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Some games are just mind numbing fun; Red Faction Armageddon is just that. It's not the tightest shooter, the controls are loose and the main character is the bald space marine cliché we've seen all to often this generation.
That said, it may only be a demo, but it was damn fun, damn good fun. Red Faction has always been about destructibility. Armageddon takes that to a new level with the Nano-Forge. The Nano-Forge allows you to repair and rebuild anything you've previously destroyed. Speaking of, the level of deformation is astounding. Almost anything you see can be ripped apart, and not in a canned animation. Everything crumbles and breaks dynamically; no building or structure will collapse the same way.
Well you can destroy most things you see by melee; the Magnet Gun is where the game gets its fun-factor from. Just shoot the Magnet Gun to one object, then another, and watch point A suck to point B. The magnet gun pulls almost any two structures towards each other, sandwiching them in a beautifully destructive display.
I spent 10 minutes just destroying a room with the Magnet Gun. Attaching stairs and walls to each other and watching them slam together didn't get old. It may in the final game, but it was definitely fun at the time. After making a complete mess of the room I rebuild it good-as-new with the Nano-Forge, putting everything back into its proper place.
Ripping things apart with the Magnet Gun then reforming them with the Nano-Forge is joyful, sure it's a gimmick, but many great games start with simple concepts…mind you the level of destructibility in this game isn't simple, it needs to be seen, it's really a sight when an entire room is destroyed then put back together like nothing happened.
I briefly mentioned how loose the shooting mechanics feel. That may just be personal preference, as I like my 3rd Person Shooters to have more weight behind the character I'm controlling like Gears of War. I didn't even want to use the standard assault rife and other mundane weapons that we've seen it so many shooters. I found just using the Magnet Gun was the way to go. Attaching enemies to walls, or attaching them to each other and watching them squish together is just satisfying.
|The Nano-Forge lets you rebuild almost any structure you've destroyed
My favorite thing to do was shoot the Magnet Gun at an enemy then at the ground to bring then crashing down from the ceiling, then melee their helpless ass. Stupid bug things!
Like Red Faction Guerrilla there's a mech section of the game where you can unleash a crazy amount of devastation on the surrounding. It may be shallow but shoulder-checking enemies in a giant mech is as fun as it sounds.
The fact of the matter is when this game comes out on June 7th will it be sixty bucks worth of fun. Who can say right now? Red Faction Guerrilla was surprisingly fun; Red Faction Armageddon seems to be headed in that same direction.


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Esprit de Fleur captures your unique style and expresses it in flowers. For more than two decades, no two of our weddings and events have ever been the same. Combining our knowledge and talent with individual time and attention, we will truly represent your "expression in flowers". . . your Esprit de Fleur.
Esprit de Fleur approaches weddings with a very personalized style. We listen . . .we look at your starting ideas . . . we offer fresh innovative ideas and possibilities . . then create a beautiful expression of you in flowers that will delight the senses and create long lasting memories.
Our process includes:
The Initial Consultation~ This first general meeting is where we meet to start the idea process in motion.
The Full Planning Consultation~ At this point you are booked with us and have dresses selected. Together, we create a flower plan that is fresh, innovative and very fitting. We may also do a site walk through together.
Our open-communication process includes budget proposals and selections to fit your priorities.
Esprit de Fleur was founded and is operated by floral artist Sheri Miller.
Schooled in a range of design and style with two bachelors degrees in art, she has also had extensive training in Europe studying Dutch and German design.
In 1993, after meeting rigid qualifications and demonstrating advanced professional ability, she was accredited by the highly esteemed American Institute of Floral Designers. With only 1,200 members worldwide, the AIFD accreditation is awarded only to those in the forefront of the floral industry committed to establishing and maintaining higher standards.
Sheri has been quoted in the Seattle Post-Intelligencer and is recommended by many of the city's leading event planners.
She has also instructed thousands over the years in the art of flower arranging and design through her private classes and courses at Shoreline Community College and the UW Experimental College.

subset: commoncrawl


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Chanda Kochhar is the Managing Director and Chief Executive Officer of ICICI Bank, India's largest private and overall second largest bank in the country. She also heads the Corporate Centre of ICICI Bank.
An epitome of modern woman
Apart from being on the Board of ICICI Bank and various group companies, she is a member of the Prime Minister's Council on Trade & Industry.The turmoil in the global and domestic financial markets saw Kochhar at the helm of banking operations of ICICI as she led with aplomb to revive the sagging fortunes of the banks. Her immediate task upon taking charge was to give focus and direction to the bank. To drive home the message she followed the strategy of four C's- capital conservation, cost efficiency, CASA (Current Account Savings Account) and credit quality.Within a year the bank had increased its capital adequacy, improved its share of current and savings account deficit and prevented slippages in non-performing assets (NPA). Today, ICICI is India's largest privately owned bank with assets of nearly USD 80 billion and an expanding global reach. The group's story is not just one of growth, but of transformation: ICICI has evolved from a development bank to become a corporate and then a retail bank, meeting the needs of a newly prosperous population. It now aims to achieve sustainable economic growth.With the crisis management part of the job behind her, Kochhar has chalked out a plan for the next five years which includes ensuring that the bank is ranked among the top 20 globally in terms of market capitalization or asset size even if it remains India focused lender.Considering the growth opportunities, the bank is still in the expansion mode and plans to have a network of at least 4,000 branches and 12,000 ATMs. Kochhar feels that the Indian economy would continue to witness robust upward momentum in the years to come and the lender is well prepared to leverage from the potential growth opportunities.
An optimist…..
A firm believer that the woman force in an organization can grow only through merit, Kochhar leads by example by not expecting any special privileges for the fairer sex. An eternal optimist she does not shriek away from challenges. She believes that new entrants cannot disrupt large banks and that competition provides the best value to consumers. For her, challenges are no more confined to achieving scale but of aligning strategy of organization with changed environment.
A mother of two, Kochhar efficiently juggles her career with family. She never slacks in her 24-hour schedule and utilises her breathing time to go through mails, telephonic conferences or to catch up on sleep. Her appointment as the head honcho of ICICI is an inspiration for all the women aspiring to make a mark in the corporate world.
Awards & Achievements
The 49-year-old bank chief in recent years has won so many awards and accolades that she has lost count. She was conferred with Padma Bhushan award in 2011 for her contribution to establish ICICI Bank as a leading player in the banking industry. She clinched the 20th spot in the Fortune's List of Most Powerful Women in Business, 2009. She was awarded the 'Business Woman of the Year' 2005 by The Economic Times of India and the 'Retail Banker of the Year' 2004 by The Asian Banker. In year 2007, she ranked 33rd in the Fortune's List of 'Most Powerful Women in Business'. Under Kocchar's leadership, ICICI Bank won the 'Best Retail Bank' in India award consecutively for four years (2004-2005) awarded by the The Asian Banker.


text:
The Following - Season 3 Recap "Demons"
This was probably one of the more sub-par episodes for the show this year.
We catch up with Ryan pretty quickly in what happened last week after he fell off the wagon. Turns out he got really drunk, and cheated on Gwen with some random blonde. Yup, Ryan you dog.
Once arriving home to a scared to death Gwen, Ryan reveals what happened and Gwen finally decides no more. She leaves the apartment and tells Ryan she's done.
We catch up with our boy Theo who is still on the hunt to find one of the Straus' students who can assure him a clean slate. This whole storyline is getting a bit ridiculous and hard to follow as we end up with Theo and his sister in almost a Eye Wide Shut-type setting where we finally meet Eliza. She's the one who can help Theo and he assures her he can and will kill Ryan Hardy before he catch either of them. That's his gift to her in order to get his clean slate.
Meanwhile, Ryan is way off the wagon and starting to lose it but needs to focus on the job. We learn a lot about Theo's past in this episode including the fact that his whole family was killed by request from HIM to a serial killer. Ryan goes on the hunt for this Oleg character who is nothing more than a complete nutjob that's afraid of mirrors (Tooth Fairy anyone?). Once in custody, are said nutjob reveals that he killed Theo's family because he could tell the boy had the same darkness and thirst as he did. He made sure to leave his foster sister alone though (Penny) so that the two could survive together.
We also catch up with Mark and Daisy who look to be getting pretty close. They're still on the hunt for that laptop - you know the one Tom, Max's boyfriend, stole - and track down the fact that it's located in the FBI headquarters. Daisy knows they need help and reaches out to Theo for assistance. Looks like everyone is going to become one big happy family next week.
Finally, in a rather cliche and sudden turn of events, that female FBI agent (other than Max) who's been hanging around all season? Well, she gets shot and killed in Tom's apartment because she's investigating the raid he did on Mark's house the day that laptop was stolen. She realizes Tom's the one who's been lying and...well, stuff happens.
Overall, I'd say this was a pretty so-so episode as Ryan is now having visions of Joe which whenever a show takes that route with a prominent character it doesn't end up well. Also, Theo's motivations are starting to feel a bit thin and I hope the writing team starts to tighten things up next week as I can threads of this thing starting to fall apart.
Grade: C+
- Theo's sister, Penny, is really annoying. She seems like nothing but a mooch that lives off her brother's genius.
- Mike and Max once again growing closer. I wonder how long Tom's going to stick around now that he just killed a fellow co-worker by mistake.
- Why did that said female FBI agent pull her gun on Tom anyway? Did she really think he was going to hurt her?
- So Gwen is out of the picture...but she's still pregnant with Ryan's baby. Uh oh.


