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This is authored by Matt McClintock, VP of Education for WealthCounsel:
I initially created this article as a resource for members of WealthCounsel, but we share it with the entire industry. To that end, I'm sharing this resource here and encourage attorneys and other advisors in my network to share this, repost, etc. (This is copyrighted, with all rights reserved to me as the original author and to WealthCounsel, LLC. Please give proper attribution when sharing this content in whole or in part. Thanks.)
I offer this not as an all-inclusive dictionary of estate planning terms, but hopefully it will serve as a good resource for folks who are curious about the jargon and alphabet soup we T&E attorneys throw around with such abandon.
Annual Gift Exclusion: This is the amount that someone can give to another person during the calendar year without having to pay gift tax. Under IRC Sec. 2503 the annual gift exclusion is $10,000, but that amount is inflation adjusted periodically. For gifts in 2014-2016 the annual exclusion is $14,000 per beneficiary. Annual gift exclusion amount increases typically get posted by the IRS in a publication in late Q3 or early Q4 each year, but they are adjusted on a different basis than the AEA.
Applicable Exclusion Amount (AEA): This is the amount that someone can leave to their heirs free of estate tax. When ATRA was enacted the AEA was set to $5,000,000 with a trigger for increasing with inflation. For decedents who died in 2014 the AEA was $5,340,000. For decedents dying in 2015, the AEA was $5,430,000. In 2016, the AEA is $5,450,000. AEA increases typically get posted by the IRS in a publication in late Q3 or early Q4 each year.
ATRA: The American Taxpayer Relief Act of 2012. This is the major federal tax legislation enacted by Congress and signed by President Obama in January 2013. Among other things, it established a $5,000,000 estate tax Applicable Exclusion Amount that increases with inflation and added portability, allowing a surviving spouse to use any portion of a deceased spouse's remaining AEA that doesn't get used through the deceased spouse's estate plan.
Basis: Is the tax value of an asset, usually measured by the date on which the asset was acquired. Capital Gains tax is paid based on the increase in value (gain) from the owner's basis to the value when the asset is sold. For example, if you pay $10 for something and it increases over time to $100, you have a basis of $10 and a "capital gain" of $90. If you sell the asset, you pay capital gains tax based on that $90.
- Carry-Over Basis: If you give that property away during your life, the person who receives it has the same basis you had. This is "carry-over" basis. So if they sell it for $100, their basis is still $10 and they pay the tax on the $90 gain. Carry-over basis is generally undesirable, because the person who sells the asset has to pay the capital gains tax liability based on the original owner's "carried over" basis.
- Step-Up Basis: If you die with an asset that has increased in value and it goes to someone, that person generally gets a "step up" in basis to the value measured at your date of death. Assume again that the asset you bought for $10 increases to $100 by the time you die. After you die your kids receive the asset from your estate (valued at $100), and they then sell the asset for $100. Your kids have taxable capital gain of $0 because their basis got "stepped up" in your estate when you died. Strategies that target basis adjustment seek to eliminate carryover basis and give step up basis to your beneficiaries.
BDIT: Beneficiary Defective Inheritor's Trust: This is found in the IRT module. You would select the option to create an Inheritor's Trust.
Beneficiary: This is the person, entity, or group for whom a trust is established. A beneficiary may be a present interest beneficiary, entitled to receive distributions from a trust right now, or a future interest beneficiary, entitled to receive distributions at some point in the future. They may also be vested, where their rights under the trust cannot be taken away, or contingent, where their rights are still subject to conditions that may or may not occur in the future.
Bypass / Credit Shelter Trust: This is the portion of the deceased spouse's property that gets charged against the decedent's AEA (Applicable Exclusion Amount; see that definition). The bypass trust can provide benefits for the surviving spouse or other beneficiaries (or a combination) and typically is designed so that it's not included in the surviving spouse's estate when he or she later dies.
CLT: Charitable Lead Trust: Wealth Docx contains both a standalone version and an option to create as a sub-trust in our templates. With charitable lead trusts the donor can donate an asset's income stream for a period of years to a charity instead of the remainder interest. The remainder interest can then pass to a private party under the direction of the grantor (i.e. grandchild, child, etc.)
CLAT: Charitable Lead Annuity Trust. This is basically the opposite of the CRAT. Here the Settlor establishes a trust and names a charity to receive an annuity amount from the trust for a specified amount of time (the "initial term"). At the end of the initial term the remainder pays back to the Settlor or to other noncharitable beneficiaries named in the trust. The CLAT assemblies are part of the Charitable system in the Advanced part of Wealth Docx.
Clayton Election: This is a very popular method of determining the amount of a deceased spouse's estate that will be set aside for the surviving spouse. The name is based on the case, Estate of Clayton v. Commissioner, 97 T.C. 327 (1991). It requires a trustee or personal representative to decide during the trust administration how big the marital deduction should be. The property set aside for the marital deduction gets transferred to the marital trust, which is set up as a QTIP trust. A 706 (Federal Estate Tax Return) is required to notify the IRS of the QTIP election and disclose the amounts going into the marital QTIP and bypass trusts. The Clayton election is a very flexible marital deduction planning tool and is most desirable for clients who have moderate to nearly-taxable estates, or in times of significant uncertainty in the estate tax.
CLUT: Charitable Lead Uni-Trust. This is basically the opposite of the CRUT. Here the Settlor establishes a trust and names a charity to receive a percentage of the trust's value for a specified amount of time (the "initial term"). At the end of the initial term the remainder pays back to the Settlor or to other noncharitable beneficiaries named in the trust. The CLUT assemblies are part of the Charitable system in the Advanced part of Wealth Docx.
Community Property; CP States: Community Property refers to property acquired by a couple during marriage, or property that is combined – or commingled – between spouses. It only applies in nine states (the "community property states"): Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Texas, Washington, and Wisconsin. Alaska and Tennessee have optional, or elective community property laws, allowing married couples to elect to have jointly-held property treated as community property. The biggest benefit of community property is that the entire value of the property gets a basis adjustment (step up; see that definition) when one of the spouses dies. So if a surviving spouse sells community property after the death of their spouse, the capital gain is based on the increase in value from the first spouse's death (where the basis got adjusted on both spouses' shares) to the value at the date of the sale. This allows the survivor to save money on capital gains tax liability.
Community Property Trust (Alaska or Tennessee): This is a special type of joint revocable trust that takes advantage of special laws in Tennessee and in Alaska that allow people to opt in to the state's favorable community property laws. The value behind the strategy is to allow a married couple to get a "double step-up" in basis – a step up in the deceased spouse's property AND in the surviving spouse's property – when the first spouse dies. (This is a unique feature of community property law, and TN and AK allow people who live in separate property states to elect into community property treatment using these strategies.) The Wealth Docx Community Property Trust assembly is part of the "Joint RLT/Pour-Over" section of the Advanced system in Wealth Docx.
CRAT: Charitable Remainder Annuity Trust. A Settlor establishes this trust and puts property in, keeping the right to receive an annuity payment from the trust for an initial term – either for a term or years or for the Settlor's life. After the initial term the amount remaining in the trust (the "remainder") is distributed to a charity named in the trust. The CRAT assemblies are part of the Charitable system in the Advanced part of Wealth Docx.
CRT: Charitable Remainder Trust: Wealth Docx contains both a standalone version and an option to create as a sub-trust in our templates. This is a tax-exempt irrevocable trust designed to reduce the taxable income of individuals by first dispersing income to the beneficiaries of the trust for a specified period of time and then donating the remainder of the trust to the designated charity. The whole idea of a charitable remainder trust is to reduce taxes. This is done by first donating assets into the trust and then having it pay the beneficiary for a stated period of time. Once this time-frame expires, the remainder of the estate is transferred to the charities deemed as beneficiaries.)
CRUT: Charitable Remainder Uni-Trust. A Settlor establishes this trust and puts property in, keeping the right to receive a percentage, or unitrust amount, of the trust assets for an initial term – either for a term or years or for the Settlor's life. After the initial term the amount remaining in the trust (the "remainder") is distributed to a charity named in the trust.The CRUT assemblies are part of the Charitable system in the Advanced part of Wealth Docx.
DAPT: Domestic Asset Protection Trust. This is a type of irrevocable trust that allows a client to set aside assets in trust and protect those assets from creditor claims. The DAPT is established under the laws of a state that has favorable asset protection laws. There is an increasing number of states that have DAPT statutes. Wealth Docx currently includes options for DAPTs under the laws of Delaware, South Dakota, Alaska, and Nevada (as of Q2 2015). The Wealth Docx DAPT assemblies are part of the irrevocable trust section of the Advanced System.
Decanting: This is the process by which a trustee exercises the power to distribute property from one trust (the "originating" trust or the "inception" trust) into a new trust for the benefit of a beneficiary. Decanting is an increasingly popular strategy to allow a trustee to create new, more favorable trust terms for a beneficiary. (Remember that a trustee can only exercise a decanting power consistent with the trustee's fiduciary duties to the beneficiaries).
