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Politics & Government
Obama acts on flood of children crossing U.S.-Mexico border; FEMA to coordinate aid
Citing an "urgent humanitarian situation," President Barack Obama on Monday ordered the government to provide special services for a flood of unaccompanied migrant children crossing into the United States from Mexico.
Obama ordered federal departments to coordinate relief for the children, including housing and medical care as well as transportation to reunite them with family members.
Border Patrol stations along the 1,950-mile southwest border and shelters are overflowing with the tens of thousands of unaccompanied children who have crossed into the United States this year.
Experts are at a loss to provide an explanation for the surge, which has seen the number of unaccompanied minors skyrocket from 13,625 in 2012 to 24,668 last year. The numbers are expected to climb as much as fivefold this year.
"They've already hit the 60,000 mark, and they are expecting another 60,000 before the end of the year," said Blaine Bookey, an attorney and associate director of the Center for Gender and Refugee Studies at the University of California Hastings College of the Law.
Most of the minors are from Central America and have made the grueling journey _ on foot, by bus, and atop railway freight cars _ either alone, in groups or in the custody of people smugglers who often abandon them.
Relief efforts will be coordinated by Department of Homeland Security Secretary Jeh Johnson, who said in a statement that he'd named Federal Emergency Management Agency Administrator Craig Fugate to oversee the federal response.
"We will also continue to work closely with the governments of Mexico, Guatemala, Honduras and El Salvador to counter this recent surge in migrant children," Johnson said. "We must, and we will, address this situation."
Johnson said his department's Customs and Border Protection, which oversees the Border Patrol, along with immigration agents, will "provide for the proper care of unaccompanied children when they are temporarily in DHS custody."
Those agencies will work with the departments of State, Defense and Health and Human Services to deal with the short-term aspects of the migrant wave as well as address "the root cause behind these recent migration trends."
Customs and Border Protection Commissioner R. Gil Kerlikowske told reporters Friday that he'd just returned from a trip to observe the problem.
"More shelter space is needed," he said. "And overcrowded Border Patrol stations are something that we're working very hard to address."
The unaccompanied minors face a perilous journey from Central America, through Mexico and into the United States, often encountering gangs or authorities who prey on them, steal from them and physically abuse them.
"These kids are encountering abuse all along the way," said Bookey, the California attorney.
The plight of the children was underscored in March when a 12-year-old Ecuadorean girl, Joselin Nohemi Alvarez, was found dead, apparently having hung herself, in a migrant facility in Ciudad Juarez, across the border from El Paso, Texas. The girl was traveling alone to join her parents in New York City, where more than 1 million Ecuadorans reside.
The reasons for the sudden surge are not entirely clear. Some analysts cite continued rates of high violence in the northern tier of Central America, both social and domestic. Others note that parents of many of the migrant children came to the United States years ago and are now sending for their children. Others say the numbers may be up because unaccompanied minors can obtain asylum or a special immigrant juvenile status that prevents their deportation.
U.S. taxpayers will have to pony up more money to deal with the crisis. The Office of Management and Budget sent a letter last week to Sen. Barbara Mikulski, a Maryland Democrat who heads the Senate Appropriations Committee, asking for more than $2.2 billion to deal with the migrant children, some $1.4 billion more than originally budgeted, the Associated Press reported. Mikulski's office confirmed receipt of the letter.
Rather than face immediate deportation, unaccompanied migrant children are held in shelters while federal officials hunt for relatives or a foster parent who can care for them through immigration court hearings.


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Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final regulations adopt proposed regulations ( REG-104397-18) with certain modifications, including a revised constructed property rule. In addition, the IRS has issued a new set of proposed regulations dealing with issues it is not ready to finalize.
Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final regulations adopt proposed regulations ( REG-104397-18) with certain modifications, including a revised constructed property rule. In addition, the IRS has issued a new set of proposed regulations dealing with issues it is not ready to finalize.
