buldge a bit, if necessary.
Trout is not skewered closed. Place trout on a greased rack in
shallow pan. Cover with bacon strips. Bake, uncovered, in
preheated 350-degree oven until trout flesh is opaque when
tested with fork. Allow about 20 minutes per pound, stuffed
weight. Place any leftover stuffing in covered baking dish. Bake
with trout. If bacon gets too crisp, cover trout loosely with foil.
Number of servings depends on size of trout.
This recipe from a spring of '67 issue of
The Denver Post first came to our attention
through an advertisement for Hunt's Tomato Sauce
with Cheese. The recipe survived even
when the cheese-flavored sauce was unavailable
and plain tomato sauce had to be substituted.
Five-Hour Stew
2 lbs. boneless round steak,
trimmed of fat and cut in 1-inch cubes
2 cans (8 oz. each) tomato sauce
1 cup water
Salt and pepper to taste
2 medium potatoes, cut in eighths
6 medium carrots, cut in 2-inch pieces
1 cup coarsely chopped celery
1 medium green pepper, chopped
1 medium onion, chopped
1 slice white bread with crusts, cubed
Combine all ingredients in Dutch oven. (Meat need not be browned first.) Mix well. Bake, tightly covered, in preheated 250 degree oven 5 hours or until meat is tender. Stir once or twice. Serves 6 or more.
Former White House chef Rene Verdon
and Mrs. Ralph Schomp of Denver were among
cooks who contributed quiche recipes to
Denver Post food columns in the '60s.
Katherine Schomp's is one of the best we've
tasted. Here it is.
Seafood Quiche
Pastry for deep 9-inch pie
2 tablespoons minced green onions and tops
3 tablespoons butter
1 cup (about) cooked seafood, such as crab
meat, lobster, chopped shrimp or combination
2 tablespoons madeira, dry vermouth or
dry white wine
3 eggs, beaten
1 cup heavy cream
1 tablespoon tomato paste
1/2 teaspoon salt
Dash pepper
1/4 cup shredded Swiss cheese
Line deep 9-inch pie plate with pastry. Bake in preheated 375-degree oven 8 minutes. Cool to room temperature. Saute onion in butter until soft. Add seafood and madeira. Mix eggs, cream, tomato paste, salt and pepper until smooth. Combine with seafood. Pour into pastry shell. Sprinkle with cheese. Bake in preheated 375-degree oven about 30 minutes or until lightly brown and knife inserted in center comes out clean. Serves 6 as luncheon main dish or 12 or more for hors d'oeuvres.


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Arvest Bank and Shred-It recently held a free Shred-a-Thon event for the community, destroying more than 500 boxes of paper on-site. The Shred-a-Thons in Mountain Home and Harrison helped the community destroy more than 17,500 pounds of personal and confidential documents in an effort to guard against identity theft.
In exchange for free shredding provided by Arvest Bank and Shred-It, residents were encouraged to make a monetary donation or bring nonperishable food items in support of Arvest Bank's 1 Million Meals campaign that works to reduce hunger in local communities.
The Shred-a-Thon collected more than $3,165 in donations and 375 food items for the campaign. The monetary donations will provide 15,825 meals to Ozark Share and Care, a local hunger relief organization.
"We look forward to this event every year because it combines two great services to the community, protecting people from identity theft, and supporting those who face food insecurity," said Scott Tennyson, market president of Arvest Bank in Harrison. "We are very grateful to our generous community that once again pulled together to make a difference in the lives of those in need, and we appreciate Shred-It for their willingness to make this project possible."
Arvest Bank's annual 1 Million Meals campaign continues through June 2. The goal of the campaign is to collect enough food and monetary donations to provide the equivalent of one million meals in the 120 communities Arvest Bank serves across a four state territory. Residents may drop off nonperishable food items or monetary donations at any Arvest Bank location in support of the Food Bank of North Central Arkansas' backpack program and other similar programs in the area. Every donation made in Mountain Home stays local.
"We couldn't have done this event without the help of Shred-It and our compassionate and giving community," said Sally Gilbert, market president of Arvest Bank in Mountain Home. "We are very grateful to those who donated."
Donations may also be made by calling (866) 952-9523. Arvest credit card customers can donate Arvest Flex Rewards™ points by visiting arvestflexrewards.com and clicking on the 1 Million Meals banner, and customers who use the Arvest Go mobile banking app may contribute through the app as well. Every dollar raised through 1 Million Meals provides the equivalent of five meals for those in need.
For additional information, visit www.arvest.com/millionmeals.
Submitted questions will be answered by an Arvest banker and may appear on the Arvest Blog.
All Arvest banks are Equal Housing Lenders and Member FDIC.
Investment products and services are provided by Arvest Investments, Inc., doing business as Arvest Asset Management, member FINRA/SIPC, an SEC registered investment adviser and a subsidiary of Arvest Bank. Trust services are provided by Arvest Bank. Insurance products are made available through Arvest Insurance, Inc., which is registered as an insurance agency. Insurance products are marketed through Arvest Insurance, Inc., but are underwritten by insurance companies.
Securities and Insurance Products: Not Insured by FDIC or any Federal Government Agency, May Lose Value, Not a Deposit of or Guaranteed by a Bank or any Bank Affiliate.

subset: commoncrawl


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Transfer Students
Whether you started your education at a community college or another four-year university, Cameron University is a great place to continue working toward your degree. Here at Cameron we are not only committed to providing students with a top-quality education, but to also provide excellent resources and opportunities to ensure your success as a student.
Cameron defines a transfer student as anyone who has attempted 6 or more college credit hours (excluding developmental courses or pre-college work) at another college or university. High school students who are concurrently enrolled at a college or university, including Cameron, will need to apply as a first-time freshman.
Basic Academic Requirements
- If you have fewer than 15 hours of college credit, you will need to attend Orientation.
- If you have fewer than 24 hours of college credit, you will need to also submit an official high school transcript
- If you have fewer than 24 hours of college credit AND under the age of 21, you will also need to submit your ACT or SAT scores
- If you are an international student, you will need to meet all admission requirements established by Cameron's Office of International Admissions
All transfer applicants must complete the following application requirements:
- Have met Cameron's undergraduate admission requirements
- Complete the online undergraduate application
- Pay the one-time $20 application fee
- Official transcripts from all colleges and universities attended as well as ACT/SAT scores (if required) should be sent to the following address:
2800 W Gore Blvd
Lawton OK 73505
- Schedule a campus visit for a tour of Cameron University.
Completed AS or AA in Oklahoma prior to transferring:
If you have completed the requirements for an Associate in Arts or Associate in Science degree at an Oklahoma State System institution you will be accepted as having fulfilled the general education requirements for bachelor of arts or bachelor of science degrees. Additional requirements will apply when:
- Prerequisites for upper division courses are lacking,
- Grade levels required by Cameron in order to pass a class have not been attained, or
- Professional licensing or certifying agency requirements exceed junior college general education requirements
When to apply for Re-Admission:
All Cameron applicants and former Cameron students who did not attend CU during the previous academic year must apply for re-admission and meet the current academic requirements.
Checklist for Admitted Transfer Students
Once you have been admitted, you will need to complete the list of items below:
- Register to attend Orientation (if transferring fewer than 15 credit hours)
- If applicable, complete all initial course placement (such as CPT, Residual ACT, CLEP, etc.) with the Testing Center
- Transfer current financial aid, complete your FAFSA, apply for scholarships, and learn about other financial assistance resources through the Office of Financial Assistance
- If applicable, apply for student housing in Shepler Center or Cameron Village
- Schedule an appointment with the Academic Advising Center and bring copies of your transcripts, testing scores, and tentative schedule of classes in which you plan to enroll
Contact Info
Cameron University
Office of Admission
227 North Shepler Center
Lawton, OK 73505
Toll Free 1-888-454-7600
Local 580-581-2289


text:
3 Filters You'll Actually Use
- How to import presets ?
- Compatibility with macOS Catalina
- My plug-in is not shown in Pro-Tools plug-ins list
- How to resize plugin's GUI ?
- Analog Lab & V Collection mappings unresponsive in Logic
- How to insert a third party instrument in my favourite DAW?
- I have a black screen / broken UI, what should I do ?
- Bug, issue or crash with the V Collection plugin(s) ?
- Setup a MIDI controller in my favorite DAW
- Program Changes in V-Collection 6
- Program Changes in V-Collection 4
- How to insert a third party effect in my favorite DAW?


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Coach Borchers is excited about the opportunities God is planning for the revitalized EC soccer programs. He noted during his introduction to the EC Athletic staff and current soccer teams that he has three primary passions are: serving God, his family, and soccer.
Scott comes to EC with an impressive breadth of experience. He played at Piedmont College (1995-1998) as a "Four-year starter and three-year captain". He earned distinction as an all-conference player (1996-1998), selection to the 1997 NAIA All-South Region Team, and earned All-American Honorable Mention in 1997. Scott also played at the semi-pro level as a member of the "Bluebird Premiere League", New Zealand in 2000.
Coach Borchers' coaching experience is also noteworthy. Scott has coached at the Georgia Futbol Club in Lilburn, GA, at the North Georgia Soccer Association in Clarkesville, GA, and from 2003-2006 he served as the Head Coach for Men's and Women's Soccer at Truett-McConnell College in Cleveland, GA. Scott led the 2006 Truett-McConnell Men's team to a 11-4-4 record, their first winning season in 10 years. He was also responsible for a similar result with the Women's program, leading the team from a 1-17 record to a 10-9-2 record and 3rd place in their conference in 2006. These were remarkable reversals of direction in only three full seasons.
Scott was recognized by his coaching peers as the 2006 GJCAA Region 17 Coach of the Year. Coach Borchers holds a NSCAA Advanced National Diploma. Borchers earned his Masters degree in Physical Education with a Coaching Specialization from Ball State University (08).
Scott and his wife Audrey, with their sons Cole and Kale, are already becoming an integral part of the EC Community.
Please feel free to contact Coach Borchers if you are interested in becoming a part of the EC Soccer program.
Click here to email Scott Borchers.