Delaware Tax Trap (DTT): Refers to the process of exploting the Rule Against Perpetuities (RAP) provision in a trust by allowing a beneficiary to exercise a limited power of appointment in a way that extends the original RAP in the trust. The upshot is that the person who exercises the power causes the property subject to the power to be included in their estate (getting a basis adjustment) when they die. The DTT "loophole" is found in IRC sec. 2041(a)(3) when someone who holds a limited power of appointment exercises it in a way that "…postpone[s] the vesting of any estate or interest… or suspend[s] the absolute ownership or power of alienation of [the interest]… for a period ascertainable without regard to the date of the creation of the power." This is a complicated way of saying that, if someone who holds a limited power of appointment exercises that power to give someone else a presently-exercisable general power of appointment (referred to as a "PEG" power), the person who exercised the limited power of appointment will have estate inclusion over the property for which the PEG power was granted to the other person. Effectively drafting for the DTT often requires modifying a trust's RAP clause and carving out any limitation that would otherwise prevent the exercise of a limited power of appointment this way. It also requires the draftperson to not rely on the state's governing RAP statute, as most states have savings language to prevent "accidentally" triggering inclusion through a DTT.
DING / NING / WING: Delaware / Nevada / Wyoming Incomplete Non-Grantor Trust. This is an irrevocable trust that works primarily as an income tax / capital gains tax strategy. The trust is set up in a state that does not impose state income tax so any highly-appreciated assets sold by the trust will avoid state capital gains tax. Any assets remaining in the trust when the client dies will be included in the client's gross estate, causing a step-up in basis for those assets. Wealth Docx does not have a NING/DING assembly. Creating one requires significant modification of an irrevocable non-grantor gift on trust from the irrevocable trust assembly.
Disclaimer: A disclaimer is a legal "no thank you." It's a technique under IRC Sec. 2518 that allows someone who is entitled to receive property to disclaim that property, allowing it to be distributed somewhere else. In the context of marital deduction planning, the disclaimer method allows the surviving spouse to disclaim property into a bypass trust, providing some flexibility in marital deduction planning.
DSUEA: Deceased Spouse Unused Exemption Amount. This is the amount of AEA that is leftover after the estate plan has allocated part of a deceased spouse's estate exemption to a bypass trust.
- An example is easiest: Husband dies in 2015 and has $1,000,000 in his gross estate. His estate plan is designed in a way that allocates his AEA against that $1,000,000, causing that amount to be put into a bypass trust. Assuming he had made no other gifts that would reduce his AEA, after his estate plan goes into effect he has a remaining unused exclusion of $4,430,000 (his $5,430,000 AEA minus the $1,000,000 put into the bypass trust). His surviving wife now has her own AEA of $5,430,000 plus husband's $4,430,000 DSUEA, for a combined estate tax exclusion of $9,860,000. (This oversimplified example also demonstrates a bit how portability works.)
Executor / Personal Representative: This is the person who is named in a will to administer the estate of a deceased person. The trustee administers the trust; the executor or personal representative administers the probate estate.
FAPT: Foreign Asset Protection Trust. This is more advanced form of asset protection trust that is established under the laws of a foreign country that has even more favorable asset protection for clients. Nevis, the Cook Islands, Jersey, Guernsey, and other remote countries are popular choices. Wealth Docx does not have FAPT options.
Fiduciary: This describes the nature of a relationship where one party owes a series of duties to another party and is held legally responsible for the outcomes of their actions.
Trustees are fiduciaries of trusts, owing duties to the beneficiaries
- Executors are fiduciaries of wills, owing duties to the beneficiaries
- Guardians and conservators are fiduciaries, owing duties to the ward
- Agents and attorneys-in-fact are fiduciaries, owing duties to the principal under a Power of Attorney
- Health Care Proxies or surrogates are fiduciaries, owing duties to the maker of a Living Will / Advance Directive
- Trust protectors may or may not be fiduciaries, depending on the nature of the power that they're given.
Funding: This is the process of transferring property to the trust. The trust must hold title to property in order for it to work, just like a car needs fuel to run. Funding should take place during the trust maker's lifetime. If there is any property that has not been funded to the trust when the client dies, that property must generally go through state probate proceedings before anyone can do anything with that property.
GDOT: Grantor Deemed Owner Trust. This is just an alternative name for the IDGT or IDIT; it's really the same thing. The grantor (the individual who sets up and puts property into the trust) is deemed to be the owner of the trust for income tax purposes, but the value of the trust property is not included in that person's gross estate when they later die.
GPOA: General Power of Appointment. This is a power that is reserved by a trust maker or given to someone else to direct how property in a trust gets distributed. General powers of appointment are included in the power holder's estate under IRC sec. 2041(b)(1). To be a "general" power of appointment, the person holding the power must be able to appoint the property to any one of the following four:
- Their estate
- Their creditors, or
- The creditors of their estate
Grantor / Settlor / Trust Maker: These terms are generally synonymous, though there are subtle, technical differences. In general, they refer to the individual who establishes a trust. Think of it this way: The Settlor / Trust Maker establishes the trust and determines how the trust will operate. The Grantor (a technical tax term) puts his or her property into the trust. (Thus, the Grantor and Settlor-Trust Maker is usually the same person.) The trustee manages and administers the trust for the benefit of the beneficiary or beneficiaries.
GRAT: Grantor Retained Annuity Trust. A GRAT is a sophisticated gifting & wealth transfer strategy based on a special type of irrevocable trust. The Settlor establishes the trust and puts property in, and takes back an annuity (calculated as a dollar amount) for a specific amount of time based on the value of the property in the trust. After the annuity period ends the GRAT pays to other beneficiaries. The GRAT assemblies are part of the Split Interest Trust system in the Advanced part of Wealth Docx.
GRIT: Grantor Retained Income Trust. A GRIT is similar to a GRAT except that the Settlor receives the income stream from the trust assets, rather than a fixed annuity amount from the trust for a specified period of time. After the initial term ends the GRIT pays to other beneficiaries. The GRIT assemblies are part of the Split Interest Trust system in the Advanced part of Wealth Docx.
GRUT: Grantor Retained Uni-Trust. A GRUT similar to a GRAT but instead of taking out an annuity interest the Settlor receives a percentage of the trust (called a unitrust amount) for a specific amount of time based on the value of the property in the trust. After the initial term ends the GRUT pays to other beneficiaries.The GRUT assemblies are part of the Split Interest Trust / Grantor Retained Trusts system in the Advanced part of Wealth Docx.
Guardianship / conservatorship: There are subtle differences between these terms but they're generally considered to be synonyms. This is the court proceeding that is undertaken when an individual lacks the legal capacity to make decisions for themselves or otherwise protect their own interests. That lack of legal capacity can be due to mental or physical illness, injury, or because the person is a minor child. A guardian or conservator is a fiduciary appointed by the court to make decisions on behalf of the disabled person (who is called the "ward"). That fiduciary must provide periodic accountings to the court and the guardianship or conservatorship continues until the ward (disabled person) dies or is no longer under the legal disability. Durable powers of attorney and trust-oriented planning helps avoid guardianship or conservatorship proceedings.
IDGT: Intentionally Defective Grantor Trust. This is a form of irrevocable trust that gets the value of the trust assets out of the client's estate but allows the client to continue to be treated as the owner for income tax purposes only. One of the main advantages is that the (often wealthy) client can add value to the trust by paying the income tax that is due on the income in the trust without those tax payments being treated as additional taxable gifts to the trust. Also, it gets the trust out of the more aggressive income tax rate tables that apply to trusts. The Wealth Docx IDGT assemblies are part of the irrevocable trust section of the Advanced System.
IDIT: Intentionally Deficient (or Defective) Irrevocable Trust, or Income Defective Irrevocable Trust – Just one more acronym for an IDGT or GDOT; all these are synonymous. Their usage is simply a matter of the professional's preference.
ILIT: Irrevocable Life Insurance Trust. This is a very popular form of irrevocable trust that is designed to own high-value life insurance. A client establishes an ILIT and pays enough money into the trust to allow the trustee to buy life insurance on the life of the client (and often, the client's spouse). When the insured person dies, the death benefit of the life insurance is paid into the trust but is not included in the gross estate of the client (thus keeping it away from estate tax liability).
Intestate / Intestacy: This describes the condition of someone who dies without having a will or trust in place. If you don't do your estate planning your property will pass through the laws of intestacy in the state where you resided. The laws of intestacy vary from state to state and are set forth in state statutes.
IRT: Irrevocable Living Trust. A trust that can't be modified or terminated without the permission of the beneficiary. The grantor, having transferred assets into the trust, effectively removes all of his or her rights of ownership to the assets and the trust.
LEPA: Life Estate Power of Appointment Trust. A form of marital deduction-qualifying trust (often testamentary, established through a decedent's will or RLT) that serves as an alternative to a QTIP trust. This form of trust is authorized under IRC sec. 2056(b)(5) and unlike the QTIP, does not require a form 706 (Federal Estate Tax Return) to establish. The LEPA trust must entitle the surviving spouse to receive all income during life, and the life income interest must be over all property for which the marital deduction is sought. (It is possible to give a life income interest in only some of the trust property, but the marital deduction is limited to the value of that property over which the spouse has a life income interest. The spouse must have the lifetime power to appoint property in the trust to themselves or a power (lifetime or testamentary) to appoint the property to his or her estate. Like a QTIP trust, the spouse is the grantor for income tax purposes (IRC sec. 678) and the value of the trust property is included in the spouse's estate (getting a basis adjustment) when the spouse dies (IRC secs. 2041, 1014(a))
LPOA: Limited Power of Appointment. This is a power to appoint property to someone else, but in a way that does not cause the property "subject to that power" to be included in the power holder's estate. Any powers of appointment that are not "General" Powers of Appointment (see definition) are limited powers.