FINAL REGULATIONS: Written Binding Contract Rules
Constructed property. The proposed regulations provided that property manufactured, constructed, or produced for the taxpayer by another person under a written binding contract entered into prior to the manufacture, etc., of the property is acquired pursuant to a written binding contract. Thus, if the contract was entered into before September 28, 2017, the 100 bonus rate did not apply.
That rule was scrapped in response to negative feedback. Instead the final regulations provide that such property is treated as self-constructed property, and the contract is ignored for purposes of determining when the property is deemed acquired. The acquisition date is now the date that the taxpayer begins manufacturing, constructing, or producing the property as determined under rules similar to those that apply to 50 percent bonus property.
Acquisition date. The final regulations provide that the acquisition date of property acquired pursuant to a written binding contract is the later of:
- the date on which the contract is entered into;
- the date on which the contract is enforceable under state law;
- if the contract has one or more cancellation periods, the date on which all cancellation periods end; or
- if the contract has one or more contingency clauses, the date on which all conditions subject to such clauses are satisfied.
Liquidated damage clause. When a contract has multiple damage provisions, the final regulations clarify that only the provision with the highest damages is taken into account in determining whether the contract limits damages.
Qualified Improvement Property
The IRS once again declined to make qualified improvement property placed in service after 2017 eligible for bonus depreciation. A legislative change is required to give this property its intended 15-year recovery period. With a 15-year recovery period, qualified improvement property will qualify for bonus depreciation under the general rule that allows bonus depreciation on property with an MACRS recovery period of 20 years or less.
Used Property
Predecessor defined. Property previously used by the taxpayer or a predecessor of a taxpayer does not qualify for bonus depreciation if the taxpayer or predecessor had a depreciable interest in the property. The final regulations define "predecessor" as:
- a transferor of an asset to a transferee in a transaction to which Code Sec. 381(a) applies;
- a transferor of an asset to a transferee in a transaction in which the transferee's basis in the asset is determined, in whole or in part, by reference to the basis of the asset in the transferor's hands;
- a partnership that is considered as continuing under Code Sec. 708(b)(2);
- the decedent in the case of an asset acquired by an estate; or
- a transferor of an asset to a trust.
Depreciable interest look back rule. The final regulations do not define a "depreciable interest" because this is a facts and circumstances issue. However, a five-year look back period is provided for determining whether a taxpayer or predecessor held a depreciable interest in property.
Substantially renovated property. If a taxpayer places substantially renovated property in service and the taxpayer or a predecessor previously had a depreciable interest in the property before it was substantially renovated, the taxpayer's or predecessor's prior depreciable interest does not prevent the taxpayer from claiming bonus depreciation. Property is substantially renovated if the cost of the used parts is not more than 20 percent of the total cost of the substantially renovated property, whether acquired or self-constructed.
Syndication transactions. A lessor who reacquires property in a syndication transaction is not treated as having a prior depreciable interest in the property.
The final regulations permit a partnership to claim bonus depreciation on the portion of a Code Sec. 743(b) basis increase that is attributable to built-in gain under Code Sec. 704(c), even if the partnership is using the remedial allocation method. An exception is provided for publicly traded partnerships that need to maintain fungibility for publicly traded partnership units.
If a partnership interest is acquired and disposed of during the same tax year, the bonus deduction is not allowed for any Code Sec. 743(b) adjustment arising from the initial acquisition. However, if a partnership interest is purchased and disposed of in a "step-in-the shoes" Code Sec. 168(i)(7) transaction in the same tax year, bonus on the section 743(b) adjustment is allowed. The section 743(b) adjustment is apportioned between the purchaser/transferor and the transferee.