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Alcamat needed a new logo design and created a contest on 99designs.
A winner was selected from 92 designs submitted by 26 freelance designers.
Logo design for ice creamery, gelato and smoothy parlor. Logo is "Tingles" with the tag line "fun on your tongue".
It is ice cream with a difference and we need a logo to reflect this unique offer.
fun on your tongue
Accepted File Formats:
Vector Formats (.eps, .pdf or .ai)
Logo must be in vector format and appeal to consumers between the ages of 5 to 45 years of age. Design needs to be fresh, fun and relevant.
Design needs to be supplied in full color and mono (B&W) and needs to be uncomplicated in design to enable it to be clearly communicated on all formats (mail, email etc).
Design of outlets will primarily be brilliant white, so logo will be set against a white background. Initial thoughts on logo colors are pinks, lavenders or soft rainbow colors. Design needs to be fun, eye catching and long lasting
Find out how a design contest works or learn more about our logo design services.


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You are here
Our Best Before-and-After Kitchens
Here, some of our most memorable kitchen renovations in stark before-and-after contrast
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Renovations are part and parcel of owning a home, and while few are stress-free (Hmm—granite or marble, hardwood floors or subway tiles?), the end result can be stunning. We have collected some of our most memorable kitchen renovations here in stark before-and-after contrast to inspire readers who may be staring down the abyss of renovation. Read on for the fabulous results.
The kitchen needed a sturdier island that better fit the scale of the space. Appliances integrated into the custom cabinets by Casa Verde give the kitchen a furniture feel that blends with the adjoining living room. The island chandelier and the hanging lantern between the wall cabinets are from Dennis & Leen.
See the "before" photo on the following slide.
The original layout of this kitchen was large and utilitarian, appropriate for raising a busy family. With the kids out of the house and homeowner Susan Brunn living more independently, she desired a more updated, stylish look for her kitchen.
See another view of the updated kitchen on the following slide.
The updated kitchen is much brighter and more cheerful than the previous one. Wavy handmade glass imported from Germany and installed in cabinet fronts reflects light and adds character to the space. "Calacatta Gold" marble countertops give the space an airy, lighter feel.
Photographs: Werner Straube
Design: Rosemary Merrill
Explore the rest of this remodeled suburban Minneapolis home here.
Prior to renovation, this kitchen was narrow and unremarkable.
Above, homeowner Stephen Heavner enjoys his new oversized island, which was designed to emulate a tall farmhouse table with mahogany turned legs and a custom beadboard base.
See another angle of the updated kitchen on the following slide.
Designer (and co-homeowner) Bob Williams incorporated a mix of materials—Carrara marble, honed black granite, stainless steel, and subway wall tiles—in the expanded space. A 1936 Magic Chef range adds vintage appeal.
Photographs: Colleen Duffley
Design: Bob Mitchell
Wooden cabinetry lining the walls made Trish Scalia's kitchen seem dark and constricted.
One island was replaced with two—one for cooking, the other for cleaning—to ease traffic flow. Pendant fixtures from Circa Lighting illuminate the counters. Stools from Restoration Hardware add a touch of rustic charm at the island for casual seating.
Photograph: Francesco Lagnese
Kitchen Design: Nancy Thornett
The original kitchen was spacious but not comfortable or inviting. There were two large existing islands, including this large trapezoid one.
The two islands were combined into one large island, introducing more balance to the space. With seating for six, the island features "Amsterdam Bar Stools" in blue from the Suzanne Kasler Collection for Hickory Chair. Three nickel-banded pendants from Lauren by Ralph Lauren for Circa illuminate the kitchen and visually fill spatial volume above the island.
See this kitchen remodel from another angle on the following slide.
Previously, the knee wall separating the two rooms had little functional purpose.
Now, the granite-topped cabinets against the knee wall serve as a staging area and provide extra storage underneath.
Photographs: John Bessler and Peter Rymwid
Design: Julia Kleyman
The countertop in this original kitchen broke up the room, but the addition to the back of the house allowed the homeowners to completely renovate and open up the space.
In the new kitchen, a window above the sink was high on homeowner Ellen Conley's wish list. This window embraces the historic language of the original windows, notes architect Donald Lococo. The massive island, stained in a delightful chocolate brown, serves as the focal point of the kitchen work area.
See the remodeled breakfast room on the following slide.
Two steps up from the family room, the breakfast area is bathed in light from new windows that also repeat the unusual grid of the house's original windows.
Photographs: Gordon Beall
Design: Mary Jo Donohoe
Lacking flow, this kitchen seemed stuck in the '80s.
The new traditional-style kitchen is more open. New custom-built cabinets in creamy white now complement the architectural details of the house and provide generous storage—a must-have for homeowners who love to cook and entertain. A peninsula was removed to open the kitchen to the family room, and a large island painted a soft gray now anchors the space. To bring in more natural light, two small kitchen windows were replaced with taller ones that rise from the countertops and symmetrically flank the range.
Photograph: Emily Followill
Design: Debbie Cummins
When he began this redo, the kitchen was "state-of-the-art 1980s," laughs designer Eric Lysdahl, who worked with a kitchen design company on the makeover.
"With no redeeming interior architectural features to start with, I was able to do a complete renovation that included drawing all interior moldings, millwork, and ceiling details," explains Lysdahl. The "blank slate" allowed him to create a working kitchen with great flow and a spacious center island for cooking and casual dining.
Photograph: John Bessler
Design: Eric Lysdahl
See the rest of this revamped Connecticut Tudor-style home here.
Both narrow and short, with limited storage space, this kitchen was due for a makeover.
The galley kitchen was updated with new floor-to-ceiling cabinets (to maximize storage space) and Calcutta marble countertops that were designed to complement the elegant millwork in the home's main living area. The cabinets are glazed with a subtle honey-toned stripe, and the ceiling is painted a deep taupe to highlight the elaborate new crown molding. Floor tiles laid on the diagonal "blow out the space and make it seem larger," explains designer Gerald Pomeroy.
Photograph: Gordon Beall
Design: Gerald Pomeroy
This Scottsdale condominium had not been updated since its construction in 1979. "It was in dire need of a lift to today's standards," says homeowner and designer Christopher Coffin. The icy white kitchen lacked character and warmth.
The only room in the condominium in which Christopher opted to retain the original white marble floor tiles was the kitchen, where, he reasoned, they contributed to his vision of chic French style. Getting that look required a complete transformation with all new cabinetry, countertops and appliances.
Photograph: Michal Venera
Design: Christopher Coffin
Blue cabinets against white walls gave this kitchen a depressing pallor, which was only emphasized by the high ceilings and expansive wall space.
The kitchen was transformed with flame-mahogany trompe l'oeil over gray Formica cabinets. Bamboo details and bright colors give the space a West Indies feel. The brightest hue, a snappy lemon-lime on the kitchen's far wall, lights up the darkest part of the space, while a duskier chartreuse defines the adjacent entry.
Photograph: Bruce Buck
Design: Michael Connors
A dreary kitchen with 1960s cabinetry and a worn linoleum floor begs for an update.
New painted cabinets with a mix of open shelves and glass-front doors were added. A vintage-looking apron sink with bridge-style faucet blends easily with a modern stainless-steel stove, vent hood, and dishwasher. A blue-and-white color scheme is warmed by coral accents.
See another view of this remodeled kitchen on the following slide.
The kitchen's dining area is centered around a functional 19th-century cookstove, which was lovingly refurbished with extra-fine steel wool and stove-black polish–"just enough to show its age nicely," says designer Liz Mitchell. Accessories reflect the stove's vintage styling: pewter platters, iron sconces, a pewter chandelier, and white stoneware.
Photograph: Kevin Lein
Designer: Liz Mitchell
The biggest obstacles to overcome in this kitchen were an outdated heating system and the location of the kitchen sink, which was in the center island facing away from the windows.
The kitchen received a mechanical workover as well as some cosmetic changes. The radiator and upper cabinets were removed to make room for open shelving, the sink was relocated to the window wall, and a new island was built for casual meals.
Photograph: Gordon Beall
Design: Stephen O'Brien and Eileen Deymier
This former Manhattan apartment kitchen felt constricted with heavy red walls, dated cabinetry, and black countertops.
Instead of replacing cabinets, designer Brad Boles changed their look with wallpaper insets. "We had a limited amount of money to make a major difference, and this was a great trick that I highly recommend," homeowner Jill Zarin says.
Photograph: John Bessler
Design: Brad Boles
The asymmetrical cabinetry gave the kitchen an unpolished feel and did not maximize the usable space.
Cabinets in the butler's pantry were reconfigured to provide a more symmetrical layout. New countertops, a wine refrigerator, and additional refrigerator drawers were added to transform it into a workhorse prep and storage space–perfectly placed between the large kitchen and the dining room.
See this kitchen remodel from another angle on the following slide.
Architect Dan Rew was brought in to relocate the kitchen to the center of the home, creating a family-friendly hub for meals and socializing.
The kitchen work area was shifted from the rear of the home to the heart of it, and 500 square feet were added to accommodate the adjoining breakfast nook and mudroom. An oversized center island was also added, perfect for food prep, art projects, and meals on the fly.
Photograph: John Bessler
Design: Joe Lucas and Parrish Chilcoat
A former fraternity house at the University of Maryland was in desperate need of an update as part of the 2009 Baltimore Symphony Showhouse. The before kitchen had no seating and outdated cabinetry and appliances.
A new cherry island with a bowed limestone top offers seating for two. A Wolf Appliance cooktop and hood puts the chef in the middle of the action. Weathered-finish faucets by Herbeau add charm.
"I like the idea of cooking as theater, and having the cooktop in the island provides for that," says designer Blue Arnold. "Family and friends can interact with the cook."
See the updated kitchen from another angle on the following slide.
Granite countertops from Brazil in Cabernet Brown are finished with wire brushes for a distressed-leather look. Wet Bar Sub-Zero refrigerator drawers and a wine cooler are near the door to the dining room, providing a convenient area for guests to gather out of the main workspace.
Photograph: Gordon Beall
Design: Blue Arnold
The existing kitchen was just nine feet wide, making it seem more like a "bowling alley" than a kitchen, according to designer Mary Douglas Drysdale.
An addition bumped out the kitchen several feet on one side and allowed for a large center island and more seating space in the breakfast room. Wine is stored in cubbies below the island and across from the bar area. To improve the home's rear entrance, an interior stairway that leads to a ground-level mudroom was added.
See another view of this updated kitchen on the following slide.
A secondary sink eases meal preparation time, especially with multiple cooks in the kitchen.
Photograph: Ron Blunt
Design: Mary Douglas Drysdale
The existing kitchen read "outdated" instead of the classic "Old World" style that designer and homeowner Norm Wogan desired.
Only the original Wolf range remains, and even that was recalibrated and repainted. The beautiful old Belgian black stone floor contrasts with new pale Venetian plaster walls. An airy look prevails despite the black floor, thanks to his opening up the room with two pairs of transomed French doors. "I pushed out the bay. The doors, which are made of leaded 'restoration glass' that looks old, bring in light from two different directions," Norm observes.
Photograph: Werner Straube
Design: Norm Wogan
The 18x18-foot kitchen in this 1928 Colonial-style house in Boston had great bones with less-than-desirable aesthetics. White metal cabinets, red linoleum countertops edged in steel, black-bordered pink tile wainscoting, and asbestos floor tiles begged for an update.
The modest kitchen got a modern update with retro appeal. The limited space was maximized with a built-in refrigerator, an appliance garage behind a tambour door, and a niche for the toaster. A wine refrigerator is under the counter.
See this kitchen update from another angle on the following slides.
The kitchen's lone cooktop looks small against the original kitchen's largest wall.
A traditional English-made Aga stove replaced the previous cooktop. The wall behind is set with a bold pattern of white and green tiles with chamfered edges for texture and color.
Photograph: Bruce Buck
Design: Eileen Kollias
While the configuration of this original kitchen did not change, major updates were needed to the cabinetry and countertops.
Brand-new amenities and a cushy cork floor are sharp updates. "The cork is soft and never shows anything," says homeowner and designer Bill Murphy. "It has a grayish cast that is nice with the stainless finishes." The swirling grain of the brown marble countertops complements the variegated coloring of the cork floor. Mirrored backsplashes and a stainless-steel panel behind the range hood reflect the light and make the room feel open.
Photograph: Deborah Whitlaw Llewellyn
Design: Bill Murphy
The existing dining-living room and kitchen shared a cavernous space, dominated by a stone fireplace and vaulted ceilings with dark, weathered trusses. Windows were odd sizes, awkwardly positioned, and trimmed with barn board. "The house had no architectural charm whatsoever," says designer Ken Gemes.
Walls were built to separate the kitchen and the dining-living room. "We needed some distinction between the dining area and kitchen," Gemes explains. The wide doorway still allows for comfortable interaction between the rooms.
The kitchen, redone to encourage casual gatherings, is anchored by a large mahogany-topped island where family and friends congregate. A boxed beam ceiling with beadboard insets and simple cabinets with chrome hardware give the kitchen a vintage feel. A Roman shade in Bijou Stripe from China Seas adds a pop of warm color, and caned-back bar stools from Thomas Pheasant for McGuire offer comfortable seating at the island.
Photograph: Tria Giovan
Design: Ken Gemes
This home's existing galley kitchen was not ideal for the type of entertaining the homeowner's frequently hosted.
Without completely redesigning the kitchen, the couple was able to retain its galley-style layout while making it more hardworking and aesthetically pleasing. Cabinets were torn out and replaced with recessed-panel Shaker-style ones, which were then painted sunny yellow, a departure from the suite of whites that illuminate most of the rest of the house. Brass hardware from the existing cabinetry was nickel-plated to give the recycled items modern spirit.
The terra-cotta tiles on the kitchen floor were exchanged for limestone. In the breakfast area, a round table and modern wicker chairs are set in front of a wall with soaring windows that light up the space and afford views of the beautiful garden.
Photograph: Erik Johnson
Design: Loi Thai
Hungry for more renovations? Check out this Before and After Hollywood home.