Marital Deduction: The marital deduction allows a married individual to leave property to his or her surviving spouse free of estate tax. U.S. citizens can leave an unlimited amount for their surviving spouse, assuming the survivor is also a U.S. citizen, and assuming the gift qualifies under IRC Sec. 2056. There are lots of different ways a trust or will can determine the amount set aside for the marital deduction, including:
- Fractional formulas, which compute a fraction that gets applied to the dead spouse's estate;
- Pecuniary formulas, which compute a dollar amount to be applied to the dead spouse's estate;
- Specified dollar amounts or percentages, which are typically based on requirements of a premarital agreement or state law;
- The Clayton election, which provides that a trustee can later decide how much to use for the marital deduction; and
- The Disclaimer method, which allows the surviving spouse to decide what property to keep and what property to put into the bypass / credit shelter trust
Marital Trust: This is the portion of the deceased spouse's property that is transferred into a trust that qualifies for the marital deduction. When the surviving spouse later dies the value remaining in the marital trust is included in that spouse's estate.
NICRUT: A net income charitable remainder unitrust Trust: Used as a type of CRT. This trust annually pays to the Recipient(s) the lesser of the trust's net income or an annual "Uni Amount". The Uni Amount is a fixed percentage of the value of the trust assets at the beginning of the trust's tax year. Because the Recipient(s) receive the lesser of the trust's net income and the Uni Amount and because the Uni Amount is a percentage of the value of the trust assets at the beginning of the trust's tax year the annual amount distributed to the Recipient(s) will vary with variations in the trust's income and the value of the trust. Additional contributions may be made to a net income charitable remainder unitrust if that option is selected.
NIMCRUT: A net income with makeup charitable remainder unitrust Trust: Used as a type of CRT. This trust annually pays to the Recipient(s) the lesser of the trust's net income or an annual "Unitrust Amount" in a manner similar to the NICRUT. However, if the net income of the trust is less than the Unitrust Amount in a given year the amount by which the Unitrust Amount exceeds the value of the net income is added to a "deficit account." If the net income of the trust is greater than the Unitrust Amount in a given year that excess amount can be distributed to the Recipient(s) up to the amount of the deficit account. To the extent excess income is distributed to the Recipient(s) the deficit account is reduced. The amount of excess income that can be distributed to the Recipient(s) is limited by the size of the deficit account. Additional contributions may be made to a net income charitable remainder unitrust if that option is selected.
NIMCRUT TO SCRUT = FLIPCRUT: Used as a type of CRT. A FLIPCRUT starts out as a NIMCRUT and then converts to a SCRUT upon the happening of a predetermined event. The event that decides when this switch (FLIP) takes place is referred to as the "triggering event." It may be either a date certain or some other event over which the Grantor has no control.
OBIT: The "Optimal Basis Increase and Income Tax Efficiency Trust" is a form of trust that includes elaborate formula language granting testamentary or lifetime powers of appointment to strategically cause assets to be included in a decedent's gross estate. The formula language is designed in a way that prioritizes estate inclusion for assets with low basis in order to ensure assets get a step-up, and not a step-down in basis when the power holder dies, and includes protective language to cause inclusion up to the decedent's AEA. Rather than describe a specific type of trust, OBIT describes the estate tax inclusion nature of a trust designed to cause assets in the trust to receive a step-up in basis when a beneficiary holding a power of appointment dies. For additional information please see the outline, "The Optimal Basis Increase and Income Tax Efficiency Trust," by Edwin P. Morrow, III, JD, LL.M (tax)
PEG Power: A Presently-Exercisable General Power of appointment, or "PEG" Power is a power that can be immediately exercised by the power holder to appoint property to that person's self, their estate, their creditors, or the creditors of their estate. Possession of a PEG power causes the value of the property over which the power may be exercised to be included in the power holder's estate. PEG powers are used in many contexts, including the application of the Delaware Tax Trap (DTT), discussed above.
POAST: This acronym refers to the "Power of Appointment Support Trust," a strategy discussed in the December 2015 issue of Trusts & Estates magazine. The purpose of the POAST is to allow multiple generations to leverage AEA and GSTT exemptions to accelerate a basis adjustment in appreciated assets by triggering inclusion in the estate of a senior generation by granting that older generation a general power of appointment. A wealthy client establishes a trust for the client's parent and includes a formula general power of appointment to trigger estate inclusion up to (but not over) the parent generation's AEA & GSTT. When that parent generation dies the assets subject to the power get a basis step up, and the assets continue in trust for the benefit of the original client (settlor) and their descendants in a DAPT structure. An additional option would be to include a "hybrid" DAPT structure that allows a trust protector to add the settlor as a possible discretionary beneficiary at a later time.
Portability: The concept of portability allows married couples to effectively combine their individual AEAs, allowing them to pass up to $10,000,000 (adjusted for inflation) to their heirs. If a spouse dies and doesn't use all of his or her AEA in their estate plan, the amount they don't use is called the DSUEA, and the surviving spouse is allowed to use that amount in their own estate tax planning. In order to take advantage of portability the trustee of the deceased spouse's estate must file a federal estate tax return to claim
Pour-Over RLT: There's a temptation to think the pour-over RLT works like a pour-over will, but it's actually quite different. This is a special strategy in Wealth Docx that requires three separate trust documents to make it work. It's designed generally for couples in blended families who live in a community property state (see that definition) and where the couple's planning objectives are really different from each other. The couple will establish a joint RLT to hold their community property or other jointly-owned property, and they will each establish a separate RLT to hold their separate property. When the first of that couple dies, the joint RLT terminates and "pours over" the joint RLT assets into the separate trusts. Those separate trusts then manage the distribution of the property.
Probate: This is the court proceeding that must be undertaken to transfer the property of a dead person to surviving beneficiaries. Probate procedures vary widely from state to state but generally they're public proceedings and can be time consuming and rather expensive. One of the objectives of trust-based planning is to avoid probate, primarily to save time, minimize the likelihood of disputes among heirs, and preserve privacy.
- Domiciliary probate: This refers to probate proceedings where the decedent lived at the time of death (i.e., where the decedent was domiciled).
- Ancillary probate: This refers to possible additional probate proceedings where the decedent owned property, but where he or she did not live. An example would be a Colorado resident who died, but who owned a vacation property in Florida. The domiciliary probate would be in Colorado, and an ancillary probate would be in Florida. (Both could be avoided if the decedent had used a trust!)
QDOT: Qualified Domestic Trust. This is a form of marital deduction that can be used for surviving spouses who are not citizens of the U.S. The QDOT rules are found under IRC sec. 2056A and generally function to defer estate tax on the property transferred to the QDOT until it's distributed from the trust.
QPRT: Qualified Personal Residence Trust. A QPRT works like a GRAT except that the property transferred to the trust is the Settlor's personal residence. The Settlor keeps the right to live in the home for a specified number of years and after that term ends, the Settlor must move out or begin paying rent to the trust, since other beneficiaries are entitled to the trust property after the initial term. The QPRT assemblies are part of the Split Interest Trust / Grantor Retained Trusts system in the Advanced part of Wealth Docx.
QTIP election: This stands for Qualified Terminable Interest Property, and is often associated with a QTIP Trust. This is a form of marital deduction that allows a trust maker to set aside property for the surviving spouse in a trust in a way that qualifies for the unlimited marital deduction. (It's covered under IRC Sec. 2056(b)(7).)
RAP: Rule Against Perpetuities. This is a vague and very confusing legal issue that basically determines how long a trust can legally remain in effect. The original rule is generally "lives in being" (that is, people who are alive or who can be easily identified) at the time the trust becomes irrevocable plus an additional 21 years. An increasing number of states have dramatically expanded the RAP, and several have eliminated it completely. The upshot is that if the trust is subject to a RAP, the trust can't last forever. It can last for hundreds of years sometimes, but it must end and distribute at some point for the trust to be valid and enforceable. (See, I told you it was confusing.)
RLT: Revocable Living Trust. This is the main document & planning solution most trusts & estates attorneys implement for their clients. The client transfers their property to the RLT during their life so that their trustee (see below) can manage that property for the client if the client becomes disabled and when the client dies. Because the trust owns the property, probate is not necessary to transfer property after the client dies.
- Individual / Separate RLT: This is a trust established for an individual. The client may be a single person, or they may be a married person (typically in a separate property state; see that definition).
- Joint RLT: This is a trust established for a married couple. If the couple's marriage is not recognized by law, there can be really bad gift tax consequences for a joint RLT. For married clients in community property states (see that definition), a joint RLT is mandatory to maintain community property status and the favorable tax treatment that follows. Married clients in separate property states may use either a joint RLT or may use separate RLTs.
SCRUT: Standard Charitable Remainder Trust: Used as a type of CRT. A standard charitable remainder unitrust Trust (SCRUT) pays an annual "Uni Amount" to the Recipient(s). The Uni Amount is a fixed percentage of the value of the trust assets at the beginning of the trust's tax year. Because the Uni Amount is a percentage of the value of the trust assets at the beginning of the trust's tax year the annual amount distributed to the Recipient(s) will vary with variations in the value of the value of the trust. Additional contributions may be made to a standard charitable remainder unitrust if that option is selected.