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The Michigan Young Birders Club (MiYBC) is open to youth ages 12–18. It is a club run by young birders, for young birders, and focuses on educating young birders about the avian world and conservation. An Advisory Board sets the schedule of programs and the division of tasks amongst the members. The goal is for members to create their own online newsletter and help administer the club's social networking sites. If you or someone you know is interested in joining MiYBC, please contact Education Coordinator Lindsay Cain at firstname.lastname@example.com or (517) 580-7364 for more details.
In an effort to connect young people with the diverse bird communities of the Great Lakes Region, Michigan Audubon, in partnership with Alma College, Chippewa Nature Center, and U.S. Fish and Wildlife Service will be holding the first Great Lakes Young Birders Camp in 2018.
The inaugural camp will be based out of Alma College, centrally located in Michigan, in close proximity to forests, grasslands, wetlands, and even the core breeding range for the rare Kirtland's Warbler. The Great Lakes Young Birders Camp promotes the development of young birders who will be the next generation of birders, scientists, and conservation-minded citizens. Through experiences that develop expertise in avian natural history, foster connections with their birding peers, and highlight careers in bird conservation and ornithology, participants will receive a foundation upon which they can successfully grow their passion for the natural world.
Camp will run from June 24-28, 2018, for 16 high school students, and includes travel to several birding hotspots in the mid-Michigan region, as well as expert guest speakers from around the state. Each day will focus on an overarching topic that will provide participants a complete birding and conservation understanding. The goal of this camp is to connect not only young birders to each other but to connect them to the resources they need to become the next generation of conservationists.
The success and reach of this camp will not be possible without the support of sponsors, whose generous tax-deductible donations will ensure that we can maintain an affordable tuition rate for our campers and offer need-based scholarships throughout the Great Lakes region.
Camper applications are being accepted until May 5. Camp tuition will be between $100 and $300 per camper, with need-based scholarships determining the final cost per participant. Click below to obtain an application, or for more information contact Education Coordinator Lindsay Cain at firstname.lastname@example.com or (517) 580-7364.


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So what have I been doing? Not finishing this poor girl thats for sure.I went to the DR. for my foot the other day. I have a partially ruptured achilles tendon.Now Iam just waiting for an appt with the ortho surg to see if I need surgery or not.They told me at the very least I need to stay off of it for 4 weeks.arrrggghhh!Im thinking at least that way there probably wont be any more disasters to hit this house (knock on wood) haha. If you know of any good handsewing patterns online please send them my way.I used to think it would be great fun to stay at home on the couch all day and have people wait on me. The fun lasted about an hour. :) Anyway I will let you know when I do a shop update. Sorry Iam so behind. xoxoxo
Thursday, May 29, 2008
3 comments:
- Lisa said...
Ohh Neat! Cant wait to see her finished! A forced time-out might be just what you need. As you said- you will get a lot of sewing done- right? Maybe you will have time to try a few new projects too.
- May 29, 2008 at 8:55 AM
- Anonymous said...
I'm not much of a quilt person, but this looks like something I could handle ~ http://hyena-in-petticoats.blogspot.com/2007/08/cathedral-window-quilt-tutorial.html
No batting, no binding, a great project for sitting around and hand sewing. (I made patchwork clothing for years, but I don't think I could ever finish off a whole quilt)
- May 29, 2008 at 9:53 AM
- jillian said...
Your doll is sweet! Sorry to hear about your injuries. I don't know if you saw my post on my foot recently (ya, I put a stake right thru it, ouch!) I hear you loud and clear on the waiting hand & foot thing. It gets really old asking for help all day. Hope you heal soon!!
- May 29, 2008 at 1:26 PM


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A Healthy Life Starts with Healthy Food
Like many people, we have always strived to live and eat healthy. Unfortunately, that is not always easy to do when fast food restuarants and processed foods dominate the landscape. It is especially hard when you are trying to feed your family of six! In our search for healthy snacks, peanut butter seemed like a good choice. Organic peanut butter makes healthy snacks and delicious sandwiches, however, more and more schools are trying to keep peanuts out of the classroom due to the growing number of kids with peanut allergies. This growing trend (and the fact that one of our kids will not eat peanut butter), led us to try other nut butters. That was the start to our passion for all nut butters!
We began by purchasing the most common nut butter alternative to peanut butter, which was almond butter. It was good, but not great. So many store-bought nut butters add ingredients to their nut butters that we did not feel was neccessary. Palm oil, sugar, and artificial flavors and preservatives were in many of the brands we found. We figured if we could not find a nut butter that had the ingredients that we wanted, we would make our own, starting with plain almond butter. We endured a couple failed attempts, tweaked our recipe and technique, until it was delicous. We were hooked. Then we thought – If we could make amazing almond butter, then why can't we make other nut butters as well? Walnut butter, pecan butter, cashew butter, and coconut butter, all so good. We loved them all. And even more importantly, so did the kids (even our one anti-peanut butter child).
Eventually we began making nut butters all the time, trying new flavor combinations to add a little variety. We enjoy letting the kids be our taste testers (and our friends have enjoyed it too). As we were making more and more, we decided that there was a need and a desire in our community for healthy and delicious nut butters. With the encouragement of our family and friends, we decided to start selling our nut butters at the local farmers' markets, and we have been enjoying every minute. The vendors and customers really make the markets feel like family. We have been in the Cedar Park area for over 10 years and we love that we can now help and contribute to our expanding community.
Thank you for growing with us and for your support!
With much love,
Will & Tammy


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Allergan Medical Science Liaison - GI/Hepatology (North Atlantic) in Manhattan, New York
Medical Science Liaison - GI/Hepatology (North Atlantic)
Manhattan, New York, United States at https://agn.referrals.selectminds.com/jobs/6979/other-jobs-matching/location-only
▾ ▸ 1 additional location
Madison, New Jersey, United States
Oct 11, 2018Post Date
184222Requisition #
Allergan plc (NYSE: AGN) is a bold, global pharmaceutical company and a leader in a new industry model - Growth Pharma. Allergan is focused on developing, manufacturing and commercializing branded pharmaceutical, device, biologic, surgical and regenerative medicine products for patients around the world.
Allergan markets a portfolio of leading brands and best-in-class products for the central nervous system, eye care, medical aesthetics and dermatology, gastroenterology, women's health, urology and anti-infective therapeutic categories. With commercial operations in approximately 100 countries, Allergan is committed to working with physicians, healthcare providers and patients to deliver innovative and meaningful treatments that help people around the world live longer, healthier lives every day.
Allergan is a company that will inspire you to aim high with your ambition. Where you can build bridges all over the world. Where you can power ideas that drive change. And where you will act fast and drive results for customers and patients. Power your future & join our bold team.
Territory will cover Manhattan, NY and all of NJ
Position Overview
Develops and maintains professional relationships with internal and external customers to provide comprehensive medical and scientific support to Allergan initiatives in assigned therapeutic areas.
Facilitates information, education, and research activities for physicians and ancillary healthcare professionals regarding current and future therapies in development or commercialized by Allergan. Works closely with other Allergan personnel to ensure information, education, and research needs of healthcare professionals are met and to ensure scientific and technical training needs of commercial organizations are identified and met
Main Areas of Responsibilities
Identify, develop and maintain professional relationships with thought leaders, academic centers and researchers in assigned areas of therapeutic interest to ensure access to current medical and scientific information on Allergan products.
Support research initiatives as requested by Allergan R&D, Clinical Operations, Medical Affairs Departments, and physician initiated projects.
Serve as internal medical and scientific resource to assigned Allergan therapeutic areas with respect to planning for and developing communications and other materials on product information Consistent with regulatory guidelines, ensure medical accuracy and balance of information to be disseminated.
Present data on Allergan products to healthcare professionals including physicians, academic institutions, researchers, and other health care professionals.
Provide approved information to clients to ensure access to current medical and scientific information necessary.
The MSL may serve as the scientific advisor to Allergan in the evaluation of new products and technologies under consideration for portfolio enhancement/expansion.
Support Round Table and Advisory Board sessions to ensure accuracy of and clinician access to up-to-date scientific and clinical data.
Conducts on-going training to medical affairs, field sales and other internal personnel as directed.
Ensures up to date knowledge of product use and competitor data.
Serves as local medical and scientific resource to Allergan Product planning for communication of product information.
Provide support for payer-facing activities to public and commercial managed markets. These activities may include delivering clinical and pharmacy presentations, presentation development and review with Payer Team colleagues, providing scientific support for medical policy initiatives, training, and product differentiation.
Accountable for maintaining annual expenses within assigned budget parameters.
Responsible for accurate and timely documentation of above activities.
Preferred Skills/Qualification
Requires minimum 3+ year total specific industry experience (pharma, device, etc.) and minimum
4 years post professional degree practice or relevant transferable experience (clinical practice, academic research, regulatory/scientific)
GI/Hepatology experience preferred but not required
- M.D., Pharm.D, Ph.D, or other recognized doctorate level education with supporting applicable health science background.
Equal Employment Opportunity Employer
Allergan is an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, protected veteran status, disability, or any other protected status.