The final regulations also clarify the treatment of qualified property transferred in a Code Sec. 721(a) transaction to a partnership in the same tax year that the qualified property is acquired by the transferor if the partnership has another partner who previously had a depreciable interest in the qualified property. In this situation, the qualified property is deemed placed in service by the transferor during that tax year, and the bonus deduction is allocated entirely to the transferor and not to the partnership. Thus, the contributing partner has contributed property with a zero basis to the partnership, and the contributed property is Code Sec. 704(c) property in the hands of the partnership.
Film, Television, and Theatrical Productions
The final regulations clarify that a used qualified film, television, or live theatrical production does not qualify for bonus depreciation. Also, the basis of a qualified film, television, or live theatrical production is reduced by the deduction claimed under Code Sec. 181 before computing the bonus deduction.
Using ADS
Using the alternative depreciation system (ADS) to determine the adjusted basis of a taxpayer's qualified business investment (under Code Sec. 250(b)(2)(B) or Code Sec. 951A(d)(3)) or the adjusted basis of a taxpayer's tangible assets for allocating business interests expense between excepted and non-excepted trades or businesses (under Code Sec. 163(j)) does not cause a taxpayer's tangible property to be ineligible for bonus depreciation.
Public Utility Property
An example is added to clarify that the 100 percent bonus rate does not apply to self-constructed property of a regulated public utility if construction begins after September 27, 2017, and the property is placed in service in a tax year beginning after 2017.
Effective Date
The final regulations apply to qualified property placed in service during or after the tax year that includes the date of publication in the Federal Register. However, a taxpayer may choose to apply the final regulations in their entirety to qualified property acquired and placed in service after September 27, 2017, provided the taxpayer consistently applies all rules in the final regulations. Additionally, a taxpayer may rely on the proposed regulations issued on August 8, 2018, to qualified property acquired and placed in service after September 27, 2017, in tax years ending before the date of publication of the final regulations.
PROPOSED REGULATIONS: Acquired and Self-Constructed Components
A taxpayer may elect to treat components of a larger self-constructed property that are acquired or self constructed after September 27, 2017, as eligible for the 100 percent bonus rate, even though manufacture, construction, or production of the larger self-constructed began before September 28, 2017. The larger property must be eligible for bonus depreciation at the 50 percent rate.
Businesses With Floor Plan Financing
Property used in a trade or business that has had floor plan financing indebtedness does not qualify for bonus depreciation if the floor plan financing interest related to the indebtedness is taken into account under Code Sec. 163(j)(1)(C) in determining the allowable business interest deduction.
The proposals provide rules for determining whether interest in floor plan financing indebtedness has been taken into account during a tax year. In general, floor plan interest is not considered taken into account for a tax year if the sum of interest business income for the tax year and 30 percent of the adjusted taxable income for the tax year equals or exceeds business interest as defined in Code Sec. 163(j)(5). The proposals clarify that the determination of whether a trade or business that has had floor plan financing indebtedness has taken floor plan financing interest into account is made annually.
Leased Property
The proposals clarify that taxpayers leasing property to a trade or business with floor plan financing indebtedness or a rate-regulated utility may claim bonus depreciation. The taxpayer, however, may not be a trade or business with floor plan financing indebtedness that prevents it from claiming bonus depreciation or a rate-regulated utility.
Used Property
Five-year lookback. A safe harbor provides that a taxpayer who disposes of property within 90 days after placing it in service did not hold a prior depreciable interest in the property. Consequently, the property is eligible for bonus depreciation if subsequently reacquired.
Partnerships. A taxpayer has a prior depreciable interest in a portion of property if the taxpayer was a partner in a partnership at any time the partnership owned the property. The amount of the prior depreciable interest is based on the partner's total share of depreciation deductions with respect to the property.
Series of related transactions. Special rules in the original proposed regulations governing the treatment of a series of related transactions for purposes of the used property acquisition requirements are modified and expanded.
Consolidated groups. Significant clarifications to the rules governing the used property acquisition requirements for consolidated groups are also made.