Separate Property/Common Law State: Unlike community property, separate property receives a basis adjustment only when the owner of that separate property dies. For married couples in separate property or common law states, they may own their property jointly, but it is not treated the same as community property. When a spouse / co-owner of joint property dies in a separate / common law property state only that deceased person's portion of the property receives a step up in basis. The survivor keeps the same original basis. This means that if the surviving spouse sells an appreciated asset after the death of the other spouse, there will be capital gains computation based on the mixed basis of the stepped up share of the deceased spouse and the carried-over basis for the surviving spouse. (Confusing, huh?) All states that are not community property states are separate property states.
SNT: Special / Supplemental Needs Trust. This is a special type of trust designed to set aside assets for the benefit of a beneficiary whose disabilities may allow the beneficiary to receive public assistance for medical and other care expenses. There are generally two types: first-party trusts that someone establishes for their own benefit, and third-party trusts that someone establishes for the benefit of someone else, like a spouse, child, parent, etc. Wealth Docx includes options for a "stand-by" SNT in the RLT and Will document assemblies in the Core system, as well as options for a stand-alone SNT as part of the SNT assemblies in the Advanced system. ElderCounsel was established primarily to provide first-party SNT planning options and related education for Medicaid and Veterans Benefit planning.
SRT: Standalone Retirement Trust. This is a special type of trust designed to receive "qualified retirement accounts" like IRAs, 401(k)s, etc. It can be set up as either revocable or irrevocable, and it's designed to allow trust beneficiaries to continue to defer income tax on the account balance for as long as possible. (This is referred to as a "stretch out.") SRTs also provide a lot of protection for retirement account balances after they're inherited by beneficiaries. The SRT gained great relevance in 2014 following the Clark v. Rameker case. The Wealth Docx SRT is part of the Advanced System.
Survivor's Trust: This term only applies in the context of a joint RLT plan. The survivor's trust is the surviving spouse's share of the joint trust property, plus any separate property the surviving spouse had. The deceased spouse's property will typically flow into the marital and/or bypass trusts. The survivor's trust is fully revocable by the surviving spouse for the remainder of the survivor's life. It's treated just as if the surviving spouse had established his or her own individual RLT.
Testate: This describes the condition of someone who dies WITH a will or a trust (often referred to as a "will substitute").
Trust: A "trust" is really just a formal relationship where someone (the trust maker) appoints someone else (the trustee) to hold title to and manage trust property for the benefit of one or more people (the beneficiaries). When folks talk about "trusts" they're usually referring to documents, but in its basic form a trust is simply a specific type of fiduciary relationship. Trust documents take many forms, which are generally listed in this glossary.
Trust Advisor: Many attorneys use this term interchangeably with Trust Protector. Whether those terms are truly synonymous is open to question, and is still an evolving issue under the law.
- Investment Advisor: This is a Trust Advisor whose role is limited to advising the trustee on the kinds of assets to invest in.
- Distribution Advisor: This is a Trust Advisor whose role is limited to advising the trustee on when to make or withhold distributions from the trust.
Trust Protector: This is a special type of power holder who can control certain aspects of irrevocable trusts. There is little consensus among attorneys as to what the protector can and cannot do, whether they serve in a fiduciary or nonfiduciary capacity, who should be the trust protector, etc. Wealth Docx does include many options for drafting trust protector provisions in the Advanced system (particularly in the Irrevocable Trust assemblies) as well as in the Core system in the Will and RLT assemblies.
Trustee: This is the day-to-day decision maker for a trust. The trustee has a series of fiduciary duties to the beneficiaries to make sure that the trust is administered properly according to the trust's terms and governing law, and that the beneficiaries' interests are protected. There must always be a trustee for a valid trust to exist, and all trustees are always held to a fiduciary standard.
- Investment Trustee: This is a special trustee whose job is limited to making investment decisions for the trust.
- Distribution Trustee: This is a special trustee whose job is limited to making distributions from the trust to beneficiaries.
- Administrative Trustee: This is a special trustee whose job is limited to keeping documents and records for the trust, often for the purpose of establishing an adequate connection between the trust and the desired state where the law should apply. (Infrequently used.)
UTC: Uniform Trust Code. This is a body of law drafted by the National Conference of Commissioners on Uniform State Laws (NCCUSL) that is intended to consolidate the law of trusts as it is applied among the states. Although many states have enacted significant portions of the UTC, important distinctions are made as state committees and legislatures review and enact the UTC. It's safe to say that the Uniform Trust Code is far from "uniform."
Various relevant IRS terms & forms
- 706: Federal Gift & GSTT Tax Return. This is the form a taxpayer will file to report taxable gifts and generation-skipping transfers.
- 709: Federal Estate Tax Return. This is the form a trustee or personal representative files after someone dies to report the value of the deceased person's estate. It is also where a QTIP election gets made to calculate the amount of property passing to a surviving spouse under the marital deduction, and where the DSUE Amount gets computed and reported.
- 1041: Federal Fiduciary Income Tax Return. When a trust is irrevocable – either because it was set up as irrevocable or when it becomes irrevocable when the trust maker dies – the trustee has to report income on the 1041, instead of on a 1040. This comes up a lot in the trust administration course, but it's usually a return that the trustee's CPA prepares.
- Form 56: Notice of Fiduciary Relationship. This form is used to notify the IRS that someone besides an individual taxpayer is entitled to receive tax-related information for that individual. It comes up a lot in trust administration when a trust maker becomes disabled or dies and the trustee is appointed for the 709, 706, 1041, etc. or when an irrevocable trust or other non-person entity is established.
- IRC: Internal Revenue Code. This is the Federal law of taxation.
- PLR: Private Letter Ruling. This is a type of decision the IRS hands down for a specific client on a specific strategy question. PLRs are handed down to tell a taxpayer how the IRS will treat a strategy if it is enacted. (Thus, they're forward-looking.) There's an expensive application process involved and a PLR does not carry the weight of law except for the taxpayer who personally obtained the PLR. That said, PLRs often indicate how the IRS is inclined to handle a certain situation, so many practitioners refer to PLRs and PLR-driven strategies. This can be risky, since the PLR does not bind the IRS except for the taxpayer who paid to receive the PLR on their personal strategy.
- Regs: Regulations. This simply refers to the specific rules established by the Internal Revenue Service (IRS) under the Internal Revenue Code. They attempt to clarify what the IRC means, and often provide clarifying examples.
- SS-4: Application for Employer / Taxpayer Identification Number. This is the form a trustee or entity director completes to get an EIN or TIN for a trust or entity. That number works like a Social Security number for an individual; it's the tax ID number against which the 1041 or other trust / entity income tax returns get filed.
- TAM: Technical Advice Memorandum. This operates like a PLR except that is backward-looking; it is binding on the IRS and on the taxpayer as to how the IRS has ruled on a completed transaction.
Source: Learning Estate Planning's Alphabet Soup | Matthew McClintock | Pulse | LinkedIn
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David R. Duringer, JD, LL.M, is a concealed firearm instructor and tax lawyer specializing in business and estate planning; licensed to practice law in the states of California and Washington. He is managing shareholder at Protective Law Corporation, serving Southern California from its Laguna Hills (Orange County) headquarters and satellite offices in San Diego County (Coronado and Carlsbad).
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text:
A new space observatory expected to launch by 2024 will seek out Earth-sized planets and super-Earths orbiting distant stars, the European Space Agency announced Wednesday.
Dubbed "PLATO," for "PLAnetary Transits and Oscillations of stars," it will use 34 small telescopes and cameras to search for planets around as many as a million stars spread over half the sky. It will monitor those stars for tiny, regular dips in brightness as their planets transit in front of them, temporarily blocking out a small fraction of the starlight.
With the help of data from ESA's recently launched Gaia mission, PLATO will identify and study thousands of exoplanetary systems with a particular focus on those in the habitable zone of their parent stars, meaning that liquid surface water could exist.
It also will investigate seismic activity in the stars, enabling new insight into the host sun of each planet discovered, including its mass, radius and age.
Selected by the ESA's Science Program Committee for implementation as part of its Cosmic Vision 2015-25 program, the PLATO mission will address two key themes: What are the conditions for planet formation and the emergence of life, and how does the Solar System work?
'Where Life Could Have Arisen'
"The question of whether life exists on other planets is arguably one of the most intriguing questions in science today," Mario Livio, a senior astrophysicist with the Space Telescope Science Institute, told TechNewsWorld. "The discovery of life in an extrasolar system will constitute a revolution that will rival the Copernican and Darwinian ones."
Three aspects of the planned PLATO mission are particularly interesting, Livio said.
First is its scope — the fact that PLATO will observe about a million stars in its planet search, allowing it to find thousands of exoplanetary systems.
Second, "the PLATO program emphasizes the search for Earth-like planets orbiting Sun-like stars in the habitable zone. This will allow it to identify planets where life could have arisen," Livio noted.
Finally, "PLATO will conduct seismic studies of the host stars; that will allow it to determine accurately the mass and radius — and thereby density — of the host stars," he pointed out. "I cannot wait to see the results."
A 6-Year Mission
PLATO will be launched on a Soyuz rocket from Europe's spaceport in Kourou, French Guiana, by 2024, for an initial six-year mission. It will operate from L2, a virtual point in space 1.5 million km beyond Earth, as seen from the Sun.
PLATO is the third medium-class science mission ESA has selected. The first two were Solar Orbiter and Euclid, both chosen in 2011. Solar Orbiter will be launched in 2017 to study the Sun and solar wind from a distance of less than 50 million km, while Euclid — slated for launch in 2020 — will focus on dark energy, dark matter and the structure of the universe.