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Staff report
The Twin City Hawks Squirt 2 youth hockey team defeated Arlington, 8-1, on Sunday.
Eleven seconds into the game, Twin City's Therron Glynn opened the scoring with a goal off an assist by Joe Steffey. Additional Twin City goals were scored by Shea Arsenault, Lucas Flagg, DJ LaCross, Aaron O'Connor and Joe Steffey. Assists were made by Flagg, Josh Leider and Steffey.
Strong defense was played by Hunter Arsenault, Justin Boussom and Tristan Gallant. The Twin City Hawks play in the Valley Youth Hockey League and the Squirt 2 team remains undefeated this season.


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Ready Made Rigs
A range of Ready Tied Rigs for Carp Fishing, including Drennan Carp Match Hair Rigs and Method Bandits; Korda Zig Rigs, and ESP Carp Rigs, Chod Rigs, Mega Method Rigs and Strip Teaze Combi Rigs.
We have lots more products in store than currently displayed here. If you can't see what you are looking for, please contact us for advice. We can also take your order over the phone (01323) 460911.


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I was delighted to find this piece while searching for info on the new-to-me Shelly Manne and Andre Previn recordings, and the XRCDs in particular. I appreciate the justice you have done to this man's story. While he might not see it like we do, the man has left some astounding work, work that a 24 year old hardcore punk enthusiast in Ohio can find in the year 2014 and go "wow" over. As a teacher of digital audio and a lightweight recording engineer, I salute you and Mr. DuNann both.
The Search for Roy DuNann
The song was, improbably, "I'm an Old Cowhand," and it began with Shelly Manne striking a woodblock in the right channel, and the blows carried in a perfectly defined acoustic space that included me. Then Rollins' tenor sax came in, so real in the left channel that I believed I could walk up and touch it. Deadpan, Rollins bit off the notes of Johnny Mercer's cowboy melody, the details of his pronunciation audible in his reed, now raspy, now clarion-clear.
The label was Contemporary, and the back of the album jacket said, "Recorded at Contemporary's Studios, Los Angeles. Produced by Lester Koenig. Sound by Roy DuNann." What made the sound truly astonishing was the recording date: March 7, 1957.
I found other Contemporary albums, and discovered some extraordinary music, such as Art Pepper Meets the Rhythm Section and Sonny Rollins & the Contemporary Leaders and Teddy Edwards' Teddy's Ready. The sound of these albums had a naturalness and sense of space that I had never heard before—except in live music. And that purity of sound was achieved in the very early days of stereo, in 1957 and 1958 and 1960. Who the hell was this Roy DuNann?
It was not easy to find out. Lester Koenig, owner of Contemporary and producer of all of its sessions, died in 1977. He had typically provided voluminous liner notes for each album, but none of them talked about recording techniques or the engineer. Reliable reference works and histories, such as Jazz: The Essential Companion by Carr, Fairweather, and Priestley, and the scholarly West Coast Jazz by Ted Gioia, never mention DuNann, though the latter repeatedly affirms the historical importance of Lester Koenig and his label.
The most comprehensive reference work of all, The New Grove Dictionary of Jazz, contains no entry on DuNann, though it covers the Contemporary label in detail, even praising Koenig's "high standards" and "concern for quality"—without ever mentioning sound. It was easy to find references to Rudy Van Gelder. Van Gelder's quantity certainly exceeded DuNann's, since he engineered hundreds of famous sessions for the Blue Note label in the 1950s and '60s, and has remained active to the present day. But the quality of Van Gelder's early recordings, with their fuzzy pianos and flat soundstages, is not in the same class with Roy's.
The only people with whom I could share my enthusiasm for DuNann's work were jazz engineers and producers. Jim Anderson knew about Roy DuNann. He's one of the most respected engineers on the current scene, responsible for the lick-your-ear sound of Patricia Barber's recordings, and he absolutely lit up (over the phone) when I mentioned DuNann. Anderson remembered his college days at Duquesne, when he first heard some of the DuNann Contemporaries in a friend's dorm room and was stunned by their "beautiful golden round bloom."
Joe Harley knew all about Roy—or rather, Roy's sound. Harley is the producer of several dozen sonically exceptional recordings for labels like AudioQuest and Groove Note and Enja. He had been a DuNann fan since he was in high school in the late '60s. But, like everyone else who admired Roy's work, Harley mused, "I wonder whatever happened to him. I wonder if he's still alive." Harley was the first to tell me that DuNann's last known whereabouts were Arizona.
My respect for DuNann's achievements reached a new level in spring 2001, when I received a batch of Contemporary titles on the JVC XRCD label. They included classics like Art Pepper + Eleven, André Previn's West Side Story, and, yes, Way Out West.
For the XRCD reissue program, JVC engineers Akira Taguchi and Alan Yoshida micromanage every element of the mastering and manufacturing processes in order to get the highest-quality transfer from the original master tape. In its XRCD version, Way Out West was sublime. Another title in the batch was Art Pepper Meets the Rhythm Section, and it made me laugh out loud. No recording from January of 1957 had any right to hit me in the face like that—Pepper's alto fiercely alive and dancing on air, Paul Chambers' bass hitting deep and hard. I had to find Roy DuNann, and ask him how he'd done it.
It was not easy. There was, as far as I could discover, not a single DuNann living in the state of Arizona. There were DuNanns in southern California, but no Roys. Fantasy, Inc. in Berkeley, California, current owner of the Contemporary catalog, couldn't help.