Written Binding Contract Rules
Property not acquired pursuant to a contract. The acquisition date of property that is not acquired pursuant to a written binding contract is the date on which the taxpayer paid or incurred more than 10 percent of the total cost of the property. The cost of land and preliminary activities are excluded from cost for this purpose.
Purchase of entities. Binding contract rules that apply to the purchase of an entity are proposed. The current binding contract rules only deal with purchases of assets.
A contract to acquire all or substantially all of the assets of a trade or business, or to acquire an entity such as a corporation, a partnership, or a limited liability company, is binding if it is enforceable under state law against the parties to the contract. The presence of a condition outside the parties' control (including, for example, regulatory agency approval) will not prevent the contract from being a binding contract. Further, the fact that insubstantial terms remain to be negotiated by the parties to the contract, or that customary conditions remain to be satisfied, does not prevent the contract from being a binding contract. This proposed rule also applies to a contract for the sale of the stock of a corporation that is treated as an asset sale as a result of a deemed asset acquisition election under Code Sec. 338.
Long Production Property
The proposals provide rules for determining qualifying basis attributable to the manufacture, construction, or production of long production property and certain aircraft eligible for an extended placed in service deadline.
Mid-Quarter Convention
The mid-quarter convention applies to property placed in service during the tax year if 40 percent or more of the basis of the property was placed in service in the last three months of the tax year. The proposals clarify that the basis of property is not reduced by the 100 percent bonus allowance. This rule has always applied to 50 percent bonus property.
Effective Date of Proposals
In general, the proposed regulations apply to qualified property placed in service during or after the tax year that includes the date the proposals are finalized. A taxpayer may rely on the proposals in their entirety to qualified property acquired and placed in service after September 27, 2017.
Proposed regulations would provide guidance on the inclusion of income and deduction items in the calculation of built-in gains and losses under Code Sec. 382(h). The proposed regulations would:
- simplify the application of Code Sec. 382;
- provide more certainty to taxpayers in determining built-in gains and losses for Code Sec. 382(h) purposes; and
- ensure that the application of certain law changes made by the Tax Cuts and Jobs Act ( P.L. 115-97) (TCJA) does not further complicate the application of Code Sec. 382(h).
Taxpayers may rely on these proposed regulations until final regulations are issued. When these proposed regulations are adopted as final regulations, it is expected that Notice 87-79, 1987-2 CB 387, Notice 90-27, 1990-1 CB 336, Notice 2003-65, 2003-2 CB 747, and Notice 2018-30, 2018-21 I.R.B. 610, will be withdrawn and declared obsolete.
Built-in Gains and Losses
Generally, Code Sec. 382 imposes a value-based limitation (section 382 limitation) on the ability of a loss corporation to offset its taxable income in periods subsequent to an ownership change with losses attributable to periods prior to that ownership change.
Code Sec. 382(h) provides rules relating to the determination of a loss corporation's built-in gains and losses as of the date of the ownership change (change date). In general, built-in gains recognized during the five-year period beginning on the change date (recognition period) allow a loss corporation to increase its section 382 limitation. Built-in losses recognized during the recognition period are subject to the loss corporation's section 382 limitation.
Specifically, if a loss corporation has a net unrealized built-in gain (NUBIG), the section 382 limitation for any tax year ending during the recognition period is increased by the recognized built-in gain (RBIG) for the year, with cumulative increases limited to the amount of the NUBIG. If a loss corporation has a net unrealized built-in loss (NUBIL), the use of any recognized built-in loss (RBIL) during the recognition period is subject to the section 382 limitation.
IRS Guidance and TCJA
Notice 2003-65 provides interim guidance on the identification of built-in gains and losses under Code Sec. 382(h). This notice permits taxpayers to rely on safe harbor approaches for applying Code Sec. 382(h) to an ownership change prior to the effective date of temporary or final regulations issued under that provision.