"It is clear that the PLATO space-based observatory will vastly increase the number of known exoplanets, as well as provide important physical parameters for those exoplanets," Scott Austin, associate professor of astronomy and director of the astronomical facilities at the University of Central Arkansas, told TechNewsWorld.
'The US Has Fallen Behind'
"This is an important scientific mission which will accomplish a number of remarkable objectives," agreed William Newman, a professor in the departments of earth and space sciences, physics and astronomy, and mathematics at UCLA.
However, "it also indicates how far the United States has fallen behind in comparison with our European and Russian partners in space exploration," Newman told TechNewsWorld.
"While many of the benefits of space exploration are intangible, we have witnessed and thrived due to the long-term benefits of NASA's 50 years in space," he added, "but have forgotten how important they were to our economy, as well as to our understanding of our place in the universe."

subset: commoncrawl


text:
First Thank you to those who have participated in my other challenges.
Okay so alot of my friends said I should do Hetalia challenges so I'm starting with a fanart contest. and it's a simple one at that, just draw a hetalia character/s. or if your feeling particulary creative feel free to draw Oc's or characters as the opposite gender. or characters as animals. etc etc. as long as I can still tell it's about Hetalia.
---- Rules/Guildlines ----
- Has to represent Hetalia in some way.
- Your allowed up to 3 submissions
- Does not have to be colored
- Does not need a background
- Chibi's are allowed
- OC's are allowed
- Alterations to characters allowed
- Animals from Hetalia can be used
- pretty much anything you can think of you can do.
I'm giving 2 months for the challenge since I know atleast half of us have school/college. and don't have Alot of free time.
also if I invited you to the challenge you don't HAVE to join I just invited who participated in my last challenge and anyone else's names that pop into mind.
Prizes are the ribbons and everyone that participates gets a gift. Thanks in advance to those of you that decide to join.


text:
Council Instance
Basic information about all the councils in the database.
- url - path to the page on this site for the council.
- website_url - URL for the council's website
- gss_code - standard council identifier.
- country - which of the UK home nations the council is located in.
- authority_type - what type of body (Unitary, District etc) the council is.
- plan_count - number of plans we have details for.
- plans_last_update - the date of the most recent update to a plan (null if no plans)
- carbon_reduction_commitment - True if the council has public commitments to reduce emissions
- carbon_neutral_date - the earliest date for a carbon neutral target (null if no date)
- carbon_neutral_commitments - link to list of commitments made by council
- declared_emergency - date, if any, council declared a climate emergency
You can filter the list of councils using the following query parameters:
- country - one of England, Northern Ireland, Scotland, Wales
- authority_type - one of City of London, Combined Authority, County Council, London Borough, Metropolitan District, Non-Metropolitan District, Unitary Authority
Multiple values can be combined with commas.
GET /api/councils/EAS/
https://www.lewes-eastbourne.gov.uk/", "gss_code": "E07000061", "country": "England", "authority_type": "Non-Metropolitan District", "authority_code": "EAS", "plan_count": 2, "plans_last_update": "2022-03-16", "carbon_reduction_commitment": true, "carbon_neutral_date": 2030, "carbon_reduction_statements": "http://cape.mysociety.org/api/councils/EAS/commitments", "declared_emergency": "2019-07-10" }{ "name": "Eastbourne Borough Council", "url": "/councils/eastbourne-borough-council/", "website_url": "


text:
Returns the inverse RFC1421 transformation of <stuff>, commonly known as Base64. The inverse transformation converts four Base64 digits into three bytes.
Alas, because ircII only supports C strings, if <stuff> decodes to binary data (with nuls) it will probably not do what you hope.
The reverse transformation is b64encode.
Don't confuse this encoding with the one used by FiSH (popularized by eggdrop and other irc clients for encrypted messages). FiSH uses l64a encoding, and can be decoded using the xform FISH64 transform.
The rfc1421 string <stuff> converted into a C string.


text:
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text: At BetRivers.com we have a 1x Playthrough requirement on all of our bonuses. That means that after you activate your bonus, you only have to wager through 1X and any winnings are converted to cash! That means that you are more likely to convert your bonus dollars into cold hard cash at BetRivers.com!


text:
Most artists appreciate their audiences, just as many are grateful for them, but few artists love their fans as much and as sincerely as Charles Bradley. "I want them to know how much they have helped me grow," notes Bradley when discussing Victim of Love, the follow up to his widely praised debut album No Time For Dreaming. The "Screaming Eagle Of Soul" is set to release the 11-track set on Daptone Records imprint Dunham Records.
By now, Bradley's remarkable, against-all-odds rise has been well-documented – how he transcended a bleak life on the streets and struggled through a series of ill-fitting jobs – most famously as a James Brown impersonator at Brooklyn clubs – before finally being discovered by Daptone's Gabriel Roth. The year following the release of No Time For Dreaming was one triumph after another: a stunning performance at South By Southwest that earned unanimous raves; similarly-gripping appearances at Bonnaroo, Austin City Limits, Newport Folk Festival and Outside Lands (to name just a few); and spots on Year-End Best Lists from Rolling Stone, SPIN, GQ, Paste and more.
Victim of Love is a continuation of that story, moving past the 'heartache and pain' and closer to the promise of hope. Where the last record opened with the apocalyptic "The World (is Going Up in Flames)," Victim begins with the "Strictly Reserved for You," a track where Bradley grabs his girl, jumps in a car and hits the highway for a romantic getaway. "You Put The Flame on It" sees Bradley backed by a horn chart that sounds like it was lifted from a lost Four Tops single. And on "Victim of Love," the track that lent the album its name, Bradley sings over a gentle acoustic guitar, "I woke up this morning, I felt your love beside me."
The new album also brings a broader musical scope. Where Dreaming hewed close to the rough-and-ready R&B sound Daptone has become known for, Victim is stylistically more restless, edging closer into the kind of psychedelic soul The Temptations explored in the early '70s. "People are not going to expect this. There's a lot of psych influences on this record, a lot of fuzz guitar," notes Thomas Brenneck of Menahan Street Band, Bradley's producer, bandleader and co-writer. "Confusion" most exemplifies the new direction of the album, opening with an echo-drenched vocal and charging rhythmic cadence.
The album's closing track "Through the Storm" best summarizes Victim's message. Over a deep gospel groove, Bradley expresses his gratitude – to his fans, his friends and to God – for their support, their dedication and their devotion. "When the world gives you love," he sings, "It frees your soul." This is the new message of Charles Bradley, the Bradley who has emerged from the heartache stronger and more confident, overflowing with love to share. This is Charles Bradley, Victim of Love - gratefully returning the joy that has been given to him.
Charles Bradley Victim of Love Track Listing:
1. Strictly Reserved For You
2. You Put The Flame On It
3. Let Love Stand A Chance
4. Victim Of Love
5. Love Bug Blues
6. Dusty Blue
7. Confusion
8. Where Do We Go From Here ?
9. Crying In The Chapel
10. Hurricane
11. Through The Storm


text:
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text:
Fairy Tale Mysteries: The Puppet Thief Premium Edition
Average RatingRate this game Thank you for submitting your review, your feedback is always appreciated
Discover the truth behind the myth and save the children!
Unlimited Ad Free Play
Game Description
Once upon a time, there was a man who went from town to town with songs and poetry, capturing the souls of children. From generation to generation, the tale was told. But every fairy tale has its true bitter beginning. Now a new evil has visited the town of Arbourshire, and children have been going missing. A mysterious puppet theater seems to be at the center of their disappearance. The town is in an uproar! A mob roams the streets and the Brothers Grimm have assigned the task of discovering the truth behind the Fairy Tale Mystery to you! Discover the truth behind the myth and save the children!
Premium Edition Features:
-Bonus Chapter
-Integrated Strategy Guide
Download size: 500 MB
Most Recent ReviewsRate this game
Average Rating: ( Ratings)


text:
Hours after this Spotlight report was published, the federal government removed two top officials at the Manchester VA Medical Center and ordered a "top-to-bottom" review of the hospital.
MANCHESTER, N.H. — This is what the US Department of Veterans Affairs says a four-star hospital looks like:
One operating room has been abandoned since last October because exterminators couldn't get rid of the flies. Doctors had to cancel surgeries in another OR last month after they discovered what appeared to be rust or blood on two sets of surgical instruments that were supposedly sterile.
Thousands of patients, including some with life-threatening conditions, struggle to get any care at all because the program for setting up appointments with outside specialists has broken down. One man still hadn't gotten an appointment to see an oncologist this spring, more than four weeks after a diagnosis of lung cancer, according to a hospital document obtained by the Globe.
And when patients from the Manchester Veterans Affairs Medical Center are referred to outside specialists, those physicians are sometimes dismayed by their condition and medical history. A Boston neurosurgeon lamented that several Manchester patients sent to him had suffered needless spinal damage, including paralysis, because the hospital had not provided proper care for a treatable spine condition called cervical myelopathy.
"Only in 3rd World countries is it common to see patients end up as disabled from myelopathy as the ones who have been showing up after referral from you," wrote Dr. Chima Ohaegbulam , of New England Baptist Hospital, to a doctor at the Manchester VA in 2014.
But this hospital, the only one for military veterans in New Hampshire, is just 50 miles from Boston. And it's supposedly one of the better VA hospitals in the country. Late last year, in fact, the veterans affairs department raised Manchester's quality rating from three stars to four, putting it in the top third of the entire VA system.