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Graduation with Distinction/Honors
Candidates for associate degree graduation who demonstrate high levels of scholarship through their coursework will graduate with distinction.
"With Distinction" is awarded when students achieve a GPA of 3.500 or better for all undergraduate coursework at Kent State University.
In order for students to be considered for graduation "With Distinction" and have it inscribed on their diploma, a minimum of 32 credit hours must be completed at Kent State University.
The students' unadjusted GPA at the time the associate degree is conferred (which should be unadjusted by the application of the academic forgiveness policy, or course repeat policies) will be used in determining "with distinction."
Candidates for baccalaureate degrees who demonstrate high levels of scholarship throughout their undergraduate years are graduated with institutional honors. Graduation with Institutional Honors is conferred on students who earn baccalaureate degrees with a GPA of at least:
- 3.500 cum laude
- 3.700 magna cum laude
- 3.900 summa cum laude
Institutional Honors are based solely on the GPA earned in all coursework taken at Kent State University, including original grades forgiven under other policies. A minimum of 60 semester hours must be earned at Kent State University to qualify. For the purposes of computing the final GPA and determining honors awards, the GPA is extended to three decimal places and not rounded up.
Honor citations are inscribed on diplomas as follows: cum laude, magna cum laude and summa cum laude.
Honors candidates will be distinguished at the commencement ceremony based on all their institutional academic work completed prior to those courses taken during their final term of enrollment.


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CAMBRIDGE, Mass. – Harvard and Yale split another Ivy League doubleheader at O'Donnell Field Sunday afternoon to give the Crimson a series split with the Rolfe Division-leading Bulldogs. Yale took the opener by an 8-1 score before Harvard came back with a loud 10-3 victory in the nightcap.
Yale (22-15, 10-6 Ivy) took the lead in the nightcap on an RBI single from Trey Rallis (4-4, 3 RBI, HR) but Harvard answered with a long RBI double from Jeff Reynolds and a run-scoring single from Sean O'Hara to take the lead.
Harvard (9-31, 5-11 Ivy) starter Ben Sestanovich (2-1) settled in and threw 5.1 effective innings in which he scattered five singles while striking out four.
Harvard took a 3-1 lead in the fourth on another RBI double, this one from O'Hara (3-3, 2 RBI, 2 BB) before breaking the game open with three runs in the fifth on an RBI double from Reynolds and a long two-run opposite field homer from Jack McGuiggan.
Lefty Will Keuper took over for Sestanovich in the sixth inning and finished the game with four hits against three strikeouts and two late runs in 3.2 innings of work for his first save of the season.
The Crimson iced the game with four runs in the bottom of the sixth as four Yale relievers walked four batters and hit another.
Harvard banged out 10 hits, led by O'Hara's 3-for-3 effort. Dillon O'Neill, Reynolds and McGuiggan all had two hits.
In the opener, Yale lefty Chris O'Hara scattered four hits and struck out nine batters in a complete game effort as he improved to 5-0 on the season. Rallis led Yale with a 3-for-4 effort at the plate including a pair of doubles while Andy Kolmar did some damage from the bottom of the order by batting 2-for-3 with three RBI.
Harvard once again received impressive relief efforts from Matt Doyle (1.1 IP, 0 H) and Zack Olson (1.0 IP, 0 H, 1 K).
The Crimson now looks forward to playing in the Beanpot championship game Tuesday night against Boston College at Fenway Park. Game time is set for 7 p.m.


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The onset of obesity is usually gradual. Symptoms include:
- Increased weight
- Thickness around the midsection
- Obvious areas of fat deposits
It's important to remember that fat deposited in your midsection is as much of a health risk as increasing total body weight. If you are developing a thick midsection even though your weight is not going up, you may be losing muscle mass from disuse along with dangerous fat accumulation in your abdomen. This may place you at increased risk for heart disease.
Revision Information
- Reviewer: Michael Woods, MD, FAAP
- Review Date: 02/2017 -
- Update Date: 03/15/2015 -


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When we think of the future — the awesome future, anyway — it always includes autonomous cleaning robots. We may still be a way's off from The Jetsons' Rosie, but the Vileda Virobi is one giant leap for robot maid kind.
The Vileda Virobi is a circular, spinning bot designed to give your hard floors a gentle scrub. Attach a dust-sucking electrostatic cleaning pad to the bot's velcro base, set it to a 30-minute or 120-minute clean cycle, and then let it rip.
Virobi's autonomous navigation will guide it throughout a room, ping-ponging, off the walls until every square-inch has been covered. The flexible base allows the cleaning pad to bend its way into corners where other bots miss the mark. It seems the robot is only available in Europe right now, but let's hope it invades our shores soon. [Vileda via Appliancist]


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The following marinas have boat slips, berths, and moorings in Providenciales, Turks and Caicos Islands! You have the option of selecting your area of interest directly below. Continue narrowing down your search until you've located the right marina/ yacht club for you with a boat slip/ berth/ mooring that you'll be happy about!
Want to add your facility? Click Here


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Phoenix, AZ 85043
SWC Cotton Ln & Camelback Rd, Goodyear, AZ 85338
We provide real estate solutions that positively impact our customer's bottom line from the ground up.
With development expertise ranging from multi-tenant industrial buildings to multi-million square foot distribution facilities to state-of-the-art skyscrapers, Liberty delivers thoughtfully designed, sustainable properties with our clients, our communities, and our environment in mind.
For many businesses, the first contact with their landlord is in the leasing process. We view this collaborative process as the beginning of a partnership we hope will last many years.
We believe in personalized and timely attention to every property and every tenant from our property managers, technicians, and customer service specialists in every market.


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Designs and variants
Needle roller bearings with machined inner and outer rings
- are used for applications where the shaft cannot be hardened and ground (fig. 1)
- have limited permissible axial displacement (→ product table) of the shaft relative to the housing (fig. 2), which can be extended, if needed, by using a wide inner ring (→ Needle roller bearing inner rings)
Needle roller bearings with a machined outer ring, without an inner ring
- are an excellent choice for compact bearing arrangements if the shaft can be hardened and ground (fig. 3)
enable a larger shaft diameter and a stiffer bearing arrangement compared to arrangements with bearings with inner rings
Axial displacement of the shaft relative to the housing is only limited by the width of the raceway on the shaft. By machining the shaft raceways to the appropriate dimensional and geometrical tolerances, it is possible to obtain bearing arrangements with tighter geometrical tolerances. For additional information, refer to Raceways on shafts and in housings.
- are available open (without seals) or sealed on one or both sides
- are available with or without an inner ring
with D ≤ 17 mm (Fw ≤ 10 mm), are available with non-separable closure rings that act as flanges (fig. 4)
The flanges on larger bearings are an integral part of the outer ring, and the bearings have an annular groove and one or more lubrication holes in the outer ring (fig. 5).
are generally designed as single row bearings, with the exception of RNA 69 (fig. 6) and NA 69 series double row bearings with D ≥ 52 mm (Fw ≥ 40 mm)
The roller and cage assembly and outer ring of a needle roller bearing with flanges form a non-separable unit.
Needle roller bearings with machined rings, without flanges
are separable, i.e. the outer ring, needle roller and cage assembly, and inner ring, can all be mounted separately (fig. 7)
Needle roller and cage assemblies can, depending on the arrangement design, either be mounted:
- together with the outer ring
- together with the shaft
- together with the inner ring
- between the outer ring and shaft or inner ring as the final step
are generally designed with one needle roller and cage assembly
However, wide sizes incorporate two needle roller and cage assemblies immediately adjacent to each other and have an annular groove and a lubrication hole in the outer ring (fig. 8).
To accommodate combined radial and axial loads, needle roller bearings with machined rings can be combined with a needle roller thrust bearing with a centring flange, AXW series, if the outside diameter D of the radial bearing is equal to the flange diameter D1 of the thrust bearing (fig. 9, fig. 10).For additional information, refer to Needle roller thrust bearings.
Sealed bearings
- are available in the (R)NA 49 series with a contact seal made of NBR (effective at keeping the lubricant in and contaminants out of the bearing) on one (fig. 11) or both sides (fig. 12)
- have an inner ring that is 1 mm wider than the outer ring, which maintains the effectiveness of the seals and simplifies the bearing arrangements even when small axial displacements occur
When capped bearings must operate under certain conditions, such as very high speeds or high temperatures, some grease may leak. For bearing arrangements where this would be detrimental, appropriate actions could be taken.
Associated external seals
- can be used for needle roller bearing arrangements (without an inner ring)
can be supplied in various sizes (→ product table)
For information about associated power transmission seals, refer to Seals.
The relatively large quantity of grease in the bearings means they can be operated for long periods before relubrication is required (→ Perform calculations). SKF recommends SKF LGWA 2 grease (table 1), if relubrication is required.
SKF supplies needle roller bearings with different features to facilitate effective lubrication and relubrication.
Needle roller bearings with machined rings:
with flanges and D ≥ 19 mm (F, Fw ≥ 12 mm)
- have an annular groove and, depending on the bearing size, one or more lubrication holes in the outer ring (fig. 5)
- with seal(s)
double row and without flanges
- have an annular groove with one lubrication hole in the outer ring (fig. 8)
without flanges and with an inner ring
- have one lubrication hole in the inner ring for certain sizes (→ product table)
SKF needle roller bearings with machined rings are fitted with one of the cages shown in table 2.
Double row needle roller bearings with machined rings are equipped with two cage assemblies (fig. 6).
When used at high temperatures, some lubricants can have a detrimental effect on polyamide cages. For additional information about the suitability of cages, refer to Cages.