Notice 2003-65 provides (i) a single safe harbor for computing the NUBIG or NUBIL of a loss corporation, based on principles underlying the calculation of net recognized built-in gain under Code Sec. 1374, and (ii) two safe harbors for the computation of a loss corporation's RBIG or RBIL: the 1374 approach and the 338 approach.
The 1374 approach identifies RBIG and RBIL at the time of the disposition of a loss corporation's assets during the recognition period. Generally, this approach relies on accrual method of accounting principles to identify built-in income and deduction items at the time of the ownership change, with certain exceptions.
In contrast, the 338 approach identifies items of RBIG and RBIL generally by comparing the loss corporation's actual items of income, gain, deduction, and loss recognized during the recognition period with those that would have been recognized had an election under Code Sec. 338 (section 338 election) been made with respect to a hypothetical purchase of all of the outstanding stock of the loss corporation on the change date.
Taxpayers may rely on either the 338 approach or the 1374 approach until the IRS issues temporary or final regulations under Code Sec. 382(h). Compared to the 338 approach, the accrual-based 1374 approach is simpler to apply and administer and provides greater certainty for taxpayers.
Prior to the issuance of Notice 2003-65, the IRS had issued Notice 87-79 and Notice 90-27, which provided much more limited guidance regarding the determination of built-in gains and losses. After the TCJA, the IRS issued Notice 2018-30, which makes the 338 approach unavailable when computing items arising from bonus depreciation under Code Sec. 168(k).
The law changes made by the TCJA created additional uncertainty regarding the application of Code Sec. 382 in general, and Notice 2003-65 in particular. Specifically, certain important changes under the TCJA could potentially compromise the mechanics of the 338 approach and further complicate its application.
1374 Approach
For purposes of computing NUBIG and NUBIL, the proposed regulations would adopt as mandatory the NUBIG/NUBIL safe harbor and the 1374 approach described in Notice 2003-65, with certain modifications. These modifications would include technical fixes to calculations involving cancellation of indebtedness (COD) income, deductions for contingent liabilities, and cost recovery deductions. Additionally, the proposed regulations would clarify that carryovers of Code Sec. 163(j) disallowed business interest are counted only once for purposes of Code Sec. 382.
The modifications to the existing NUBIG/NUBIL safe harbor and the 1374 approach would ensure greater consistency between:
- amounts that are included in the NUBIG/NUBIL computation; and
- items that could become RBIG or RBIL during the recognition period.
According to the IRS, the proposed regulations would modestly restrict net operating loss usage by reducing the amount that would qualify as RBIG, reducing the incentive to engage in inefficient, tax-motivated mergers and acquisitions.
NUBIG or NUBIL Computation
The proposed rules for the computation of NUBIG/NUBIL would capture a range of items that closely tracks the NUBIG/NUBIL safe harbor computation in Notice 2003-65. However, the component steps of the proposed NUBIG/NUBIL computation would be more explicit, as follows:
- The proposed NUBIG/NUBIL computation would first take into account the aggregate amount that would be realized in a hypothetical disposition of all of the loss corporation's assets in two steps treated as taking place immediately before the ownership change:
- —Step 1: the loss corporation would be treated as satisfying any inadequately secured nonrecourse liability by surrendering to each creditor the assets securing such debt.
- —Step 2 : the loss corporation would be treated as selling all remaining assets pertinent to the NUBIG/NUBIL computation in a sale to an unrelated third party, with the hypothetical buyer assuming no amount of the seller's liabilities.
- That total hypothetical amount realized by the loss corporation pursuant to Steps 1 and 2, above, would be then decreased by (i) the sum of the loss corporation's deductible liabilities (both fixed and contingent), and (ii) the loss corporation's basis in its assets.
- Finally, the decreased hypothetical total would be then increased or decreased, as applicable, by the following:
- —(i) the net amount of the total RBIG and RBIL income and deduction items that could be recognized during the recognition period (excluding COD income); and
- —(ii) the net amount of positive and negative section 481 adjustments that would be required to be included on the previously-described hypothetical disposal of all of the loss corporation's assets.