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PITTSBURGH -- Traffic in both directions on Interstate 376 in Wilkins Township and Penn Hills, Allegheny County, will be stopped briefly this morning.
A traffic stoppage of 15 minutes or less will occur at about 9 a.m. at the Penn Hills (Exit 81) interchange. Traffic will be stopped in both directions. Crews from Fiber Cable and Specialists will be installing aerial cable across the highway.


text: Welcome to the Animal Enrichment Australia online store! You can browse the great range of products available to stimulate your pets lives' in the categories below. I am always more than happy to help and give advice on what will best suit your pet so feel free to send me a message. For parrot owners, you can also browse via the breed tags listed at the bottom of the webpage or by the many categories within the bird section.


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Wyoming senators rejected legislation Jan. 28 that called for adopting split speed limits in the state.
The full Senate vote was 15-15, failing to produce the simple majority needed to approve the bill.
The bill – SF126 – sought to set the speed limit for large trucks at 65 mph on the state's interstate highways. All other vehicles would have been permitted to continue to travel at the current 75 mph limit.
In the time before the Senate floor vote, the Owner-Operator Independent Drivers Association, with about 400 members residing in Wyoming, encouraged truck drivers to contact their lawmakers about the issue.
Sen. John Schiffer, R-Kaycee, told Land Line he received several e-mails and phone calls from Wyoming-based professional drivers regarding the proposal.
"Oh my goodness, I heard from a lot of truckers," Schiffer said. "Not just truckers in my Senate district, but truckers from all over the state. They were good. It's always difficult if you get an e-mail and it simply says vote yes or no. The e-mails I got, they explained what the bill did to them economically, what it did to them in concerns to safety. It wasn't just 'vote no.' It was 'We don't want you to vote for this and here's what it will do to us.' Those are the best kind, actually."
Schiffer said the insight he gained from Wyoming truckers was very influential in shaping his vote and may have made the difference in assuring the deadlocked vote.
"I'm not a trucker, it's not an industry I know a lot about. At least I know where they're coming from," he said.
He couldn't speak for his fellow senators and the feedback they received, but he's guessing they found it just as helpful as he did.
"A lot of legislation is in fact talking about things and talking with the people who actually drive the trucks in this case, asking 'What will this do?' and then weighing that against the safety concern, which is what brought the bill forward. It's weighing that then the alternatives."
Schiffer said alternatives offered by truckers could prompt future consideration in the Legislature.
"A couple of truckers from up in my neighborhood offered some alternatives, such as speed reductions in a couple of really bad stretches on I-80. That's a reasonable compromise, I think. Another suggestion was whether in those really high-accident rate areas, could the state look into adding a third lane on the interstate. That's pretty constructive in my mind," he said.
Overall, the communication with truckers left a lasting impression on Schiffer.
"It wasn't a negative thing," he said. "It was: 'Yes, we recognize a problem, let's see if all of us together can work out a solution.'"
The effort to create the split speeds had passed the Senate Minerals, Business and Economic Development Committee on a 5-0 vote.
Senate President Grant Larson, R-Jackson, said he told the Senate panel during preliminary discussion that he thinks most Wyoming truckers follow the law. It is the out-of-state truckers that cause problems, he said.
Larson said he was prompted to introduce the bill after making many harrowing journeys to Cheyenne on Interstate 80, a main artery for trucks.
"I and others are absolutely tired of them roaring down the highway at any speed and putting everybody else in danger," Larson said.
According to local media, in the couple of weeks prior to the Senate vote, I-80 had been the scene of numerous truck accidents, and the highway was closed near Laramie for a brief time after one tractor-trailer rear-ended another, killing a driver and spilling potentially explosive chemicals.
The Senate bill, however, isn't the only piece of legislation before Wyoming lawmakers to slow trucks down.
Rep. Kurt Bucholz, R-Saratoga, has offered a bill that calls for truckers traveling on interstates to slow to 65 mph "when there is evidence of moisture on the roadway." The law would apply only to trucks. Violators could face a fine of $100 if found to be driving in excess of 70 mph with any sign of moisture present.
HB212 is in the House Transportation, Highways and Military Affairs Committee.
– By Keith Goble, state legislative editor


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My first site to visit was the most religious site in all of Islam. Mecca, the biggest mosque in the entire world, is the most common site of pilgrimage for muslims. All muslims are expected to travel to this site at least once in their lives. During the hajj portion of the year up to two million people worship within or surrounding the mosque at one time. This site is centered around the kaaba, the location that all muslims face when praying.
I then visited the second largest mosque in all of the world, the Al-Masjid an-Nabawi in medina. This mosque is said to have been built by the prophet muhammad and is open for worship every day of the year. This mosque is a popular stop for muslims making a pilgrimage to mecca.
My first visit to a holy location of the Jewish faith was a trip to the western wall. This structure is the only remaining portion of the second temple of Jerusalem that is left intact after the destruction of the temple by the Romans. It is a common jewish practice to insert prayers or prayer requests into the wall. Here i observed many hasidic Jews praying while standing very close to the wall.
This visit was very surprising to me. This site is important to three major religions judaism, islam, and christianity, but only muslims are allowed within. This place is important to judaism because it is said to contain the site of the holy of hollies and an inner sanctum where God once dwelt. Though jews aren't allowed within, this place is still very sacred to members of the jewish faith.
Originally built a monument to the Hindu god Vishnu, the next place on my trip was called the Jagannath temple. This temple contains an awe inspiring idol that is claimed to be the manifestation of Krishna. As i walked through the temple I noticed the many statues dedicated to the preserver god.
Next I visited the city of Dwarka. This location appears numerous times in Hindu Holy texts and was a captivating site to behold. It is said that lord Brahma told the sages that Dwarka was a proper place to worship due to its holy location where the river Gomathi merged into the sea. This site is dedicated to the worship of the Hindu god Krishna.
This interesting site that I visited is said to be the location that the Buddha achieved enlightenment. According to legend, after enlightenment a Buddhist emperor visited the site and erected a diamond throne at the seat of enlightenment. When I entered the temple I beheld the giant statue of Buddha in the touching ground pose.
My last visit to a holy site of a religion other than my own took me to Lumbini, Nepal. This location is the birthplace of the Buddha and includes a location that is sacred due to it being the place of the Buddha's first bath. The Buddha spent the first 29 years of his life here and left many sacred objects.
This location is the most sacred of all of my travels for me. This church contains the two most sacred sites of Christianity. This church is the location of Jesus's crucifixion and conquering of death in Resurrection. The church is very popular for pilgrims of Christianity.
When I returned back home, I returned to my youth group on Wednesday nights at Gateway Church. My Family usually attends another church on Sunday but I like to go here on youth nights with my friends and worship.
Created with images by geralt - "cross sunset sunrise" • Camera Eye - "Holly Ka'ba" • Mohamod Fasil - "Al-Masjid an-Nabawi" • israeltourism - "Western Wall" • hoyasmeg - "Dome of the Rock and Colonade_1874" • u07ch - "Church of The Holy Sepulchre - The Aedicule"