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Whitelisted Fixed Pr Ban Appeal
Discussion in 'Appeal archive' started by Harulily, 30 Nov 2019.


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Hello and Welcome to another Brown Sugar Challenge!!We encourage you all to play along this week. If you are uploading your project to an online gallery, please use keyword BSCB-79 (eg.splitcoaststampers, paper craft planet, etc.)
Thank you to all who participated in last weeks challenge! All of the entries were great.
This week our theme is: Feathers
We would like to thank our sponsor
A Day For Daisies
A Day For Daisies will award one winner a gift card to their store
Here is some inspiration from our design team:


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The IRS has updated Rev. Proc. 2011-47 to reflect changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97).The guidance provides the rules for determining the amount of an employee's ordinary a...
The IRS has released guidance to qualified states regarding how to request an allocation of unused housing credit carryover under Code Sec. 42(h)(3)(D)(iii). The new guidance requires allocation reque...
Health insurance providers (including employers and health insurance companies) now have until March 2, 2020, to furnish to individuals Form 1095-B, Health Coverage, and Form 1095-C, Employer-Provided...
The IRS has clarified which amendments are integral to a plan provision that fails to satisfy the qualification requirements by reason of a change made by the final hardship distribution regulations. ...
The IRS has issued its 2019 Required Amendments List (2019 RA List) for individually designed employee retirement plans. Beginning with the 2019 list, all RA Lists will apply to both Code Sec. 401(a) ...
A one-year extension has been granted for applying the Code Sec. 987 final regulations, and certain related final and temporary regulations covering foreign branch transactions of U.S. corporations. T...
The IRS has updated its guidance that identifies circumstances under which a disclosure on a taxpayer's income tax return with respect to an item or position is "adequate" for reducing the under...
The IRS has released the annual inflation adjustments for 2020 for over 60 tax provisions, including the income tax rate tables. The IRS issues these cost-of-living adjustments (COLAs) each year to re...
The IRS has released the 2020 cost-of-living adjustments (COLAs) for pension plan dollar limitations, and other retirement-related provisions.Highlights of 2020 ChangesThe contribution limit for emplo...
The IRS has released guidance that updates Rev. Proc. 2010-51, I.R.B. 2010-51, 883 to reflect changes made to Code Secs. 67 and 217 by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). Rev. Proc. 2010-...
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures in Rev. Proc. 2015-13, I.R.B. 2015-5, 419, apply. This guidance updates and sup...
The IRS has proposed updated life expectancy and distribution period tables under the required minimum distribution (RMD) rules. The proposed tables reflect the general increase in life expectancy, an...
The IRS Large Business and International Division (LB&I) and Small Business/Self-Employed Division (SBSE) have issued a joint directive to provide instructions to LB&I and SBSE examiners on th...
The IRS Large Business and International (LB&I) has added a new active campaign to the IRS website called "IRC 965." The campaign's goal is to promote compliance with Code Sec. 965, Treatmen...
The IRS urged taxpayers to act now to ensure the smooth processing of their 2019 federal tax return. This reminder, first in a series, was aimed to help taxpayers get ready for the upcoming tax filing...
The interest rates on underpayments and overpayments of Arizona taxes for the period January 1, 2020, through March 31, 2020, are unchanged from the previous quarter at 5%.Previous Interest RatesThe i...
The California Office of Tax Appeals (OTA) has held that value-added tax (VAT) imposed on the provision of services should be included in the state apportionment formula sales factor. In a precedentia...
For corporate and personal income tax purposes, Idaho State Tax Commission issued W-2 E-Filing Guide clarifying that the state does not make changes to taxpayers' record layouts or other require...
For corporate income tax purposes, the Oregon Department of Revenue has informed taxpayers that any changes to their state withholding must be made on Form OR-W-4 beginning January 1, 2020 as the new ...
For 2020, the Texas interest rate on overpayments and underpayments is 5.75%.Interest RatesThe interest rate for 2019 was 6.50%. Prior years' interest rates may be viewed at https://comptro...
Utah announced the following local sales and use tax rate changes, effective January 1, 2020.Local Option TaxBrighton Town (newly incorporated town in Salt Lake County) imposes a 1% local option tax.T...
Licensed out-of-state firearms dealers with nexus with Washington must collect sales and use tax and retailing business and occupation (B&O) tax.Out-of-state DealersNexus is established by a physi...
The IRS has released new proposed rules related to charitable contributions made to get around the $10,000/$5,000 cap on state and local tax (SALT) deductions. The proposed regulations:
The IRS has released new proposed rules related to charitable contributions made to get around the $10,000/$5,000 cap on state and local tax (SALT) deductions. The proposed regulations:
- incorporate the safe harbor in Notice 2019-12 for individuals who have any portion of a charitable deduction disallowed to the receipt of SALT benefits;
- incorporate the safe harbor in Rev. Proc. 2019-12 for business entities to deduct certain payments made to a charitable organization in exchange for SALT benefits; and
- clarify the application of the quid pro quo principle under Code Sec. 170 to benefits received or expected to be received by the donor from a third party.
SALT Limit
An individual's itemized deduction of SALT taxes is limited to $10,000 ($5,000 if married filing separately) for tax years beginning after 2017. Some states and local governments have adopted laws that allowed individuals to receive a state tax credit for contributions to certain charitable funds. These laws are aimed at getting around the SALT deduction limit by creating a charitable deduction for federal income tax purposes.
The IRS issued final regulations in June 2019 that provide that the receipt of a SALT credit for a charitable contribution is the receipt of a return benefit (quid pro quo benefit). Thus, the taxpayer must reduce any contribution deduction by the amount of any SALT credit received or expected to receive in return. The regulations contain a de minimis exception if the SALT credit does not exceed 15 percent of the taxpayer's charitable payment.
A taxpayer is not required to reduce the charitable contribution deduction because of the receipt of SALT deductions. However, the taxpayer must reduce the charitable deduction if it receives or expects to receive SALT deductions in excess of the taxpayer's payment or the fair market value of property transferred.
Payments by Individuals
A safe harbor was provided in Notice 2019-12 for individuals who have a portion of a charitable deduction disallowed due to the receipt of a SALT credit. Under the safe harbor, any disallowed portion of the charitable contribution deduction may be treated as the payment of SALT taxes for the purposes of deducting taxes under Code Sec. 164.
The new proposed regulations incorporate the safe harbor in Notice 2019-12. The safe harbor is allowed in the tax year the charitable payment is made, but only to the extent that the SALT credit is applied as provided under state or local law to offset the individual's SALT liability for the current or preceding tax year. Any unused credit may be carried forward as provided under state and local law.
Payments by Business Entities
The IRS also provided a safe harbor in Rev. Proc. 2019-12 that business entities may continue to deduct charitable contributions in exchange a SALT credit. A business entity may deduct the payments as ordinary and necessary business expenses under Code Sec. 162 if made for a business purpose.
The new proposed regulations incorporate the safe harbor in Rev. Proc. 2019-12. If a C corporation or specified pass-through entity makes the charitable payment in exchange for a SALT credit, it may deduct the payment as a business expense to the extent of any SALT credit received or expected to be received. In addition, the new proposal provides that if the charitable payment bears a direct relationship to the taxpayer's business then it may be deducted as a business expense rather than a charitable contribution regardless of whether the taxpayer receives or expects to receive a SALT credit.
Benefits Received from Third Party
If a taxpayer receives any goods, services, or other benefits from a charitable organization in consideration for a contribution, then the charitable deduction must be reduced by the value of those benefits. If the contribution exceeds the fair market value of the benefits received, then only the excess is a deductible as a charitable contribution.
The new proposed regulations clarify that this quid pro quo principal applies regardless of whether the party providing the goods, services, or other benefits is the charitable organization or not. A taxpayer will be treated under the proposal as receiving goods and services in consideration for the taxpayer's charitable contribution if, at the time the taxpayer makes the payment or transfer, the taxpayer receives or expects to receive goods or services in return.
Final regulations provide rules on the attribution of ownership of stock or other interests, for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The regulations also provide rules to determine whether a CFC receives rents in the active conduct of a trade or business, for determining the exception from foreign personal holding company income.
Final regulations provide rules on the attribution of ownership of stock or other interests, for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The regulations also provide rules to determine whether a CFC receives rents in the active conduct of a trade or business, for determining the exception from foreign personal holding company income.
The regulations adopt without change, proposed regulations published on May 20, 2019 ( NPRM REG-125135-15).
Attribution of Ownership
The regulations provide specific rules for applying principles similar to those in the Code Sec. 958(b) constructive ownership rules when determining related person status under the foreign base company sales income rules. The determination of related person status is relevant for many purposes, including whether certain types of income can be characterized as subpart F foreign base company sales or service income.
A person is a related person with respect to a CFC if the person is:
- an individual who controls the CFC,
- an entity that controls or is controlled by the CFC, or
- an entity that is controlled by the same person that controls the CFC.
Rules similar to those for determining stock ownership in Code Sec. 958 apply for purposes of determining whether a person is a related person. The regulations limit the application of the downward attribution rules in Code Sec. 318(a)(3), which apply by reference to the Code Sec. 958 stock ownership rules, and which attribute ownership downward from the owner of an entity to an entity. The downward attribution rules are applied regardless of the size of the ownership interest in a partnership, estate, or trust, but are applied to corporations based on a 50-percent or more ownership interest.
The regulations address concern that application of the downward attribution rules could inappropriately treat entities (including CFCs) that do not have significant relationships with each other as related persons. Accordingly, the regulations provide that the downward attribution rules of Code Sec. 318(a)(3) and Reg. §1.958-2(d) will not apply for purposes of determining related person status under the foreign base company sales income rules.
The change does not preclude a corporation, partnership, trust, or estate from being treated as controlled by the same person or persons that control the CFC under other rules that remain applicable for the related person rules.
Additionally, an anti-abuse rule is provided with respect to the option attribution rule in Code Sec. 318(a)(4). The option attribution rule in Code Sec. 318(a)(4) and Reg. §1.958-2(e) will not be applied to treat a person with an option as owning the stock or an equity interest for purposes of the related person rule if the principal purpose of using the option was to cause a person to be treated as a related person.
The regulations also incorporate a similar rule issued in section 7(d) of Notice 2007-9, 2007-1 CB 401. The rule applies if the principal purpose for the use of an option is to qualify dividends, interest, rents or royalties paid by a foreign corporation for the Code Sec. 954(c)(6) CFC look-through exception from foreign personal holding company income. The rule applies to tax years of CFCs beginning after December 31, 2006, and ending before November 19, 2019, and to tax years of U.S. shareholders in which or with which such tax years end.
Personal Holding Company Income
The regulations modify the foreign personal holding company rules for amounts paid or incurred by a CFC in connection with the CFC's rental income and the active rents exception. Rents are excluded from foreign personal holding company income if the rents are:
- received from a person other than a related person, and
- from the active conduct of a trade or business.
If rents are from leasing property as a result of marketing activities, there must be a substantial marketing organization in order to meet the active trade or business test. Under a safe harbor, an organization is substantial if active leasing expenses equal or exceed 25 percent of adjusted leasing profit. If the CFC receives rents from property it does not own, the substantiality of the organization is determined net of those rent payments.
The regulations extend the rule to apply to royalties in addition to rents. As a result, the substantiality of the organization is determined under the safe harbor net of the rents or royalties paid or incurred by the lessor CFC, for the right to use the property (or a component part of the property) that generated the rental income.
Applicability Date
The regulations generally apply to tax years of CFCs ending on or after November 19, 2019, and to tax years of U.S. shareholders in which or with which such tax years end. The regulations on the downward attribution rule, and the option anti-abuse rule for use of the option to treat a person as a related person with respect to a CFC, apply to tax years of CFCs ending on or after May 17, 2019, and to tax years of U.S. shareholders in which or with which such tax years end, with respect to amounts received or accrued by a CFC on or after May 17, 2019, to the extent the amounts are received or accrued in advance of the period to which such amounts are attributable with a principal purpose of avoiding application of the rules.