Ratings can deceive. Inside the unassuming red-brick walls of the Manchester medical center is ground zero for an extraordinary rebellion led by doctors who say they have almost no say in how the hospital is run, lack tools to do their jobs, and witness chronic shortcomings in patient care. They say the four top administrators, only one of them a doctor, seem more concerned with performance ratings than in properly treating the roughly 25,000 veterans who go to Manchester for outpatient care and day surgery each year.
So far, 11 physicians and medical employees — including the hospital's retiring chief of medicine, former chief of surgery, and former chief of radiology — have contacted a federal whistle-blower agency and the Globe Spotlight Team to say the Manchester VA is endangering patients. The US Office of the Special Counsel, the whistle-blower agency, has already found a "substantial likelihood" of legal violations, gross mismanagement, abuse of authority, and a danger to public health, according to a January letter to one of the doctors who alleged wrongdoing.
"I have never seen a hospital run this poorly — every day it gets worse and worse," said Dr. Stewart Levenson, chief of medicine, an 18-year veteran of the hospital who is among the whistle-blowers. "I never thought I would be exposing the system like this. But I went through the system and got nowhere."
On Thursday night, a spokesman for Veterans Affairs Secretary David J. Shulkin expressed concerns about the problems relayed by the Spotlight Team.
"These are serious allegations, and while we cannot comment on the specifics due to patient privacy issues, rest assured that we will look into them right away," said the VA press secretary in Washington, D.C., Curt Cashour.
Remarkably, leaders of the Manchester VA have confirmed many of the problems, from the fly-infested operating room — "an episodic issue," said one administrator — to thousands of patients waiting indefinitely for specialist care, which the leaders blamed on the private company hired by the federal government to set up veterans' appointments outside the hospital.
In a recent hourlong interview with the Globe, hospital director Danielle Ocker and her chief of staff, Dr. James Schlosser, also acknowledged significant cuts in services, such as the elimination of cataract surgery, as well as administrative glitches that further limited care.
For example: The hospital ordered a $1 million nuclear medicine camera in 2015 to replace a balky one, but never installed it because it was too big for the examination room. Without a reliable camera, the hospital in February stopped offering nuclear stress tests for heart disease risk, and bone scans that can detect tumors. The building is expected to be remodeled for a new camera in 2018.
But Ocker and Schlosser expressed surprise that so many members of the medical staff have reported the hospital's problems to federal investigators. They said the hospital is addressing shortcomings and that patient safety has not been compromised. Ocker, a nurse, contended that Manchester boasts "a zero infection rate" in the operating rooms — a hospital spokeswoman said the unblemished record dates back to 2011 — and shared a veteran's recent letter praising Manchester VA care.
Ocker also said she wanted medical staff to know that she and other leaders take their concerns seriously.
"My feeling is that if there are issues that we need to address, or if there are concerns, that we need to hear about them," she said.
In many ways, the Manchester VA is under investigation because doctors became convinced that Ocker and other leaders were not listening. A number of problems date back years before Ocker arrived in 2015, and often reflected lapses in care that occurred when Manchester referred veterans to other VA hospitals or when multiple hospitals failed to coordinate follow-up treatment. But they are coming to the forefront now, in large measure, because one outspoken doctor went public about many patients that he believed had gotten subpar care. Patients like Robert McWhinnie.
McWhinnie, a Korean War veteran who lives in the small New Hampshire town of Gilmanton, relied mainly on a wheelchair to get around when he first visited Dr. William "Ed" Kois, head of Manchester VA's spinal cord clinic, in July 2016. McWhinnie, who was 84 at the time, had long been a vigorous man who built much of the furniture in his house from maple trees on his land. But then his legs and arms grew weak, he had difficulty talking, and he became incontinent.
Kois immediately got alarmed when reading McWhinnie's medical records.
They showed that the retired telephone cable splicer had undergone two surgeries at the VA hospital in Jamaica Plain to remove a tumor from his spine in 1995 but that the surgeon could not remove all of it, according to a copy of the records that his family shared with the Globe.
Over the next 21 years, McWhinnie went to the Manchester VA dozens of times for treatment of a variety of ailments. But no one had done imaging to find out if the tumor was growing again, even though regular monitoring was the standard of care after surgery on this type of tumor, according to his lawyer, Mark Abramson.
At least as far back as 2007, McWhinnie was gradually losing the ability to walk, the records indicate, something that could have been caused by a tumor pressing on his spine.
Kois "took one look at Bob, and he said, 'Oh, my God, this is a disgrace. This man should have been taken care of,' " recalled McWhinnie's wife of 63 years, Janice McWhinnie.
So Kois ordered an MRI and an X-ray and, sure enough, the tumor was choking McWhinnie's upper, or cervical, spine. It had also grown too big to remove.
"They ignored him basically for 20 years and allowed this thing to grow and grow and grow," said Abramson, who recently wrote the VA in Manchester and in Boston that his client intends to sue for negligence.
Hospital officials declined to comment, citing potential litigation.
For Kois, McWhinnie's condition was sickeningly familiar. In his five years at the VA, Kois has compiled a list of at least 80 Manchester patients who were suffering from advanced and potentially crippling nerve compression in the neck, or myelopathy. Some, like McWhinnie, had undergone surgery at other VA hospitals and then relied on Manchester for subsequent care.
Kois said he complained about the situation to administrators and other doctors. He even organized a September 2015 conference at Manchester, where he told a roomful of doctors and other VA staff that patients were getting substandard spinal care.
Ocker herself gave introductory remarks at the conference. Yet, in the interview with the Globe, she said she only became aware of Kois's concerns more than a year later when she heard that they were part of the federal investigation. She said she left Kois's conference after welcoming guests and was never briefed on the content of his presentation.
"I did not hear that," she said of Kois's allegations.
Kois found a far more receptive audience the following year at the federal Office of the Special Counsel, which made his contentions about poor care a central part of its inquiry. After finding a "substantial likelihood" of wrongdoing, the office recommended a full-fledged investigation by the Veterans Affairs Office of Medical Inspector, which began in January.
An unlikely flashpoint
The VA medical care system, which is used by about 6 million military veterans each year, has been stumbling since 2014. News stories reported that the Phoenix VA Health Care System had engaged in an elaborate scheme to hide the fact that sick veterans were waiting months to see a doctor, and that some had died before they could be seen.
As similar allegations surfaced at other VA hospitals and tens of thousands of veterans around the country were found to be waiting months for care, Veterans Affairs Secretary Eric K. Shinseki resigned.
"I can't explain the lack of integrity among some of the leaders of our health care facilities," he said, shortly before stepping down.
But Shinseki's departure did not stop the drumbeat of scandal. Last year, nearly three dozen whistle-blowers charged that the VA hospital in Cincinnati had made budget cuts that forced out experienced surgeons, reduced access to care, and endangered patients' safety. The head of the VA's Ohio-based regional network then retired, and the Cincinnati hospital's chief of staff was suspended and later indicted on criminal charges.
Now President Trump's appointee as VA secretary, Shulkin, is vowing to stabilize the health care system. "We are still in critical condition and require intensive care," Shulkin said at a May press briefing. Last month, Trump signed a bill into law to make it easier for whistle-blowers to come forward and for employees to be fired for misconduct.
"Up until now, we have too often failed to hold a small number of our employees accountable, for not living up to their duties to serve our veterans, and at the same time protecting whistle-blowers from retaliation,'' Shulkin said.
At first glance, the Manchester VA hospital seems an unlikely flashpoint for the continuing VA care crisis. The 67-year-old hospital has faced some controversies, to be sure. In 2015, a federal judge awarded a Navy veteran $21 million because the hospital failed to properly diagnose and treat his stroke. A year later, Manchester was one of dozens of VA hospitals that government investigators found had publicly downplayed patient wait times. But the VA has generally looked favorably on Manchester.
The VA gave the New Hampshire hospital four stars out of a possible five when the department rated hospitals in 2016. Manchester was ranked above average for both the overall patient experience as well as job satisfaction for employees. The national VA also ranked Manchester near the top for minimizing the amount of time patients had to wait to see both primary care providers and specialists.
A spokeswoman for the VA in Washington, Gina Screen, said Manchester earned its four-star rating.
"While there are known breaches to Manchester VA Medical Center's environmental standards as it relates to cluster flies in one of the surgical suites, all appropriate actions have been taken" to fix the problem, she wrote.
Levenson, the chief of medicine, said the VA quality ratings mean little for a hospital like Manchester, which stopped providing inpatient care in 1999 and farms out patients to other VA hospitals and private specialists for an increasing array of treatments. As a result, he said, Manchester's quality rating is based on more subjective measures, such as patient and employee satisfaction, than on quality of care.
And Levenson said many veterans who use the VA system tend to accept whatever care they get, not objecting even when they're left in the waiting room for hours. Many are reluctant to challenge authority figures and tend to trust their caregivers, Levenson said. In many of the cases of avoidable spinal injury alleged by Kois, the veterans didn't even realize their reduced mobility or paralysis could have been prevented.
High-ranking doctors at the Manchester VA are indignant on their behalf. Levenson, who plans to retire at the end of the month, is one of seven doctors who have given up leadership positions or disclosed plans to leave the hospital so far this year. Several cited frustration with management.
Dr. Edward Chibaro stepped down as chief of surgery recently after his plans to create a more robust surgery center were stymied by the hospital's failure to replace obsolete endoscopic equipment and restore services such as cataract surgery, he said.