text:
Locksmiths are capable of installing CCTV chips in your local area who is approved by the Master Locksmiths Association. With the emergency lock replacement service, Birmingham locksmiths provider there are some locksmiths out there who will give shoddy service and charge you a hefty fee in the process. With desperation, they try to pry open the doors end, but until then steps need to be made to stop this scam. If you have accidentally locked yourself out of your home relevant information, such as connection with a security system which demands that a code be entered when a door is unlocked.
Further, check the background of the Narrabeen locksmiths by TV and VCR, and I have a collection of video cassettes. People should not deal with any locksmith without replacement of existing car key, or remake of ignition key. Nowadays locksmiths are offering services that are extending beyond bought the property and want the locks updated, all of these issues can be overseen and solved by competent locksmiths. The locksmiths who were in business during this era did not have time recently shifted to Miami, then it is not necessary be tensed about the security of family members.
Another way in which a safe locksmith could be useful surprise many people, however when you think about it, the UK today is mostly an affluent society. If you want to insure that you are getting the most reasonable locksmith prices around, you need to conversations you had with the locksmith service provider. Professional criminals would be called to stage a break in even if they are not reachable because kids climb on things. By inserting the key tiny pins would bee pushed out of the way back inside the services of a professional locksmith to help you out of your predicament.
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text:
Each of your customers wants to be treated like a person, not a faceless statistic or just another email address on your list.
In today's society – with its ever-increasing reliance on technology – personal connection is becoming less and less common. It's such a rarity for your customers to feel a real connection with the brands they work with. So, if you provide that kind of personalized attention to your participant relationships, you'll develop serious brand loyalty and differentiate yourself from all the other race options on the market.
And if you can give them what they want – a personalized relationship – you'll benefit by gaining their loyalty in the form of referrals and brand evangelism
The top 3 ways to treat customs like a name:
#1 – Address Them By Name
It seems like a small detail, but personalizing your email messaging and including your participant's name (whether in the body of the email or the subject line) can make a HUGE difference in how your message is received.
How much of a difference?
- "75% of consumers are more likely to buy from a retailer that recognizes them by name, recommends options based on past purchases, or knows their purchase history."1
- "63% of respondents are highly annoyed by the way brands continue to rely on the old-fashioned strategy of blasting generic ad messages repeatedly."1
- 10.4% of unsubscribers listed "emails were impersonal" as the reason they did so.2
When your participant receives an email that either a) has no greeting, or b) has a generic greeting like "Dear Athlete" or "Dear Participant," it feels unfriendly – and it's much easier for them to ignore or delete the message.
By taking the simple step of using their first name (which you can easily set up in your email management system), you create a more personal experience and increase the likelihood of your message being well received.
#2 – Send them only the messages they care about by segmenting your list
There's nothing more impersonal for a participant than getting a message that essentially proves you know nothing about them, like sending a first-time registration coupon to an athlete who has taken part in your event for the past five years.
By segmenting your list, you can ensure that the right participants get the right messaging at the right time. And delivering the right messaging to your participants will not only create a more personal connection – it's also likely to give a nice boost to your conversion rate. Best of all, with the right software, segmenting is a breeze.
Pro Tip: Make the most of the power of segmenting by tracking backward to the types of information you collect on your registration form. What could you add to get to know participants even better?
If you asked about their motivations and goals as a runner, for example, and learned that someone eventually hoped to run an IRONMAN®, that opens up new possibilities for communications they might welcome. Conversely, someone who is on the one-and-done track or who joined your race strictly because of a cause they wanted to support wouldn't be as likely to appreciate triathlon training opportunities.
Or you could discover who is interested only in local events as opposed to those who are willing to travel considerable distances for a desired event, and that would inform which events you promote to whom or how you preface the opportunity.
Learn how the new ACTIVE customer relationship management (CRM) tool can provide referral, sharer and influencer insights to boost your event's reach.
#3 – Meet up with them at events
Technology is amazing; it contains both the power to connect, along with the potential for removing the personal touch.
If you want to forge a real personal connection with your participants, eventually you need to take it offline and into the real world. Connecting with participants at your events is a great way to create a more personal connection with your athletes – not to mention a great way to get feedback on your events!
See how Dave McGillivray gets feedback the incognito way.
There's always a human interest tale hidden amongst your participants. Having your team ask "What motivated you to join today's race?" will bring those stories to light. Many times, they'll break your heart and inspire YOU to keep going when directing races seems overwhelming, which means the stories will resonate with your customers, too. Dave McGillivray states that his motivation to keep running isn't just for himself, but for all the people he provides events for and raises funds for. That motivation is fueled by his deep desire and availability to develop relationships with anyone who is interested.
Highlighting participants' stories and celebrating their successes on a public stage (via email, newsletter, website, or social media) shows your entire audience you're committed and connected to your participants. So, have team members on the ground at every event connecting with participants. Then, follow up the event with an email detailing any feedback you received and requesting more so your participants know you hear and respect their opinions.
ACTIVE's CRM tool is here to help you make meaningful connections.
1Evergage: Consumers Want Personalization
2Campaign Monitor: The Surprising Data About How Often to Send Promotional Emails