The IRS has issued final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A. The BEAT is a minimum tax that certain large corporations must pay on certain payments made to foreign related parties, and was added by the Tax Cuts and Jobs Act ( P.L. 115-97).
The IRS has issued final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A. The BEAT is a minimum tax that certain large corporations must pay on certain payments made to foreign related parties, and was added by the Tax Cuts and Jobs Act ( P.L. 115-97).
The final regulations adopt proposed rules ( REG-104259-18) published on December 21, 2018 (2018 proposed regulations), with certain modifications. The proposed regulations ( REG-112607-19) (2019 proposed regulations) provide rules under Code Secs. 59A and 6031 regarding certain aspects of the BEAT.
Final Regulations
The 2018 proposed regulations provided guidance related to the mechanics of determining a taxpayer's BEAT liability, and addressed application of the BEAT to partnerships, banks, registered security dealers, and consolidated groups. The final BEAT regulations retain the basic approach and structure of the 2018 proposed regulations, with certain revisions.
The final regulations continue to be exclude from the denominator of the base erosion percentage Code Sec. 988 losses with respect to transactions with foreign related parties that are excluded from the numerator of the percentage. The final regulations also retain the add-back method for computing modified taxable income and the computation of base erosion minimum tax amount (BEMTA) on a taxpayer-by-taxpayer basis.
Among some of the more significant changes to the proposed rules, the final regulations:
- adopt the "with-or-within" method to determine the gross receipts and the base erosion percentage of an aggregate group;
- disregard transactions between parties if both parties were members of the aggregate group at the time of the transaction;
- exclude the base erosion tax benefits and deductions attributable to the tax year of a member of an aggregate group that begins before January 1, 2018;
- clarify that payments resulting in a reduction to determine gross income are not treated as base erosion payments;
- require that the determination of whether a payment or accrual is a base erosion payment be made under general U.S. federal income tax law;
- clarify the definition of a "base erosion payment," and generally exclude amounts transferred to, or exchanged with, a foreign related party in certain corporate nonrecognition transactions from that definition;
- clarify the rules for determining the portion of U.S. branch interest paid to foreign related parties;
- provide rules for the treatment of an interest expense determined under a U.S. tax treaty;
include additional detail on the documentation required to satisfy the service cost method (SCM) exception;
- modify the total loss-absorbing capacity (TLAC) exception;
- provide that the additional one percent add-on to the BEAT rate will not apply to a taxpayer that is part of an affiliated group with de minimis banking and securities dealer activities;
- provide that Code Sec. 15 applies only to the change in tax rate set forth in Code Sec. 59A(b)(2) and should not apply to the change in tax rate included in Code Sec. 59A(b)(1)(A) for tax years beginning in calendar year 2018;
- change the Qualified Derivative Payments (QDP) exception;
- clarify the rules regarding how partnerships and their partners are treated for purposes of the BEAT; and
- clarify the anti-abuse rule and certain rules applicable to insurance companies and consolidated groups.
Applicability Dates
The final regulations (other than the reporting requirements for QDPs) apply to tax years ending on or after December 17, 2018. However, taxpayers may apply these final regulations in their entirety for tax years ending before December 17, 2018. Taxpayers may also apply provisions matching Reg. §§1.59A-1 through 1.59A-9 in their entirety for all tax years ending on or before December 6, 2019. Taxpayers choosing to apply the proposed regulations must apply them consistently and cannot selectively choose which particular provisions to apply.
The related Code Sec. 6038A regulations apply to tax years beginning Monday, June 7, 2021. The related consolidated return regulations generally apply to tax years for which the original consolidated return is due (without extensions) after December 6, 2019.
2019 Proposed Regulations
The 2019 proposed regulations provide rules regarding relating to (1) how a taxpayer determines its aggregate group for purposes of determining gross receipts and the base erosion percentage; (2) an election to waive deductions; and (3) application of the BEAT to partnerships.
The 2019 proposed regulations generally apply to tax years beginning on or after the date that the final regulations are filed with the Federal Register. Certain rules, however, have specific applicability dates. In addition, taxpayers may rely on the rules in the proposed regulations in their entirety for tax years beginning after December 31, 2017, and before the final regulations are applicable.
Practitioner's Observations
Arlene Fitzpatrick, a Principal in the National Tax Department of Ernst & Young LLP, told Wolters Kluwer that "there are changes and new proposed rules in the package of final and proposed regulations that are helpful, though not all changes requested through the comment process were made. For example, the rules in the final regulations to exclude, in certain circumstances, from the definition of a base erosion payment amounts transferred to, or exchanged with, a foreign related party pursuant to a specified nonrecognition transaction are welcome. Furthermore, clarifying that a built-in loss recognized on a sale or transfer of property to a foreign related party is not in itself a deduction that causes the payment to be treated as a base erosion payment is helpful. The final regulations however, retain the internal dealings rule whereby a notional payment for purposes of attribution of profits under certain tax treaties may be taken into account for purposes of determining BEAT. Thus, although deductions from internal dealings would not be allowed under the Code or regulations, and only relevant under certain treaties (the regulations do not specify the treaties), the regulations provide such amounts are relevant for purposes of determining BEAT."
The IRS has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain the basic approach and structure of the 2018 proposed regulations ( NPRM REG-105600-18). The final regulations also eliminate deadwood, reflect statutory amendments made prior to TCJA, and update expense allocation rules not updated since 1988.
The IRS has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain the basic approach and structure of the 2018 proposed regulations ( NPRM REG-105600-18). The final regulations also eliminate deadwood, reflect statutory amendments made prior to TCJA, and update expense allocation rules not updated since 1988.
Also adopted are proposed regulations on overall foreign losses, published on June 25, 2012 ( NPRM REG-134935-11), and a U.S. taxpayer's obligation to notify the IRS of a foreign tax redetermination, published on November 7, 2007 ( NPRM REG-209020-86).
A separate set of 2019 proposed regulations were also issued ( NPRM REG-105495-19).
Final Regulations
The final regulations make extensive changes to the rules on the determination of the foreign tax credit. Many of these changes were required to implement the TCJA, including the items discussed, below.
The final regulations provide details on how income is assigned and expenses are apportioned to the Code Sec. 951A global intangible low-taxed income (GILTI) and foreign branch foreign tax credit separate limitation categories added by TCJA.
The regulations provide that, for purposes of applying the expense allocation and apportionment rules, the portion of gross income related to foreign derived intangible income (FDII) or a GILTI inclusion that is offset by a Code Sec. 250 deduction is treated as exempt income. This means that fewer expenses will be allocated to the GILTI category, resulting in a higher foreign source taxable income, a higher foreign tax credit limitation, and a larger foreign tax credit offset with respect to GILTI income.
The regulations also address how the balance of foreign tax credit carryovers prior to the TCJA are allocated across new and existing separate categories. Under a default rule, foreign tax credit carryovers remain in the general category going forward. A taxpayer can elect to reconstruct the carryover regarding a foreign branch. The final regulations provide a simplified rule under which taxpayers can assign foreign tax credits to the foreign branch category proportionately, according to the ratio of foreign taxes paid or accrued by the taxpayer's branches to total foreign taxes paid or accrued by the taxpayer in that year.
The regulations modify the proposed rule for determining foreign branch income based on the U.S. tax-adjusted books and records of the foreign branch. The proposed regulations disregarded transfers of intellectual property (IP) between a foreign branch and its owner if the transfer would result in a deemed payment that reallocates income between the foreign branch category and the general branch category. The final regulations limit the rule to transactions that occurred after the date of the proposed regulations and include an exception for transitory ownership.
The regulations provide rules for the treatment of GILTI for purposes of the interest allocation rules. In general, a controlled foreign corporation (CFC) must allocate and apportion its interest expense among groups of income for purposes of determining tested income, subpart F income and other types of net foreign source income. A U.S. taxpayer must characterize the value of its CFC for allocating and apportioning its own interest expense. A CFC allocates and apportions its interest expense using either the modified gross income (MGI) method or the asset method. The U.S. taxpayer uses the same method to characterize the stock of its CFC. The regulations take into account gross tested income from a lower-tier CFC with respect to an upper-tier CFC for allocating the upper-tier CFC's interest expense when applying the MGI method.
Dividends, interest, rents and royalties (look-through payments) paid to a U.S. shareholder by a CFC were generally allocated to general category income to the extent that they were not treated as passive category income. Because this type of payment made directly by a U.S. shareholder is not included in the GILTI category, the regulations provide that the look-through payments are assigned either to the general category or the foreign branch category. The payments cannot be assigned to the GILTI category.
The final regulations also address certain potentially abusive borrowing arrangements involving loans by U.S. persons to foreign partnerships that artificially increase foreign source income and the foreign tax credit limitation without affecting U.S. taxable income. Under the regulations, the interest income attributable to borrowing through a partnership is allocated across the foreign tax credit separate limitation categories in the same manner as the associated interest expense.
Applicability of Final Regs
The final regulations related to statutory amendments made by the TCJA apply to tax years beginning after December 31, 2017. Regulations that contain both rules that relate to the TCJA and rules that do not relate to the TCJA generally apply to tax years that both (1) begin after December 31, 2017, and (2) end on or after December 4, 2018.
The regulations on the deemed paid credit under Code Sec. 960 apply to tax years that both begin after December 31, 2017, and end on or after December 4, 2018. The final OFL regulations apply to tax years on or after the date the regulations are filed in the Federal Register. The final foreign tax redetermination regulations apply to foreign tax redeterminations occurring in tax years ending on or after the date the regulations are filed in the Federal Register.
Proposed Regulations
Proposed foreign tax credit regulations address changes made by the TCJA, and also respond to issues raised in the 2018 proposed regulations on the foreign tax credit ( NPRM REG-105600-18). The proposed regulations address:
- the allocation and apportionment of deductions under Code Sec. 861 through Code Sec. 865;
- the definition of "financial services income" under Code Sec. 904(d)(2)(D);
- the allocation and apportionment of creditable foreign taxes;
- the interaction of branch loss and dual consolidated loss recapture rules under Code Sec. 904(f) and Code Sec. 904(g);
- the effect of Code Sec. 905(c) foreign tax redeterminations of foreign corporations on the high-tax exception in Code Sec. 954(b)(4) and the required notification and penalty provisions;
- the definition of "personal holding company income" under Code Sec. 954; and
- the application of the foreign tax credit limitation rule to consolidated groups.
Allocation and Apportionment
Under the general rule, a taxpayer may allocate research and experimentation (R&E) expenses to the foreign tax credit separate limitation categories under the sales method or the gross income method. The proposed regulations revise the sales method to provide that R&E expenses are only allocated to income that represents return on intellectual property. When applying these rules, gross intangible income does not include dividends or amounts included under subpart F, GILTI or Code Sec. 1293. As a result, none of a U.S. taxpayer's R&E expenses are allocated to the GILTI category. The proposed regulations eliminate the gross income method for purposes of allocating R&E expenses.
Stewardship expenses are related and allocable to dividends received or to be received from related corporations. The proposed regulations provide that stewardship expenses are allocated to subpart F and GILTI inclusions, to Code Sec. 78 dividends and all amounts included under the passive foreign investment company (PFIC) provisions.
Under the Code Sec. 818(f) allocation rules that apply to life insurance companies, expenses are generally apportioned ratably across all gross income. Under a new rule, the proposed regulations allocate expenses in a life-nonlife consolidated group solely among items of the insurance company that has reserves (separate entity method).
The final foreign tax credit limitations provide a matching rule for a U.S. partner that makes loans to a foreign partnership. Under the rule, the partner's gross interest income is apportioned between U.S. and foreign sources in each separate foreign tax credit limitation category based on the partner's interest expense apportionment ratios. The proposed regulations provide the same rule for loans from partnerships to U.S. partners (upstream partnership loans).
Portions of the 2007 temporary regulations on foreign tax redeterminations ( T.D. 9362) are reproposed so that taxpayers can provide comments on the rules in light of the changes made by the TCJA. The proposed regulations address foreign tax redeterminations that affect the deemed paid credit under Code Sec. 960; procedural notification rules; and penalties for failure to notify the IRS of a foreign tax redetermination.