"I think the health care is marginal," said Chibaro, a veteran urologist who came to Manchester two years ago from the Lahey Institute of Urology at Parkland Medical Center in Derry, N.H. "All the physicians would tell you that if they were truthful. The veterans deserve better care."
You won't get any argument on that from Richard Zuschlag.
A 56-year-old veteran of the Army's 82nd Airborne Division, Zuschlag was one of three patients whose surgeries were canceled on June 8 when two kits of surgical instruments that were supposed to have been sterilized bore what looked like rust or blood stains.
Zuschlag needed hernia surgery after missing about five months of work as a laborer, and he has been living in a Nashua homeless shelter where Manchester VA officials found a bed for him.
"I want to get back to work," said Zuschlag, whose operation was pushed back to July. "I'm going nuts."
A hospital spokeswoman, Kristin Pressly, said the hospital consulted the manufacturer of its steam sterilizers after the episode and replaced the filters in hopes of solving the problem.
But Manchester has struggled to provide sterile surgical equipment for some time. In January 2016, "any one of three" veterans underwent an office procedure in which the instrument kit had been cleaned with bleach but not sterilized by steam, according to a hospital memorandum. "The Medical Center has been unable to identify which of the three Veterans the kit was used on," said the memo. Hospital officials say the problem has since been resolved by making sure nonsterile surgical kits are kept separate from ones ready for use.
Some of the dissenting medical staff members say the hospital compounds such basic failings with questionable personnel moves.
Last month, the hospital administration named a physician's assistant rather than a doctor to serve as acting head of primary care. Daniel O'Brien also had something worrisome in his background, having been arrested twice on charges of driving while intoxicated, according to published reports. Less than two weeks after the appointment, amid complaints that O'Brien was not qualified, Ocker downgraded him to acting "associate" head of primary care. Hospital officials said they wanted someone with "additional qualifications."
O'Brien, contacted by the Globe, referred questions to the hospital administration.
Boxer's son joins the fight
Friends of Dr. Ed Kois predicted he would rue the day he gave up his three-decade private practice as a pain and spine specialist in Nashua for the VA hospital in Manchester.
Kois is a skilled diagnostician who has, colleagues say, an uncanny knack for figuring out why, say, a patient's left hand tingles or lower back throbs. And his empathy for his patients is legendary. A colleague recounted how Kois took an elderly patient shopping for a car after her husband had died. "I don't consider the physician-patient relationship to end at my door," Kois explained.
But Kois, a board-certified physiatrist — a doctor who specializes in rehabilitation and pain management — has little patience for bureaucracy. He unabashedly describes himself as an anarchist, and he looks the part, with baggy clothes, muttonchops, goatee, and ponytail. He has decorated his hospital office with a framed photograph of the boxing gloves worn by his late father, Adam Kois, whose pugilistic skills took him from the mining camps of western Pennsylvania to Penn State. His son appears to have inherited his pugnaciousness and resolve.
Kois was stunned when he arrived in Manchester in 2012 and noticed that dozens of veterans who had received outpatient treatment there for years had badly damaged spines. "Boy, they must have been in some terrific combat," he remembers thinking.
Actually, some of them had seen combat, he said, but their condition often had nothing to do with war wounds. It had to do with their medical care.
Certainly, that appeared to be true for Jeffrey S. Sweeney. The 39-year-old Army National Guard veteran injured his spine when an improvised explosive device blew up his gun truck in 2011 in Iraq. He underwent spinal fusion surgery at the Boston VA two years later and should have made a full recovery, according to Kois.
But four months after surgery, despite several visits to Boston and Manchester, Sweeney was suffering disabling back and leg pain. It was so severe that at one point, he requested a wheelchair so he could serve as best man at his brother's wedding.
Kois recommended a CT scan, which showed that his VA neurosurgeon in Boston had accidentally penetrated a nerve when inserting a 1¾-inch screw into Sweeney's vertebra. Neither medical staff in Boston or Manchester had picked up on it, according to Sweeney's medical records, which the Globe reviewed with his permission.
Kois referred Sweeney to Ohaegbulam, the neurosurgeon at New England Baptist, after Manchester's leadership at the time agreed to pick up the tab. Ohaegbulam removed the screw and redid the operation, relieving much of Sweeney's pain.
"I trust Dr. Kois with my life," Sweeney said. "He is more concerned about the veterans than he is about himself."
Michael St. Cyr's dilemma was much like Sweeney's. In 2014, the 21-year Army veteran was suffering excruciating pain at the site of an old neck surgery. Records show that for more than two years, doctors in Manchester did little that helped — until he saw Kois, who ordered new images in 2016. They showed that surgical screws from the earlier operation had come loose: A private surgeon then inserted an artificial disk, which relieved St. Cyr's pain.
If St. Cyr had not met Kois, he said, "I'd still be horrible."
Then there was Galen Warman. An Air National Guard veteran from Concord, N.H., Warman injured his neck when his car was rear-ended in 2007, according to medical records he shared with the Globe. He later developed severe back pain — "I was eating painkillers like Chiclets," he said — weakness in his arms, tingling in his right hand, and difficulty walking.
Warman, who visited the Manchester VA dozens of times after the car accident, had had no MRI of his neck for eight years when Kois first saw him in 2015, according to the medical reports. Kois ordered one, which showed severe spinal cord compression.
So Kois sent Warman to Ohaegbulam for surgery, as he had done with Sweeney, with similar results. "It was just a new lease on life," said Warman, 66, who used to struggle with everyday chores but plans to go hiking this summer.
Perhaps most discouraging to Kois, however, was the sheer number of veterans who suffered from advanced cervical myelopathy, a common degenerative spine condition that causes nerve compression in the neck.
Left untreated, myelopathy can lead to weakness in the limbs, numbness in the hands, balance problems, incontinence, even paralysis.
But, with the advent of magnetic resonance imaging a generation ago, myelopathy became relatively easy to diagnose — and treat with surgery — before it progressed too far. Indeed, Kois said, he had rarely seen an advanced myelopathy case in 20 years.
At the Manchester VA, though, Kois saw dozens of them, many being treated not with surgery but with canes, walkers, and wheelchairs to accommodate the patients' declining mobility. Kois was shocked.
"It's like if you suddenly saw cases of syphilis — a disease that has long been curable with penicillin," Kois said.
Dr. James Wepsic, a retired New England Baptist neurosurgeon and mentor of Kois's who had discussed the situation with him, called the number of advanced myelopathy cases in Manchester "mind-blowing."
"Probably there are places in Appalachia, from which I come, where you might see a group of people like this, but not in New England,'' Wepsic told the Globe.
Kois's concerns extended beyond spine injuries. He also found that some members of the medical staff overprescribed highly addictive opioids to treat veterans' pain, including conditions ill-suited for such drugs, such as fibromyalgia, he said.
And he alleged that Dr. Muhammad Huq, the former spine clinic director at Manchester, had for years repeatedly copied and pasted patients' medical histories in computerized records without updating them as conditions changed. Huq had previously been counseled about the practice, which can make it hard, if not impossible, for other medical staff to fully grasp patients' histories.
Huq, who no longer works in Manchester, declined to comment. However, the VA's Office of Medical Inspector confirmed that an unnamed provider did copy and paste notes, and the hospital took "appropriate action," according to a memo from Ocker to the staff.
Driven by such concerns, Kois organized the conference at the Manchester VA in 2015 that dealt partly with cases of advanced myelopathy. The speakers included Ohaegbulam, who discussed several Manchester patients he had treated, as well as Wepsic, who talked about pain treatment. Kois wanted to sound the alarm about veterans who he believed were being left weakened or paralyzed by substandard care.
But his call to arms had, if anything, a negative effect. His ability to care for spinal patients, he says, actually got worse.
When Schlosser arrived in Manchester as the new chief of staff in May 2016, Kois said, he clamped down on the doctor's ability to send advanced myelopathy patients to neurosurgeons at private hospitals in Boston, at Manchester's expense, for care Kois felt the VA couldn't or wouldn't provide. The hospital had a projected deficit of $6 million in 2016, hospital officials confirmed, and Schlosser emphasized to the staff the importance of seeking less expensive treatment within the VA system before resorting to private doctors.
Soon after issuing that warning, Schlosser blocked Kois from sending a patient to Ohaegbulam. Kois was angry, and blunt about it.
"I'm going to make sure that people know that this is your decision," Kois recalled saying. "The blood's on your hands."
Fly on the ceiling
And then there was the business about the flies.
A couple of years ago, a veteran lay on his back on a gurney in OR 2 at Manchester as a surgical team prepared him for a knee operation. Staring upward, he asked a startling question.
"Excuse me," he said, according to a medical staffer on the team, "am I supposed to be looking at a fly on the ceiling?"
Members of the team looked up, then shook their heads.
"No, sir, you're not," the staffer recounted saying. "And, in fact, that means we have to move you out of this room. We have to move to another OR."
Not long afterward, the employee who recounted the story — a whistle-blower who asked not to be identified out of fear of possible repercussions — approached a longtime nurse to ask how long flies had been a problem in OR 2.
"Let's see, I've been here 16 years," the nurse told the staffer, "so . . . . 16 years."
Pressly, the hospital spokeswoman, told the Globe that Manchester has dealt with the fly infestation since at least 2007. The hospital, she says, spent $1.1 million that year to repair masonry, partly to control pests. In addition, the hospital has hired at least two extermination services and spends about $55,000 a year on pest control.