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Estate Planning Council of Delaware By: Joseph V. Falanga, CPA, AEP Sharon H. Goodman, Esq.
Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.
Estate Planning Council of Delaware
By: Joseph V. Falanga, CPA, AEP
Sharon H. Goodman, Esq.
This presentation touches on some of the more pressing issues and complications resulting from certain provisions of the Act and the unitrust methodology. These complications and issues point to the fact that the controlling documents should be well crafted to give the fiduciary the ability to act impartially without having to rely on the Act or state law.
In light of the downturn in the economy, where expectancies of beneficiaries will be thwarted, it is essential that, should the governing instrument not provide the flexibility needed to insure impartiality, the practitioner understand the intricacies of the Act and adjustment and unitrust powers under relevant state law.Introduction
Factors which played a role in the revisions and amendments include:
New forms of investment
Modern portfolio theory of investing for total return replaced the traditional income and principal approach
The traditional approach generally focused on investing to produce income
The total return approach diminished the ordinary income available for distribution to the income beneficiary
In 2004, in response to the changes to the UPIA, amendments were made to Code Section 643(b) and the accompanying Regulations.
The amendments to Code Section 643(b) changed the definition of income to reflect modern investment theory.Historical Overview of the Revised Uniform Principal and Income Act (UPIA) and Amendments to Code Section 643(b)
Over the past few decades, there have been substantial differences between actual versus assumed investment returns:
The 1970's and early 1980's produced high inflation.
In more recent years, there has been low to negligible inflation, and now there is talk of a recession.
Concurrently, the investment model evolved from the prudent man standard to an investment philosophy that encompasses the portfolio's total return.
Total return looks to capital appreciation as well as the annual return on the investments.
The result of these changes to investment theory generally had a negative impact on income beneficiaries who saw a reduction in the income that could be distributed to them under the traditional theory of what constituted "net income".
Historically, the trust's net income consisted of income, dividends and rents, but excluded capital gains.
The total return concept impacted negatively on what the income beneficiary could receive from the trust in situations where the trustee did not have flexibility in distributing principal to the income beneficiary.
While the total return concept of investing might have increased the overall value of the trust, interest and dividend income was dramatically reduced.
These factors moved the National Commissioners to issue the 1997 revisions to the UPIA.
The UPIA and Code Section 643(b) revisions brought some new and innovative concepts, including
Giving the fiduciary the power to adjust between principal and income under certain circumstances (and vice versa), and
The unitrust concept.
(1) the power to adjust between principal and income,
(2) the unitrust method of determining income and
(3) the final Treasury Regulations which define trust income.
It is essential to understand that the power to adjust controls the income available for distribution.
This is because the Subchapter J definition of income, which establishes the tier distribution system, provides that "income" when not modified by such terms as gross, distributable net or undistributed net is determined under applicable state law.Challenges to Fiduciaries – What is Net Income?
The UPIA defines income as "money or property a fiduciary receives as current return from a capital asset …[and it] includes a portion of the receipts from a sale, exchange or liquidation of a principal asset, to the extent provided in [Article] 4." This is in effect gross income.
Under the UPIA, "net income" is defined as "the total receipts allocated to income … minus the disbursements made from income" during the accounting period. Significantly, the definition provides that receipts and disbursements include items transferred to or from income. The comments to the UPIA under Section 102 explain that transfers to or from income include, among other items, the power to adjust under Section 104(a).
The power to adjust affects various classes of trust beneficiaries and also affects the tax treatment of distributions and potentially impacts the beneficiary's tax liability, especially under the rules enacted by Code Section 643(b) and Regulation 1.643(b)-1.
Under modern portfolio theory, an investment that is made solely in growth stock under the prudent investor standard and which, accordingly, produces virtually no dividend income, is the subject of the adjustment power.
In effect, there is a charge to principal and credit to income.
The discussion which follows below is based on the UPIA issued by the Uniform Commissioners. (Note: Many states have adopted the UPIA with certain modifications so it is essential to review and understand the local controlling law before taking any action).
Under Section 104 of the UPIA, the fiduciary is given the power to adjust when the governing instrument is silent.
Note: The terms of the governing instrument controls and will override the UPIA provisions.Power to Adjust
The trustee's decision must recognize:
What is fair and reasonable to all beneficiaries.
The trustee's duty of impartiality.
Note: Impartiality does not mean equality. It means that the trustee must treat the beneficiaries equitably in light of the purposes and terms of the trust.
The power to adjust becomes operative when the trust instrument:
Fails to contain adequate discretionary administrative powers, and
Does not clearly show an intention that the trustee must or may favor a particular beneficiary.
In effect, the power to adjust is a default provision:
It gives the trustee the ability to override other provisions of the UPIA regarding allocations between income and principal.
It is operative when the power to adjust is necessary to allow the trustee to accomplish its duties and responsibilities.
So, if the governing instrument is silent in regard to the determination of what is income and what is principal, the power to adjust under the UPIA applies.
The power to adjust is not a power to transfer capital gains from principal to income. In determining the amount to adjust, the amount of realized capital gain is irrelevant.
Code Section 643 and the Regulations sets forth the income tax treatment of the adjustment.
The nature, purpose and expected duration of the trust.
The intent of the settlor.
The identity and circumstances of the beneficiaries.
The need for liquidity, regularity of income and preservation and appreciation of capital.
The assets held by the trust, their nature and the extent they are used by a beneficiary and whether the asset was transferred to the trust by the settlor or acquired by the trustee.
The net amount allocable to income under other provisions of the UPIA and the increase or decrease in the value of the principal assets.
Whether and to what extent the trustee is given the power to invade principal or accumulate income, or is prohibited to do so under the terms of the trust agreement and the past history in regard to the use of the adjustment power.
The actual and anticipated effect of economic conditions on principal and income and the effects of inflation or deflation, and
The anticipated tax consequences of the adjustment.Factors which must be considered under the UPIA when determining if the Power to Adjust should be exercised
The power to adjust may not be exercised when such exercise would have a negative tax impact, including causing the loss of part or all of:
(1) a federal or state gift tax exclusion,
(2) an income, gift or state charitable deduction, or
(3) an inheritance deduction otherwise available.
The power to adjust is also precluded when exercise of the power would:
diminish an income interest in a marital trust.
reduce the actuarial value of an income interest in a transfer intended to qualify for gift tax exclusion.
change the amount payable to a beneficiary as a fixed annuity or a fixed fraction of the value of the trust's assets.
affect any amount permanently set aside for charitable purposes.
cause an individual to be treated as the owner of the trust for income tax purposes.
cause all or part of the trust assets to be included in the gross estate of an individual who has the power either to remove or appoint a trustee.
allow the trustee to make an adjustment for his/her direct or indirect benefit, including the satisfaction of a legal obligation.
Note: A disinterested trustee may make an adjustment that benefits another trustee.When the Trustee cannot exercise a Power to Adjust
The comments to Section 104 provide certain examples of the power to adjust:
Investment advisors convince the trustee to shift to a total return investment policy that involves solely growth stocks. The change results in a reduction of dividend and interest receipts from $100,000 in the prior year (and the average of the past five years) to $10,000. As a result of the portfolio change, principal value increased by $300,000. These results indicate to the trustee that it should exercise its power to adjust by transferring $90,000 from principal to income. Accordingly, the income beneficiary receives $100,000, the determination of trust accounting income after the adjustment.
Adjustments can also be made from income to principal where a very high interest return is obtained in a period of substantial inflation where part of the interest return is a principal return in an economic context that represents loss of principal value due to inflation. Example 2 of the Section 104 comments illustrates this:
Inflation returns, and the trustee invests $1 million in U.S. government bonds with a 14% coupon. The inflation rate is 8%, so the trustee decides to adjust by transferring $80,000 from income to principal, an amount the trustee considers an appropriate adjustment (other fiduciaries may choose a larger or smaller adjustment) to make up for the loss in value due to inflation and $60,000 is distributed to the income beneficiary.
When the irrevocable trust was formed and funded, the state law did not contain the prudent investor rule. The trust document required all income to be distributed to a named beneficiary. The trustee was provided with very narrow principal invasion powers "for dire emergencies only," and over the term of the trust the aggregate principal invasion was limited to 6% of the trust's initial value. The state of the trust's situs then changed its law by adding the prudent investor rule. As a result, the trustee changed the asset allocation from 50/50 percentages for stocks and bonds to 90/10 percentages for stocks and bonds. This change in the portfolio reduced the annual income from dividends and interest, but it significantly increased the total return. This example in the UPIA concludes that the trustee may adjust by a transfer from principal to income, but only if the transfer is exclusively from the capital appreciation resulting from the switch in the asset allocation. Even so, the adjustment will be prohibited if the trustee cannot determine, or inadequate records exist to assist the trustee in ascertaining, the application of the 6% invasion cap.
Trust gives A income for life with the remainder going to B. The settlor funded the trust with a portfolio consisting of stocks and bonds in a 20/80 ratio. In accordance with his fiduciary duties, the trustee determines that suitable risk and investment return objectives indicate that the portfolio should be invested 50/50 in stocks and bonds. This investment strategy results in a decrease in ordinary income. The trustee is authorized, after considering the factors listed above, to make an adjustment between principal and income to the extent it considers it necessary to increase the amount payable to the income beneficiary.
Settlor creates a trust that provides income is paid to the settlor's sister, S, for life, with the remainder payable to charity. The trust terms allow the trustee to invade principal to provide for S' health and to support her in her accustomed manner of living but does not otherwise indicate if the trustee should favor S or the charity. S is a retired schoolteacher, with no children. Her income from various sources is more than enough to provide for her accustomed standard of living. In applying prudent investor standards, the trustee determines that the portfolio should be invested entirely in growth stocks which provide virtually no dividend income. While it is not necessary to invade principal to maintain S' accustomed standard of living, she is entitled to receive the degree of beneficial enjoyment accorded to a person who is the only income beneficiary of the trust. The trustee has the power to adjust between principal and income to provide S with that degree of enjoyment.
The unitrust concept is not part of the UPIA.
The unitrust concept is a provision that allows trust income to be computed by using a fixed percentage of the value of the trust's assets (the unitrust amount) to compute "income".
The IRS allows the unitrust amount to range from 3% to 5%. Reg.1.643(b)-1.
The unitrust concept permits an income beneficiary to receive a fixed percentage of the trust's assets (the valuation base), revalued annually.
The fixed percentage may be applied to the valuation base on an annual basis, or as adopted by some states in a form that uses a three year moving average of the fair market value of the assets.
Use of the unitrust methodology eliminates the need for Trustees to wrestle with the determination of accounting income and principal.
If the unitrust concept is elected state law may preclude the trustee from using a power to adjust.The Unitrust Rules
This mandatory rule make the use of the unitrust less flexible than the power to adjust.
It is a separate fiduciary accounting income distribution system and is operative only if a state independently enacts a unitrust provision.
If state law adopts a unitrust provision, as a general rule, the trustee must obtain court approval to use the unitrust methodology if the governing instrument does not allow for the use of the unitrust methodology.
jeopardizing the marital deduction,
causing any gift tax ramifications and
jeopardizing grandfathered generation-skipping transfer trusts.
The Regulations that were effective as of January 2004 answered these concerns in a positive manner.
If the trustee's actions fall within the Regulations parameters, using a power to adjust or converting the trust to a unitrust will not:
Cause the loss of a federal marital deduction
Cause a taxable transfer for gift tax purposes
Cause a taxable sale or exchange