The proposed regulations generally would not allow COD income to be included in the calculation of NUBIG/NUBIL, but would provide certain exceptions.
RBIG and RBIL Items
As mentioned above, the proposed regulations would apply a methodology for identifying RBIG or RBIL that closely tracks the accrual based 1374 approach described in Notice 2003-65. However, the proposed regulations would significantly modify the 1374 approach to include as RBIL the amount of any deductible contingent liabilities paid or accrued during the recognition period, to the extent of the estimated value of those liabilities on the change date.
The proposed regulations also would add a rule clarifying that certain items do not constitute RBIG (such as dividends paid during the recognition period). In addition, limitations would be provided on the extent to which excluded COD income is treated as RBIG. Further, the proposed regulations would provide two different RBIG ceilings with regard to COD on recourse debt, and would provide special rules for COD income on nonrecourse debt.
Finally, rules would be provided for the interaction between Code Sec. 163(j) and Code Sec. 382. To eliminate the possibility of duplication of RBIL items, the proposed regulations would provide that Code Sec. 382 disallowed business interest carryforwards would not be treated as RBIL if such amounts were allowable as a deduction during the recognition period. The proposed regulations also would clarify the treatment of certain items allocated from a partnership.
Applicability Date
The regulations are proposed to be effective for ownership changes occurring after the date the proposed regulations are published as final regulations in the Federal Register. However, taxpayers and their related parties may apply these proposed regulations to any ownership change occurring during a tax year with respect to which the period described in Code Sec. 6511(a) has not expired, so long as the taxpayers and all of their related parties consistently apply the rules of these proposed regulations to such ownership change and all subsequent ownership changes that occur before the applicability date of the final regulations.
Comments and Requests for Hearing
Written or electronic comments must be received by November 9, 2019. Written or electronic requests for a public hearing and outlines of topics to be discussed at the public hearing must be received by November 9, 2019. Electronic submissions must be sent via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG-125710-18) by following the online instructions for submitting comments. Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The Treasury and the IRS will publish for public availability any comment received to its public docket, whether submitted electronically or in hard copy.
Hard copy submissions must be sent to: Internal Revenue Service, CC:PA:LPD:PR (REG-125710-18), Room 5203, Post Office Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8:00 a.m. and 4:00 p.m. to CC:PA:LPD:PR (indicate REG-125710-18), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC 20224.
The IRS has issued final regulations that amend the rules relating to hardship distributions from Code Sec. 401(k) plans. The final regulations are substantially similar to the proposed regulations. Further, plans that complied with the proposed regulations satisfy the final regulations as well. The regulations are effective on September 23, 2019.
The IRS has issued final regulations that amend the rules relating to hardship distributions from Code Sec. 401(k) plans. The final regulations are substantially similar to the proposed regulations. Further, plans that complied with the proposed regulations satisfy the final regulations as well. The regulations are effective on September 23, 2019.
The final regulations:
- reflect statutory changes affecting Code Sec. 401(k) plans, including changes made by the Bipartisan Budget Act of 2018 ( P.L. 115-123); and
- affect participants in, beneficiaries of, employers maintaining, and administrators of plans that include cash or deferred arrangements or provide for employee or matching contributions.
Deemed Immediate and Heavy Financial Need
The final regulations modify the safe harbor list of expenses for which distributions are deemed to be made on account of an immediate and heavy financial need. The final regulations:
- add "primary beneficiary under the plan" as an individual for whom qualifying medical, educational, and funeral expenses may be incurred;
- modify the expense listed in existing Reg. §1.401(k)-1(d)(3)(iii)(B)(6) to provide that the limitations in Code Sec. 165(h)(5) do not apply for this purpose; and
- add to the list a new type of expense, relating to expenses incurred as a result of certain disasters.