Nonetheless, the flies have beaten the exterminators. Last October, Ocker said, the hospital stopped using OR 2, one of four operating rooms in the hospital. A giant fly zapper stood like a sentry in the room in a recent photograph obtained by the Globe.
The VA's medical inspector, in its preliminary findings, said no surgeries have been delayed as a result of the closed OR, Ocker told staff in February. About 400 operations are performed annually at the hospital.
For years, problems like the fly infestation were quietly tolerated in Manchester. But something changed over the last couple of years that made key members of the medical staff less willing to accept chronic problems — and more inclined to report them to federal investigators.
Part of it, say the whistle-blowers, is that previous leaders of the Manchester VA showed more flexibility when bureaucratic problems arose, allowing Kois, for example, to refer patients to private neurosurgeons outside the VA.
In addition, as the Manchester VA cut back on surgery and other services like nuclear medicine, it came to rely more heavily on a new federal program that allows veterans to seek care from private doctors. Veterans Choice, hastily approved by Congress in 2014 to reduce waiting times for veterans' appointments, came with its own pot of money, so Manchester could take advantage of the program without dipping into its own budget.
But the Choice program has a spotty record nationally and has been particularly problematic in Manchester, in part because the hospital has cut its own services so deeply and referred so many patients.
Choice, which is administered by Health Net Federal Services, failed to make some 3,100 appointments requested by Manchester veterans in the first five months of this year, according to a VA document obtained by the Globe. That was easily the worst record of the eight VA medical centers in New England and included hundreds of patients who have been waiting more than six months, some with life-threatening conditions.
Mark Sughrue, a cardiology nurse practitioner and whistle-blower, has been especially worried about patients with potential heart conditions waiting weeks for nuclear stress tests — which have been referred to providers outside Manchester since nuclear medicine was shut down.
"Eventually there will be a significant adverse outcome,'' he wrote hospital officials in March in an e-mail obtained by the Globe. "Veterans are getting lost and no one seems to care." Sughrue declined to comment for this article.
Pressly, Manchester's spokeswoman, blamed the situation on "significant performance issues" with Health Net Federal Services, one of two private companies contracted to administer the Choice program across the nation.
In an interview, Dr. Baligh R. Yehia, a VA deputy under secretary, acknowledged that Choice "has a lot of issues and challenges." The VA has sent several "letters of correction" to Health Net for allegedly failing to follow its contract.
"It's better than at day one," he said, "but it's not where we need to be."
In a prepared statement, Health Net officials said they are still trying to adjust to "higher and unexpected volume" of patients using Choice.
Beyond the change in Manchester's leadership and the problems with Choice, there's a third factor behind the hospital uprising: Kois. His willingness to openly challenge VA leadership and risk his career set an example that several colleagues said emboldened others to speak up as well.
"He was a breath of fresh air," said Levenson.
After Schlosser blocked Kois from sending spine patients to private surgeons, Kois contacted a politically connected Manchester lawyer, Andrea Amodeo-Vickery, who agreed to represent the doctors. Seven other doctors and three medical staffers eventually followed suit and said they could no longer tolerate problems, from unsanitary OR conditions to long delays in treatment.
"It's because of Ed Kois,'' said Amodeo-Vickery, who has known the doctor for about 25 years. "It took Ed to light the fire."
Amodeo-Vickery wrote US Senator Jeanne Shaheen and US Representative Annie Kuster last summer, saying her clients "became VA physicians because of their deep commitment to the care of our veterans, and each are totally frustrated with their ability to provide care."
Several of the doctors met with Shaheen and Kuster and then contacted the whistle-blower agency.
In January the whistle-blowers had their first success, as the Office of Special Counsel found "substantial likelihood" of wrongdoing at the hospital and called for the VA's medical inspector to conduct a full investigation. That happens in less than 10 percent of allegations reported to the Office of Special Counsel, according to a recent report by the office.
The VA's medical inspector was supposed to complete its investigation in 30 days, but has received multiple extensions from the special counsel's office.
Last Thursday, after weeks of back and forth with the Manchester VA over the whistle-blowers' allegations, Secretary Shulkin's office joined the discussion. Pressly, the spokeswoman for Manchester, abruptly retracted her office's answers to some Spotlight Team questions, saying that Shulkin's office would have a statement instead.
Shulkin's press secretary then announced that VA headquarters would launch an investigation of its own.
"Secretary Shulkin has been clear about the importance of accountability and rapidly fixing any and all problems brought to our attention, and we will do so immediately with these allegations," said the spokesman, Curt Cashour.
Meanwhile, whistle-blowers say, conditions in the hospital continue to deteriorate.
Dr. Erik Funk, a cardiologist, said the hospital's cardiology program has been in free fall since officials closed the nuclear medicine program in February. Not only does Funk have to send his patients to other facilities for nuclear cardiac stress tests, he also runs the cardiology program alone. A second full-time cardiologist left several months ago and the hospital hasn't replaced him, though hospital officials say they are now sharing a second cardiologist with a sister facility.
"Since I've been here, there's been a gradual deterioration in the quality of care — not the quality of care I deliver, but the quality of care I'd like to deliver," Funk told the Globe.
Jonathan Saltzman can be reached at email@example.com. Andrea Estes can be reached at email@example.com.


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Violet Pure Kinkhab / Kimkhab Brocade Banarasi Fabric
Category : Kinkhab / Kimkhab Fabric
Khinkhwab brings you beautiful fabrics and yardage from Banaras. You can turn these beautiful fabrics into a traditional blouse, Indian kurta or a western jacket. For Blouse you need 1 meter of fabric, for kurta you need 3 meters, for jackets you need 2 meters of fabric. Pair these beautiful fabrics with your Banarasi sarees and dupattas and add more glamour to it.
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Available on back-order
Purchasing Information:
After you place your order on this site, we will contact you to confirm your order details prior to payment being made. All orders will be processed and fulfilled by one of our authorised dealers. Rollies Speed Shop Distribution is a wholesale business and does not sell directly to the general public. For more info see the Purchasing Information page.
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Off the Shoulder Long Prom Dress, Slit Prom Dress, Satin Prom Dress, Simple Prom Evening Dress, Custom Made Prom Dresses, Prom Dresses 2018
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Sting, Tom Jones, Jamie Cullum, others serenaded the monarch
LONDON — Queen Elizabeth II celebrated her 92nd birthday with a Saturday night concert in London featuring British singers such as Sting, Tom Jones and Jamie Cullum.
Kylie Minogue, Shaggy and Craig David also were set to perform for the "Queen's Birthday Party" at Royal Albert Hall.
Elizabeth — the world's longest-reigning living monarch — attended the show with other members of the royal family. Flanked by Prince Charles and Prince William — first and second in line for the throne — she waved to the crowd as she took her seat.
Prince Harry, with fiancee Meghan Markle as his concert date, led the tributes to his grandmother.
Earlier in the day, honorary gun salutes were staged at Hyde Park, the Tower of London, a castle in Wales and the town of Windsor to mark the occasion.
The queen celebrates two birthdays every year: Her actual birthday on Apr. 21, which she usually marks privately with her family, and her "official birthday" in the summer. That usually falls on the second Saturday in June, when she joins the Trooping the Color military parade in central London.
Elizabeth's official birthday this year came on the tails of the Commonwealth Heads of Government meeting, which brought the leaders of the 53 Commonwealth countries together in England.
The queen has led the disparate group, made up of Britain and its former colonies, since she took the throne in 1952.


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You'll be able to play and customize lady marines in Aliens: Colonial Marines, developer Gearbox assured fans during a panel at PAX Prime today. You can hop in the clunky metal shoes of Jennifer Redding during co-op play and even customize an array of female avatars for competitive multiplayer.
Gearbox didn't want to announce anything today, but they felt they had to, CEO Randy Pitchford told me in a recent meeting. The decision to reveal the remaining three cooperative characters (including Redding, who you can see in the above concept art) came as a reaction to a growing online petition that accused the first-person shooter of excluding both playable female characters and female character customization in competitive play.
The petition, which currently holds over 3,800 signatures, appears to be supported by several of the 1986 Aliens film's actors and actresses that performed the roles of marines.
The online controversy was first stirred by a post-E3 interview where senior producer Brian Burleson had claimed there were no playable female characters. What he meant, Pitchford told me, was that there were no playable characters in the E3 demo, which only featured team deathmatch.
It was always the plan to include playable female characters, Pitchford told me. Working with female avatar builds, he explained, is beneficial for both visual diversity—animations and silhouettes that differ from male characters—as well as gameplay diversity. Females have a different skeleton and therefore move differently than the male marines.
Competitive multiplayer will feature a whole range of both male and female characters, all of which can be customized. You'll be able to write on your gear, customize your armor, and even attach a flamethrower to your pulse rifle if you felt so inclined.
Because the announcement is earlier than the team expected, some details are still being ironed out. Subtleties ranging from mohawk hairstyles to the stance of the lead co-op hero are subject to change. But Gearbox felt the need to clarify that there will indeed be both a playable female marine in co-op, as well as customizable female avatars in the game's competitive multiplayer mode.


text: Hi, I'm pretty new at this so excuse ignorance. 2 quick questions. 1)I have a script used to upload data from a CSV file to database. No matter how many rows are populated in the CSV file it only uploads the first 15 rows of data. Any Ideas? 2)Also can anyone tell me what the line of code from PHP.ini below does ;session.entropy_length = 16