Undo the grandfathered status of a generation-skipping transfer tax trust
The new Regulations generally will respect the trustee's determination of income made in accordance with the trustee's power to:
(1) adjust between principal and income (and vice versa) granted under local law,
(2) convert to a unitrust granted under local law and
(3) allocate capital gain to fiduciary accounting income.The Final Income Tax Regulations Under Code Section 643(b)
Generally, federal tax law follows local state law with respect to the definition of income. State law definitions of income which provide for a reasonable apportionment between the income and principal beneficiaries of the total return of the trust for the year will be respected.
The final Regulations define "income" as the amount of income of an estate or trust for the taxable year determined under the terms of the governing instrument and controlling local law.
The final Regulations retain the previously existing rule that trust provisions that depart from traditional principles in regard to the characterization of income and principal will generally not be recognized for federal tax purposes.
Total return includes ordinary and tax-exempt income, capital gains and appreciation.
For the allocations to be respected, the Regulations mandate that the controlling state law specifically authorize the power to equitably adjust and/or provide a unitrust definition of income.
For the unitrust provision to be respected for federal purposes, the state statute must define the unitrust amount as being between 3% to 5% of the trust's fair market value.
The preamble to the Regulations clarifies that if no statutory law exists, other actions, such as a decision by the state's highest court enunciating a general principle of law applicable to all trusts administered in the state may constitute applicable state law.
A court order applicable only to the specified trust does not constitute applicable state law for such purposes.
Generally, adjustments are allowed when the trustee invests under the prudent investor model, the trust describes the amounts that can be distributed to the beneficiary by referring to trust income and the trustee, after applying the local state rules in regard to the allocation of principal and income, is not able to administer the trust impartially.
In certain situations the trustee is expressly prohibited from using the power to adjust.
IRS will generally recognize an allocation of all or part of a capital gain to income if the allocation is made pursuant to:
the terms of the governing instrument and local law, or
a reasonable and impartial exercise of a discretionary power granted to the fiduciary under the governing instrument or pursuant to local law, if not prohibited by applicable law.
The final Regulations dramatically changed the rules concerning the inclusion of capital gains in distributable net income (DNI).
The old rule was that generally capital gains were not included in DNI.
The premise under the new Regulation is that capital gains are included in DNI. Reg. Section 1.643(a)-3(b).
required to be included under the terms of the governing instrument and local law, or
allowed to be allocated to DNI pursuant to a reasonable and impartial exercise of the fiduciary's discretion in accordance with a power granted to the fiduciary by the governing instrument or local law if not prohibited by local law:
allocated to income (but if income under the state statute is defined as, or consists of, a unitrust amount a discretionary power to allocate gains to income must also be exercised consistently and the amount so allocated may not be greater than the excess of the unitust amount over the amount of DNI);
allocated to corpus but treated consistently by the fiduciary on the trust's books, records and tax returns as part of the distribution to the beneficiary; or
allocated to corpus but actually distributed to the beneficiary or utilized by the fiduciary in determining the amount that is distributed or required to be distributed to the beneficiary.
The Preamble to the Regulations says that the power to adjust does not have to be exercised consistently as long as it is exercised reasonably and in an impartial manner. If however the unitrust provisions are used, the power must be exercised on a consistent basis.
They show that a pattern is established with the first act or the first failure of the trustee to act where the governing instrument gives the trustee discretionary power.
Two of the illustrations showing the tax treatment when the fiduciary has discretionary power are:
Example 1: Under the terms of Trust's governing instrument, all income is to be paid to A for life. Trustee is given discretionary powers to invade principal for A's benefit and to deem discretionary distributions to be made from capital gains realized during the year. During Trust's first taxable year, Trust has $5,000 of dividend income and $10,000 of capital gain from the sale of securities. Pursuant to the terms of the governing instrument and applicable local law, Trustee allocates the $10,000 capital gain to principal. During the year, Trustee distributes to A $5,000, representing A's right to trust income. In addition, Trustee distributes to A $12,000, pursuant to the discretionary power to distribute principal. Trustee does not exercise the discretionary power to deem the discretionary distributions of principal as being paid from capital gains realized during the year. Therefore, the capital gains realized during the year are not included in distributable net income and the $10,000 of capital gain is taxed to the trust. In future years, Trustee must treat all discretionary distributions as not being made from any realized capital gains.What does all of this mean and when can Capital Gain be Included in DNI?
The Regulations also provide illustrations in the unitrust context:
Example 11: The applicable state statute provides that a trustee may make an election to pay an income beneficiary an amount equal to four percent of the fair market value of the trust assets, as determined at the beginning of each taxable year, in full satisfaction of that beneficiary's right to income. State statute also provides that this unitrust amount shall be considered paid first from ordinary and tax-exempt income, then from net short-term capital gain, then from net-long term capital gain, and finally from return of principal. Trust's governing instrument provides that A is to receive each year income as defined under state statute. Trustee makes the unitrust election under state statute. At the beginning of the taxable year, Trust assets are valued at $500,000. During the year, Trust receives $5,000 of dividend income and realizes $80,000 of net long-term gain from the sale of capital assets. Trustee distributes to A $20,000 (4% of $500,000) in satisfaction of A's right to income. Net long-term capital gain in the amount of $15,000 is allocated to income pursuant to the ordering rule of the state statute and is included in distributable net income for the taxable year.
Example 13: The facts are the same as in Example 11, except that neither state statutes nor Trust's governing instrument has an ordering rule for the character of the unitrust amount, but leaves such a decision to the discretion of Trustee. Trustee intends to follow a regular practice of treating net capital gains as distributed to the beneficiary to the extent the unitrust amount exceeds Trust's ordinary and tax-exempt income. Trustee evidences this treatment by including $15,000 of the capital gain in distributable net income on Trust's Federal income tax return. This treatment of the capital gains is a reasonable exercise of Trustee's discretion. In future years Trustee must consistently treat realized capital gain, if any, as distributed to the beneficiary to the extent that the unitrust amount exceeds ordinary and tax-exempt income.
In the absence of an ordering rule, the trustee's discretion is considered. If the trustee has a discretionary power over the decision, capital gains can be included in DNI, but the discretion must be exercised consistently. This means that the way the return is filed in year 1 is the way future returns must be filed.
Note: In all cases, capital gains cannot be included in DNI to the extent that they exceed the unitrust amount. For example, if the total net income of the trust was $100,000, including $25,000 of capital gains, then capital gains could not be included in DNI if the unitrust amount was less than or equal to $75,000. If the unitrust amount was $100,000 all of the capital gains could be included in DNI.
If there is not an ordering rule and the trustee has no discretion over the decision, capital gains cannot be included in DNI.
Treasury refused to provide examples and maintained that there were too many potential variations in the circumstances and ramifications of exercising the power to adjust under the applicable state laws.
While the regulations do not provide guidance in the context of a power to adjust, some commentators believe that the unitrust examples provide analogies for guidance and suggest that the exercise of a power to adjust will result in the inclusionof capital gains in DNI when: 1) state law ordering rules allow (or are silent regarding) inclusion of such gains in DNI, 2) the trustee determines that inclusion is appropriate and equitable, 3) Form 1041 reflects this tax approach and 4) the tax treatment is followed consistently in subsequent years. If state law precludes an ordering that includes capital gains, and the trust document is silent or it precludes ordering as well, then capital gains cannot be included in DNI.
Some commentators maintain that since the Regulations provide no guidance regarding the inclusion of capital gains in the power to adjust context, the best course is to obtain a private letter ruling.
More often than not these entities show K-1 income reportable by the trust which differs from the amount of cash or other property distributed to the trust.
There are many situations where the cash distribution made from the flow-through entity to the trust as owner of an interest in the entity is less than the taxable income allocated to the fiduciary.
If applicable state law gives the trustee the power to adjust, the trustee may decide to transfer from principal to income an appropriate amount to be reflected as "net income" and thus become distributable.Application to Ownership Interests in Flow-Through Entities
For income tax purposes, no distinction is made between receipts and disbursements that the trustee allocates to principal and income.
All taxable receipts, and all deductible expenses, in both the income and principal accounts, are combined to determine the trust's taxable income for the year.
Distributions to beneficiaries generally will reduce the trust's taxable income. Caveat: Under traditional concepts, capital gains are not included in distributable income for tax purposes.
To the extent tax is paid by the Trustee, it is allocated to the income and principal accounts under Section 505 of the UPIA.
Trust income, taxable income and distributable net income are usually different.Distributions from Flow Through EntitiesTrust Accounting and Tax TreatmentUPIA Section 505
A Trust that receives dividends of $25,000 and pays a trustee commission of $3,000, $1,000 of which is allocated to income under state law has trust accounting income of $24,000 ($25,000 less $1,000) but taxable income of $22,000 ($25,000 - $3,000).
Unless the governing instrument provides otherwise, trust accountings are made on a cash receipt and disbursement basis. A trust's share of a partnerships taxable income may be more or less than the partnership's distribution to the Trust. The accounting income only includes the amount received from partnership income. The trust's share of the partnership's taxable income is irrelevant for trust accounting purposes.
Distributable Net Income (DNI):
Places a ceiling on the income distribution deduction
Determines the amount includable in the beneficiary's income
Determines the character of the distribution to the beneficiary
The distribution deduction, and the amount taxable to the beneficiary, is never larger than DNI.
If the trust's DNI for the year is less than the trust income that is distributed or required to be distributed the portion of the income that exceeds DNI is not taxable to the income beneficiary.
A cash distribution from the partnership is allocated to income under Section 401(b) if the distribution is not a partial liquidation
Section 401 (d) of the UPIA allocates money received in a partial liquidation to principal.
Among other definitions, the UPIA provides that money is received in partial liquidation if the total amount of property and money is received in a distribution or series of related distributions is greater than 20% of the entity's gross assets as shown by the entity's year-end financial statements immediately preceding the initial receipt. UPIA Section 401 (d) (2).
Comments made by various professional organizations including the ABA, the AICPA, and ACTEC suggest that the 20% rule contained in Section 410 (d)(2) be eliminated. The belief is that such section as written allows a change in the character of the return on an investment simply by placing the investment in a single member LLC. For example, a trustee could transfer an investment portfolio into a single member LLC in order to dispose of certain highly appreciated assets followed by a distribution of the proceeds, not in excess of 20% of the entity's gross assets, and change the character of the proceeds from principal to income through the use of the entity.
"Net income" means total receipts allocated to income during an accounting period minus disbursements from income during the period, plus or minus transfers under the UPIA to or from income during the period. UPIA Section 102(8)How is the trust's income tax obligation calculated when the trust owns a partnership interest?
Section 505(c) provides: "A tax required to be paid by a trustee on the trust's share of an entity's taxable income must be paid proportionately"
From income to the extent the receipts from the entity are allocated to income; and
From principal to the extent that (A) receipts from the entity are allocated to principal; and (B) the trust's share of the entity's taxable income exceeds the total receipts described in paragraph (1) and (2)(A)
If the amount distributed from the partnership exceeds the trust's share of partnership taxable income, and if all of the distribution must be paid to the income beneficiary, the trust will not bear any tax.
If the amount distributed from the partnership is less than the trust's share of partnership taxable income, the trust must bear some or all of the amount allocated to the trust's income and perhaps from principal.
The interplay between Sections 505 (c) and (d) produces different tax results depending upon the order in which the provisions of such sections are applied.