The proposed regulations require taxpayers to account for foreign tax redeterminations of foreign subsidiaries on an amended return that reflects the revised foreign taxes deemed paid under Code Sec. 960 and any changes to the taxpayer's U.S. tax liability. This reflects the repeal of the pooling mechanism to account for redeterminations of foreign taxes.
A transition rule provides that post-2017 redeterminations of pre-2018 foreign income taxes must be made by adjusting the foreign corporation's taxable income and earnings and profits and post-1986 undistributed earnings and income taxes in the pre-2018 year to which the redetermined foreign taxes relate. The proposed regulations also provide that the foreign tax redetermination rules cover situations in which the foreign tax redetermination affects whether or not the CFC qualifies for the high-tax exceptions under GILTI and subpart F.
Additional Rules
Additional provisions in the proposed regulations:
- modify the definition of a "financial services entity" by adopting a definition of "predominately engaged in the active conduct of a banking, insurance, finance, or similar business" and "income derived in the active conduct of a banking, insurance, finance, or similar business" that is generally consistent with Code Secs. 954(h), 1297(b)(2)(B), and 953(e);
- provide more detailed guidance on the allocation and apportionment of foreign income taxes, and generalize the rules to apply to statutory and residual groupings;
- provide a new ordering rule for overall foreign loss recapture that addresses additional income recognition under the branch loss recapture and dual consolidated loss recapture rules: the amounts are not taken into account for purposes of the ordering rules until Code Sec. 904(f)(3) amounts are determined;
- clarify the rules that apply to jurisdictions that do not impose corporate income tax on CFCs until earnings are distributed. or where foreign tax is contingent on a future distributions, for purposes of the high-tax exception in Code Sec. 954(b)(4);
- apply the principles for allocating and apportioning foreign income taxes for purposes of Code Sec. 965(g); and
- update the Code Sec. 1502 regulations relating to the computation of the consolidated foreign tax credit to reflect changes in the law, and add new rules for the determining the source and separate category of the a consolidated NOL, as well as the portion of a consolidated net operating loss (CNOL) that is apportioned to a separate return year of a member.
Applicability of Proposed Regs
The proposed regulations are generally proposed to apply to tax years that end on or after the date the proposed regulations are filed in the Federal Register, with exceptions. For example, the rules for R&E expenses are proposed to apply to tax years beginning after December 31, 2019. However taxpayers on the sales method for tax years beginning after December 31, 2017, and before January 1, 2020, may rely on the proposed regulations if the rules are applied consistently. Thus, a taxpayer on the sales method for its tax year beginning in 2018 may rely on the proposed regulation, but must also apply the sales method (relying on the proposed regulation) for its tax year beginning in 2019.
Practitioner's Observations
WK: Were you surprised by anything in the final regs?
Martin Milner: The final regulations are generally consistent with the proposed regulations and do not include any major surprises. The changes and clarifications that are in the final regulations are largely helpful. As would be expected, most of the new provisions are in the proposed portion of the package.
WK: With the proposed regs are there areas that you can see may result in pushback? If so why?
Martin Milner: The business community is likely to comment on the proposal to apportion stewardship expenses to dividends, subpart F income and GILTI (including IRC Section 78 gross-ups) because many had hoped that stewardship expenses would not be apportioned to GILTI.
WK: How did you feel about the R&E Expense Apportionment changes?
Martin Milner: The mandatory sales-based apportionment of R&E expenses to all gross intangible income related to the relevant product SIC code will be complicated in practice. However, it is helpful that the proposed rules specifically exclude dividends, subpart F income and GILTI.
The IRS has released guidance that provides that the requirement to report partners' shares of partnership capital on the tax basis method will not be effective for 2019 partnership tax years, but will first apply to 2020 partnership tax years.
The IRS has released guidance that provides that the requirement to report partners' shares of partnership capital on the tax basis method will not be effective for 2019 partnership tax years, but will first apply to 2020 partnership tax years.
2019 Reporting
For 2019, partnerships and other persons must report partner capital accounts consistent with the reporting requirements in the 2018 forms and instructions, including the requirement to report negative tax basis capital accounts on a partner-by-partner basis.
Section 704(c) Gain or Loss
As a clarification, the notice also defines the term "partner's share of net unrecognized Code Sec. 704(c) gain or loss," which must be reported by partnerships and other persons in 2019. Further, the notice exempts publicly traded partnerships from the requirement to report their partners' shares of net unrecognized Code Sec. 704(c) gain or loss until further notice. Solely for purposes of completing the 2019 Forms 1065, Schedule K-1, Item N, and 8865, Schedule K-1, Item G, the notice defines a partner's share of "net unrecognized Code Sec. 704(c) gain or loss" as the partner's share of the net (meaning aggregate or sum) of all unrecognized gains or losses under Code Sec. 704(c) in partnership property, including Code Sec. 704(c) gains and losses arising from revaluations of partnership property.
Section 465 At-Risk Activities
The notice provides that the requirement added by the draft instructions for 2019 for partnerships to report to partners information about separate Code Sec. 465 at-risk activities will not be effective until 2020. The draft of the instructions for the 2019 Form 1065, Schedule K-1, released October 29, 2019, included a new paragraph at page 12, At-Risk Limitations, At-Risk Activity Reporting Requirements, that would expressly require partnerships or other persons that have items of income, loss, or deduction reported on the Schedule K-1 from more than one activity that may be subject to limitation under Code Sec. 465 at the partner level to report certain additional information separately for each activity on an attachment to a partner's Schedule K-1. The new paragraph would require the partnership to identify the at-risk activity, the items of income, loss, or deduction for the activity, other items of income, loss, or deduction, partnership liabilities, and any other information that relates to the activity, such as distributions and partner loans. This requirement in the draft instructions for the 2019 Form 1065 is in addition to long-standing at-risk reporting requirements included in the instructions to the Form 1065.
Penalty Relief
Taxpayers who follow the provisions of the notice will not be subject to any penalty, including a penalty under Code Sec. 6722 for failure to furnish correct payee statements, under Code Sec. 6698 for failure to file a partnership return that shows required information, and under Code Sec. 6038 for failure to furnish information required on a Schedule K-1 (Form 8865).
The IRS has released final regulations that present guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI) under Code Sec. 512(a).
The IRS has released final regulations that present guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI) under Code Sec. 512(a).
Organizations that are otherwise exempt from tax under Code Sec. 501(a) are subject to tax on their unrelated business taxable income (UBTI) under Code Sec. 511(a). Code Sec. 512(a) defines UBTI of exempt organizations and provides special rules for calculating UBTI for organizations described in Code Sec. 501(c)(7) (social and recreational clubs), voluntary employees' beneficiary associations (VEBAs) described in Code Sec. 501(c)(9) and supplemental unemployment benefit trusts (SUBs) described in Code Sec. 501(c)(17).
Covered Entity
"Covered entity" describes VEBAs and SUBs subject to the UBTI computation rules under Code Sec. 512(a)(3). A corporation is treated as having exempt function income for a taxable year only if it files a consolidated return with the organization described in Code Sec. 501(c)(7), (9), or (17). These final regulations add a clause to clarify that the term "covered entity" includes a corporation described in Code Sec. 501(c)(2) to the extent provided in Code Sec. 512(a)(3)(C).
Nonrecognition of Gain
If a property used directly in the performance of the exempt function of a covered entity is sold by that covered entity, and other property is subsequently purchased and used by the covered entity directly in the performance of its exempt function—at any point within a four-year period beginning one year before the date of the sale and ending three years after the date of sale—gain, if any, from the sale is recognized only to the extent that the sales price of the old property exceeds the covered entity's cost of purchasing the other property.
Limitation on Amounts Set Aside for Exempt Purposes
The total amount of investment income earned during the year should be considered when calculating whether an excess exists at the end of the year. Any investment income a covered entity earns during the taxable year is subject to unrelated business income tax (UBIT) to the extent the covered entity's year-end assets exceed the account limit.
Effective Date
The final regulations apply to tax years beginning on or after December 10, 2019.
The IRS has issued Reg. §20.2010-1(c) to address the effect of the temporary increase in the basic exclusion amount (BEA) used in computing estate and gift taxes. In addition, Reg. §20.2010-1(e)(3) is amended to reflect the increased BEA for years 2018-2025 ($10 million, as adjusted for inflation). Further, the IRS has confirmed that taxpayers taking advantage of the increased BEA in effect from 2018 to 2025 will not be adversely affected after 2025 when the exclusion amount is set to decrease to pre-2018 levels.
The IRS has issued Reg. §20.2010-1(c) to address the effect of the temporary increase in the basic exclusion amount (BEA) used in computing estate and gift taxes. In addition, Reg. §20.2010-1(e)(3) is amended to reflect the increased BEA for years 2018-2025 ($10 million, as adjusted for inflation). Further, the IRS has confirmed that taxpayers taking advantage of the increased BEA in effect from 2018 to 2025 will not be adversely affected after 2025 when the exclusion amount is set to decrease to pre-2018 levels.
The regulations apply to estates of decedents dying on and after November 26, 2019.
Special Rule for Post-2025 Decedents
Reg. §20.2010-1(c) provides a special rule in cases where the portion of the credit against the estate tax that is based on the BEA is less than the sum of the credit amounts attributable to the BEA allowable in computing gift tax payable within the meaning of Code Sec. 2001(b)(2). In that situation, the portion of the credit against the net tentative estate tax that is attributable to the BEA is based upon the greater of those two credit amounts.
Inflation-Adjusted Amounts and DSUE Amount
Because the term "BEA" includes the exclusion amount, as adjusted for inflation, the examples in the regulations reflect hypothetical inflated adjusted BEAs. Reg. §20.2010-1(c)(2)(ii), Example 2, illustrates the application of the special rule based on gifts actually made, and would be inapplicable to a decedent who did not make gifts in excess of the date of death BEA, as adjusted for inflation.
Reg. §20.2010-1(c)(2)(iii) and (iv), Examples 3 and 4, illustrate that if a spouse dies during the increased BEA period, and the deceased spouse's executor makes the portability election, the surviving spouse's applicable exclusion amount includes the full amount of the deceased spousal unused exclusion (DSUE) amount based on the deceased spouse's increased BEA. The DSUE amount is available to reduce the surviving spouse's transfer tax liability regardless of when transfers are made.
BEA Calculations
The final rules explain how to determine the extent to which a credit allowable in computing gift tax payable is based solely on the BEA. Reg. §20.2010-1(c)(2)(iv), Example 4, addresses the application of the DSUE ordering rule, as well as the computation of the credit based solely on the BEA in a calendar period in which the transfer exhausts the remaining DSUE amount with the result that the BEA is also allowable.
The Treasury Inspector General for Tax Administration (TIGTA) has released a report on suitability checks for participation in IRS programs. TIGTA initiated this audit to assess the effectiveness of IRS processes to ensure the suitability of applicants seeking to participate in IRS programs and to follow up on IRS planned corrective actions to address prior TIGTA recommendations.
The Treasury Inspector General for Tax Administration (TIGTA) has released a report on suitability checks for participation in IRS programs. TIGTA initiated this audit to assess the effectiveness of IRS processes to ensure the suitability of applicants seeking to participate in IRS programs and to follow up on IRS planned corrective actions to address prior TIGTA recommendations.
Suitability Checks
The IRS's suitability checks for applicants to the Acceptance Agent, Enrolled Agent, and e-File Provider Programs generally ensured that only reputable individuals were accepted in the programs during fiscal year 2018. Further, the IRS's continuous suitability checks also ensured that individuals accepted in the programs prior to the initial suitability checks had not engaged in criminal activity warranting removal from the program. TIGTA also identified that when the Federal Bureau of Investigation reported a criminal history for an applicant, the adjudication process was inconsistent depending on the program to which the individual was applying. Finally, the IRS did not take sufficient actions to address the fraudulent submission of fingerprint cards by some applicants to pass their background investigations.
TIGTA Recommendations
TIGTA recommended that the IRS:
- assess the risk to tax administration of performing inconsistent initial and continuous suitability checks on individuals seeking to participate or enrolled in the e-File Provider, Acceptance Agent, and Enrolled Agent Programs;
- assess the risk of the e-File Provider Program's use of decision matrices to adjudicate an applicant's criminal history that are inconsistent with the matrices used by the Acceptance Agent and Enrolled Agent Programs; and
- work with the Federal Bureau of Investigation to identify additional individuals who may have submitted fingerprint cards that match the fingerprints of another individual.
The IRS agreed with all the recommendations.