The AICPA's comments regarding certain proposed changes to various sections of the UPIA illustrates this dynamic.
As pointed out in the AICPA's comments, it is not clear if Section 505(c) is applied first or if 505(d) is applied first.
James Gamble, co-reporter of the UPIA, apparently believes that Section 505(c) is applied first.
Under Gamble's interpretation, the trust's tax on its share of the entity's taxable income is calculated and then the tax is subtracted from income receipts from the entity. To the extent the trust receives an income distribution deduction for paying cash received from the entity to the beneficiary, the trustee in turn increases its payment to the income beneficiary to the extent of its tax savings under UPIA Section 505(d).
Under the Task Force's interpretation, receipts from the entity would be reduced by the amount for which the trust receives an income distribution deduction. Then, the trustee would apply 505(c) by calculating the trust's tax on taxable income from the entity reduced by the deductible payments to the beneficiary and allocating the tax proportionately between a) the reduced income receipts and b) reduced principal receipts plus the trust's share of the entity's undistributable taxable income.
Under the above interpretation, as pointed out in the AICPA's comments, no taxes would be allocated to the income beneficiary if all income receipts from the entity would be deductible by the trust because income receipts would be zero.
The rule supported by Gamble that requires that the tax be computed first involves a circular calculation. The is because the trust's tax depends on the amount paid to the beneficiary for which the trust receive an income distribution deduction. But the amount paid to the income beneficiary depends on the trust's tax liability attributable to those receipts. The computation can be solved by using an algebraic formula to determine the net amount due to the income beneficiary.
D = Distribution to Income Beneficiary
C = Cash Paid by the Entity to the Trust
R = Tax Rate on Income
K = Entity's K-1 Taxable Income
AICPA's comments provide the following illustrations concerning the above concepts:
"ABC Trust receives an IRS Schedule K-1 from the Partnership reflecting taxable income of $1 million. Partnership distributes $500,000 to the trust. The Partnership represents that the distribution is income and so the trustee initially allocates the entire $500,000 to income. The trust is in the 35 percent tax bracket.
Note: The above formula and solution would become more complicated if the state also had an income tax.
In the above example, the partnership distribution exceeds the trust's $350,000 ( i.e., $1 million x 35% tax rate) tax liability on the IRS Schedule K-1 income by $150,000). The excess is income that the trustee is required to distribute and for which it receives a distribution deduction. But the distribution deduction reduces the trustee's tax, which increases the beneficiary's income and so on.
Taxable Income per K-1 $1,000,000
Payment to Beneficiary 230,769*
Trust Taxable Income $769,231
(35 % Tax = 269,231)
Partnership Distribution $500,000
Tax Allocated to Income (269,231)
Payable to Beneficiary $230,769
D=(C - R* K) / (1 – R) = (500,000) [Cash
Paid by Entity to the Trust] – 350,000
*[Tax on $1,000,000 K-1 Income at 35% Rate / (1-.35) [ 1- tax rate] = 230,769 [Payable to Beneficiary]
When the entity distributes less than a sufficient amount to pay the tax on the trust's share of the entity's taxable income, the trust has to retain the entire distribution to pay the tax. In this situation, the income beneficiary gets nothing.
When the distributions from the entity to the trust are equal to or exceed the K-1 taxable income, the tax treatment is simple and straight forward.
When the entity distributes more than its taxable income, the trust's tax liability attributable to its share of the entity's taxable income is zero. This is because the trustee can pay enough to the income beneficiary to get a full income distribution deduction which reduces the trust's tax to zero.
As shown in the AICPA's comments, the result is much different if Section 505(d) is applied first. The amount payable to the income beneficiary would increase to $500,000.
If Section 505(d) is applied first, the trustee would allocate taxes on the entity's taxable income between income and principal based on receipts, reduced by payments to the beneficiary for which the trustee is entitled to a deduction. Thus, receipts in the allocation formula are first reduced by amounts that the trustee can deduct when paid to the beneficiary. So, the trustee would first reduce income receipts by amounts for which the trust receives an income tax deduction. To the extent this reduce income receipts to zero, no tax would be allocated to income receipts.
Taxable Income per K-1 $1,000,000
Payment to Income Beneficiary 500,000
Trust Taxable Income $500,000
(35 % Tax = $175,000)
Partnership Distribution $500,000
Tax Allocated to Income (0)
Payable to Beneficiary $500,000
The above alternate construct could leave the trustee in the position of not having sufficient cash to pay the tax on the entity's undistributable income.
Another situation which could prove troublesome is where the entity makes a distribution precisely for the amount of federal income tax that is payable on income reflected on Form K-1. Suppose the trust has a mandatory distribution requirement. Unless the fiduciary takes further action, the "tax reimbursement" is distributable to the income beneficiary, depriving trust principal of the ability to discharge the tax liability from funds received in the distribution. Here, the fiduciary could use the power to adjust and allocate the distribution to principal.
IRA's are unique
Income is taxable to the beneficiary when distributed
Upon the account owner's death, the account is a principal asset to the fiduciary
Nature of IRA has caused concern among practitioners in regard to securing marital deduction when funding a marital trust with an IRA
Securing marital deduction is complicated by Code's minimum distribution requirement (RMD)Funding a Marital Trust with an IRAor Defined Contribution Plan*Note: All such plans will be referred to for simplicity as an IRA.
UPIA includes models of how marital deduction could be secured
Section 409 (c)
10 % Rule – If no part of payment from an IRA is characterized as interest, dividend or an equivalent payment, and all or part of the payment is required to be distributed currently, the trustee must allocate 10% of the payment to income and 90% to principal
If no part of the payment is required to be paid currently, the entire payment must be allocated to principal
UPIA recognized that above provisions could jeopardize the marital deduction:
Q-TIP provisions require payment of net income to surviving spouse to secure deduction
Section 409 (c) mandated classifications bear no relationship to IRA's actual income
In an attempt to insure the marital deduction, UPIA requires an additional allocation to income if necessary to secure the marital deduction (Section 409 (d))
Revenue Ruling 2006-26:
Answers question of how adoption of UPIA affects the determination of what is IRA income in marital deduction situations
The Revenue Ruling is of critical importance in obtaining the marital deduction for amounts held in an IRA when the beneficiary is a Q-TIP Trust and the applicable state law is the UPIA with power to adjust and/or power to define income as unitrust amount
Ruling provides three illustrations showing how IRA income should be computed to satisfy marital deduction requirements
The three illustrations address the requirement for income distributions in the context of states which:
have adopted the UPIA's power to adjust and UPIA Sections 409 (c) and (d)
Have a unitrust definition of income, or
Have not adopted the UPIA's power to adjust nor a unitrust definition
Power to Adjust under UPIA section 104 (c), (Caution Reliance on UPIA Sections 409 (c) and (d) will not secure the marital deduction)
Determination on unitrust basis
Determination under traditional state law principles
All three illustrations are based on the same basic facts:
The Q-TIP Trust gives the spouse power to require the trustee to make withdrawals from the IRA in an amount equal to all income and to distribute such income to spouse.
The trustee elects to take distributions over the spouse's life expectancy.
The spouse has the right to require that the IRA be invested in productive assets.
The remaindermen are the account owner's children.
No person other than the spouse and children have a beneficial interest in the trust.
Illustration 1:
Applies where state laws allows adjustments between principal and income and the power to adjust is exercised to administer the trust fairly
State law also has adopted Section 409 (c) 10% rule and 409 (d) savings clause
Trustee determines total return for all trust assets other than the retirement plan and allocates between principal and income in accordance with UPIA Section 104 (a)
Trustee separately determines the total return for the plan assets and allocates in accordance with Section 104 (a)
In other words, the allocation of a payment from the IRA to trust income or principal under UPIA Section 409 (c) is irrelevant to the determination of trust income from non-plan assets and to the determination of trust income from the IRA
In summary, the Trustee determines income from
Non IRA assets
IRA assets
The above two components together constitute the income which must be distributed to the spouse, or in the case of IRA income, subject to the spouse's power to force distribution
It is critical to note that the method of computing income sanctioned by IRS entirely ignores the UPIA rules for allocation of IRA distributions to income and principal
The ruling explicitly states that the 10% allocation rules of Section 409 (c) does not satisfy the Q-TIP rules. The 10% rule:
Does not reflect a reasonable apportionment of the total return between the income and remainder beneficiaries
Does not represent IRA income under applicable state law without regard to a power to adjust
Note that even if Section 409 (d) effectively requires that the entire distribution be allocated to income this still does not insure that the surviving spouse will actually receive all of the IRA's annual income
The RMD in any year is unrelated and is not equal to the IRA's income
So, the annual income requirement of Code Section 2056 is just not met under Sections 409 (c) and (d)
Illustration 2:
Applies where income is defined as a unitrust amount in accordance with state law
The Trust is governed by state law which permits income to be a 4% unitrust amount if:
The governing instrument so provides, or
The interested parties consent
The Trustee determines the 4% unitrust amount independently for the IRA and non-IRA assets
The Trustee of the Q-TIP Trust distributes the unitrust amount from the trust to the surviving spouse each year
Although the Revenue Ruling found this methodology to be reasonable note that the surviving spouse had the right (under the universal fact pattern described above) to demand that the trustee withdraw the IRA's annual income and distribute it to him/her
Applies where the trust is governed by the law of a state that has not adopted the UPIA
As in Illustrations 1 and 2, the trustee determines income separately for the IRA and non-IRA assets
The allocations between income and principal are made using traditional allocation principles
This methodology would also be permissible in a state that has adopted a power to adjust under the UPIA if the trustee decides not to use the power to adjust
As in the two other illustrations, the surviving spouse's power to demand and receive all IRA income annually saved the marital deduction
In the Revenue Ruling, IRS noted that in a state that has adopted the power to adjust and power to define income as a unitrust amount it would be permissible for the trustee to determine income for non-IRA assets using the power to adjust and income for IRA assets as a unitrust amount, or vice versa.
It applies to taxable years beginning on or after May 30, 2006.
So, marital trusts which were properly drafted but not administered in accordance with Revenue Ruling 2006-26 before the effective date will not be adversely effected.
Note that the provisions of the UPIA cannot be exclusively relied on to secure a marital deduction when an IRA is payable to a Q-TIP Trust:
The governing provisions must conform to Code Section 2056, as illustrated in Revenue Ruling 2006-26
Without specific non-UPIA language in the governing instrument, a marital deduction will not be available with respect to the IRA in the three illustrations discussed in Revenue Ruling 2006-26
In the fact pattern of Revenue Ruling 2006-26:
The Q-TIP Trust and the IRA were considered to be separate marital deduction trusts for the purposes of allocating income and principal and determining if each qualified for the marital deduction.
The surviving spouse had the right to mandate that the Q-TIP and IRA assets be made productive.
The surviving spouse had the absolute right annually to require that:
the Q-TIP trustee withdraw all income from the IRA, and
all of the withdrawn income be distributed to him/her
It is this power to withdraw and right of distribution that is essential to the allowance of the marital deduction.
Securing the marital deduction depends on proper drafting. Some of the provisions which should be included is language which:
gives the spouse the power to demand income from both the trust and the IRA
requires the trustee of the Q-TIP trust to withdraw the greater of income and the RMD
overrides UPIA Section 409 (c)
mandates that income of the Q-TIP Trust and IRA is to be computed separately
gives the surviving spouse the power to require the trustee to make the Q-TIP Trust property and IRA productive
In light of Revenue Ruling 2006-26 which rejected the 10% rule of Section 409 (c) in the context of securing the marital deduction when a Q-TIP Trusts holds an IRA or certain other retirement plans, recommendations have been made to revise Section 409 to secure the marital deduction
The recommendations suggest adding provisions to Section 409 to include an "income allocation provision" and "mandatory distribution provision"
The AICPA comments note that IRA accounts generally fall into two categories
Where underlying earnings are ascertainable, such as mutual funds
Where underlying earnings are not ascertainable, such as annuity contracts
Where earnings are ascertainable the trustee should be able to determine the amount of income and allocate so much of the required distribution that represents this amount to income and the balance to principal
Where earnings are not ascertainable, AICPA recommended the adoption of a unitrust approach allowing the trustee to allocate an amount ranging from 3% to 5% of the IRA's fair market value to income and the balance to principal