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July 15, 2013
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Poland's LOT airline working on rescue plan
WARSAW, Poland (AP) — Poland's LOT airline said Friday it will present a plan to stave off bankruptcy next month after the government indicated that there will be no more money for the lossmaking state-owned company.
Poland's main link to the western world under communism until 1989, LOT has largely struggled since.
LOT spokesman Marek Klucinski said the rescue plan will be presented March 20 and will include layoffs among some 2,000 employees and a deep restructuring of the company and its routes. LOT's most profitable routes are to Chicago and New York.
The latest blow for the 83-year-old airline has been the grounding since Jan. 16 of its two Boeing 787 Dreamliners, which has cost the company 8 million zlotys ($2.5 million) so far. LOT was Europe's first carrier to buy the plane, but has been obliged by Boeing to keep them grounded — in Warsaw and in Chicago— after problems were discovered with batteries on some of the aircraft.
As a result, the carrier will need to extend a lease on three Boeings 767s it currently uses and lease another two for the summer season. The management, under new President Sebastian Mikosz, is also talking to Boeing about the costs generated by the idling.
In 2012, LOT carried about 5 million passengers, but incurred losses of 157 million zlotys, chiefly due to high fuel prices and the changing rate of the zloty. It sought a government loan of some 1 billion zlotys ($312 million) and so far has received around 400 million zlotys to service debts and temporarily stabilize the budget. Poland will need to clear that move with the European Commission, which monitors whether government support violates competition rules.
But Prime Minister Donald Tusk has indicated there will be no more "infusions" or efforts to save LOT "at any cost."
The government owns almost 68 percent of LOT shares. Another 25 percent belong to a group that specializes in restructuring companies, while just under 7 percent are in the hands of employees.
The plan to float LOT on the Warsaw Stock Exchange, possibly this year, remains.
Copyright 2013 Associated Press. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.


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