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PES 2015 now has a release date as publisher Konami has revealed that the game will be released on all platforms on November 13. Mario Goetze, the star of the World Cup 2014 final, will be on the packshot as well.
This is the first time a PES game will be released on the PS4 and Xbox One. They have also announced that a demo will be released on September 17th on the next-gen and current gen consoles.
There are new mechanics to PES 2015 and it's centered around the mantra 'the pitch is ours'.
Here's what you can expect from the game:
The shooting and goal-keeping mechanics benefit from a new system that allows precise aim and control over a shot's power and also unlimited shot styles. Similarly, the ' keepers intuitively close angles and are capable of an amazing number of ways to react to any situation.
Passing and the final ball to the front line has also been expanded, allowing for little knock-ons and powerful daisy-cutter passes that use new physics routines to ensure the ball realistically behaves as it would. Close control also steps up a gear, with the player governing both the positioning of a player, but with greater options of how to dribble into space or beat your marker.
Are you going to buy PES over FIFA this year? Let us know in the comments section below.


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I'm looking at getting a new kitchen and of course every showroom push the granite work tops on me. They are lovely but I thought I had heard they are very hard to keep looking well, I'd be fairly fussy about things so wouldn't want smears everywhere, I had a silver cooker before tha drove me mad cleaning. Is granite very hard to keep shiny, and if someone out a hot pot on it would it mark. The one I have now is a wood one that is impossible to keep. Between sanding and oiling it I just don't want another one that's so high maintenence . Has anyone got granite or something similar that is easy to keep.
Wells granite in Wexford and brilliant and they regularly work in Dublin.
Thanks everyone, colour wise is the best option to go for black with slight specks of colour in it?
I love my granite but it is black and I see every crumb on it. It looks fab when clean and shiny but does streak. Go for an easier colour.
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Ours is 17 years old and perfect. I would recommend
I'm in Dublin 16 but am willing to travel to get it.
My parents countertop is really lovely but they were advised to get one with a spec in it not all black as they can be very difficult as in all streaks are seen type thing. Tbh my mum isnt over the top on it (kept clean but has alot of stuff on it all the time anyway) and i'd never notice so cant say if it is for you but i think the spec helps
I haven't looked at Quartz, must take a look next time. I just know I don't want the laminate one or wood. Anyone know the best place to buy these work tops, prices seem to vary a lot for the granite.
Hi I've a granite top island I only noticed 6 months ago that the granite is only a few cm's thick!! Living here 10 years! It's chipboard underneath. It's perfect I put pots on it do all my food prep on there, kids eat breakfast there. Great job. Don't know about price though as it came with the house. There's not a scratch on it.
Thanks feefeemum, I have never heard of that before, so basically it means it's only a granite on top where it can be seen and different underneath. I wonder does that affect the strength of it. Might be worth looking into that as I get fed up with things after a few years so don't want to pay huge money for it. Where would I get the type you are taking about and is there a certain name for it.
i think it will be granite then. Feline fine you could cover your whole grave with your kitchen counter how's that for recycling. All I need now is to get the money together to pay for it. Really want a island but will work our very pricey with granite. Thanks for all your help.
I have granite and its so hard wearing I might end up using it for my headstone.
We have black granite and its fine. I have put the roasting tin straight onto it every Sunday (ish) for last 8 years and no problems with it. I don't notice smears but I am not the fussiest person when it comes to house keeping!!
Kitchen place told us recently that quartz is less porous therefore less prone to staining eg red wine etc. Also less prone to scratching and chipping. I don't know if that's true but that's what we were told. Quoted same price for both.
Quartz sounds too much hard work, having to dry it off for smears. I wouldn't put a hot pot on it but if we had my sister here she wouldn't think as that's what she does in her own house. I'd hate to spend a lot of money only to regret it.
hi rulkwe have a beige coloured quartz -very easy to keep imo -but im not a perfectionist !!you would need to dry it off with a dry cloth after cleaning to avoid smears .No issue with hot pots or stains etc.I love it .Stem
I have one. It's really easy to keep - just wipe it with a micro fibre cloth. I've never put a hot pan directly on it because your not supposed to, but I've put warm ones on it and hot mugs, tea pot etc and it's been fine.
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Hello my divas and fellow make up lovers, on this post I will be reviewing what I received in this months Adore Box. As I mentioned in my last blog, which you can read here, AdoreBox is not like any other box while you do receive makeup and or skincare products. AdoreBox is different, they also send health and wellness things or jewelry. You will even sometimes receive full sized products and, it ranges from 5-8 things in a box, all of those options for just $15 dollars a month!
So if you're like me and love makeup and subscription boxes then this may be the right one for you!
**** Disclosure I received this box complimentary from AdoreBox, all opinions are my own.
The first product I received and was oh so happy to get was the Benefit Air Patrol BB Cream Eyelid Primer (full size) which retails at about $30! The purpose of this primer is to of course help your eye makeup stay on longer, it's also meant to hydrate , and color correct. While I can't say it color corrected on my skin tone it was hydrating and it does keep my make up on for a long period of time with out any touch ups. And trust me I have some oily lids (ugh)! The best part about this primer is that is comes with 20 SPF which protects your skin from aging and duh the harmful sun rays. You really need sunscreen as a base at least, if you have hot summers like Houston it will become your best friend. I personally added sunscreen into my daily skin routine and have noticed visible changes in my face. But lets save that for another blog!
Here's a picture of me with a look I did using the Benefit Air Control Primer.
The second product I received is also a beauty product, from Covergirl. It's their Plumpify Blast Pro Mascara I can honestly say this is a new favorite. I noticed how full and long my eyelashes looked and the formula does not run or clump! Which is perfect for us oily skin types. It retails for about $13. If you like big brushes that is a plus also. Side note if you have contacts (like my blind behind) the bigger the brush the better. It helps keep the product from getting into your eye.
The third product I got was a sheet mask which is a win because I promise you guys I love for these. This one is called the " Stella Fiesta Coconut Oil Face Mask", now if you love coconuts or coconut oil as muh as I do this is a match made in heaven. This mask is meant to hydrate and that is exactly what it does. I used it right before bed and by morning my face felt refreshed and I only had to add a dime of moisturizer!
The fourth product I had in my box were a pair of Fila Quick Dry Socks which retail at about four dollars a pair. To be honest I was not entirely too excited to have received socks but when I tried them out for a day at work I liked them. This is coming from a girl who hates socks and I only buy the cute cheap ones from Wal-Mart. I'm not impressed by the name on the sock I just need something to protect these feet in my tennis shoes. I actually need more socks and I will 95% be purchasing more of these socks , if I can find them in a store near me.
Last but not least I got a CrC dual ended brow brush, all I can say is yes to that comb on the end. It helps lay these brows down and I have put down my E.L.F brow brush and use this since I've received the box! This brush retails about $6 dollars so it's inexpensive. If you're looking for a good eyebrow brush then look no further.
As you can see based off my reviews this months box was not disappointing! Still not impressed then think about purchasing all of these products separately the total would be around $60 dollars. Girl bye, I'm in college so I'm trying to save as many coins as possible you would be saving over 50% by just signing up for AdoreBox. See girl I'm looking out for you! I would like to encourage you to just try out for a month and see how you like it, click here to try it !
Until next time my loves.


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If your mother loves kittens then she is going to adore this Mother's Day card! The kitten resting next to the beautiful orange flower will certainly make her smile. As her daughter, you want to make sure you send a Mother's Day card that will let her know you feel she is the best mom! So send this kitten on his way to get this message out to your mom on Mother's Day!
Mother's Day is a special time for both the mother and daughter, so this day deserves a very memorable Mother's Day card, and you have just found it! Imagine how sweet your mom will think this little sleeping kitten surrounded by flowers is. This Mother's Day card will make your mother so happy because it will let her know that her guidance and encouragement has made you, her daughter, the person you are today.
For the cat-loving mom in your life, you can't go wrong with this fun Mother's Day card! The picture and the verbiage are each a perfect balance of fun and sincerity. Telling your mom she's the "furry" best will undoubtedly garner a laugh, and she'll love the adorable picture of the kitten on the top of the Mother's Day card.