Distribution Necessary to Satisfy Financial Need
The final regulations modify the rules for determining whether a distribution is necessary to satisfy an immediate and heavy financial need, by:
- eliminating any requirement that an employee be prohibited from making elective contributions and employee contributions after receipt of a hardship distribution; and
- eliminating any requirement to take plan loans prior to obtaining a hardship distribution.
In particular, the final regulations, like the proposed regulations, eliminate the safe harbor in existing Reg. §1.401(k)-1(d)(3)(iv)(E), under which a distribution is deemed necessary to satisfy the financial need only if elective contributions and employee contributions are suspended for at least six months after a hardship distribution is made and, if available, nontaxable plan loans are taken before the hardship distribution is made.
Expanded Sources for Hardship Distributions
The final regulations modify existing Reg. §1.401(k)-1(d)(3) to permit hardship distributions from Code Sec. 401(k) plans of elective contributions, qualified nonelective contributions (QNECs), qualified matching contributions (QMACs), and earnings on these amounts, regardless of when contributed or earned.
Section 403(b) Plans
A hardship distribution of Code Sec. 403(b) elective deferrals is subject to the rules and restrictions set forth in Reg. §1.401(k)-1(d)(3). Accordingly, the preamble to the proposed regulations had stated that the new rules relating to a hardship distribution of elective contributions from a Code Sec. 401(k) plan generally apply to Code Sec. 403(b) plans. Because this requirement is retained in the final regulations, at Reg. §1.401(k)-1(d)(3)(iii)(B), it applies to Code Sec. 403(b) plans.
Applicability Dates
The changes to the hardship distribution rules made by the Bipartisan Budget Act of 2018 are effective for plan years beginning after December 31, 2018.
Plan Amendments
The Treasury Department and IRS expect that plan sponsors will need to amend their plans' hardship distribution provisions to reflect the final regulations, and any such amendment must be effective for distributions beginning no later than January 1, 2020. The deadline for amending a disqualifying provision is set forth in Rev. Proc. 2016-37, I.R.B. 2016-29,136.
For a taxpayer using an accrual method of accounting, the all events test is not met for item of gross income any later than when is included in revenue on an applicable financial statement (AFS) or other financial statement specified by the Treasury Secretary. How the AFS income inclusion rule applies to accrual method taxpayers with an AFS is described and clarified by Proposed Reg. §1.451-3.
For a taxpayer using an accrual method of accounting, the all events test is not met for item of gross income any later than when is included in revenue on an applicable financial statement (AFS) or other financial statement specified by the Treasury Secretary. How the AFS income inclusion rule applies to accrual method taxpayers with an AFS is described and clarified by Proposed Reg. §1.451-3.
Year-by-Year Application
The proposed regulations provide that the AFS income inclusion rule generally applies to accrual method taxpayers with an AFS when the timing of income inclusion for one or more items of income is determined using the all events test. They further clarify that the AFS income inclusion rule applies only to taxpayers that have one or more AFS covering the entire tax year.
The AFS income inclusion rule applies on a year-by-year basis and, therefore, an accrual taxpayer with an AFS in one tax year that does not have an AFS in another tax year must apply the AFS income inclusion rule in the tax year that it has an AFS, and does not apply the rule in the tax year in which it does not have an AFS.
No Change to Income Tax Treatment
The proposed regulations also clarify that AFS income inclusion rule does not change the treatment of a transaction for federal income tax purposes:
- The treatment of a transaction or event in a tax year may be different for federal income tax and AFS purposes.
- The applicability of any exclusion provision, or the treatment of nonrecognition transactions, in the Code, the Income Tax Regulations, or other guidance does not change.
Partial Payment
The proposed regulations provide that an amount included in the transaction price for AFS purposes may not be treated as contingent on the occurrence or nonoccurrence of a future event if the taxpayer has been paid or has an equitable, contractual, or other right to partial payment for performance completed to date. Additionally, that transaction price may not be reduced for amounts subject to Code Sec. 461, including reward amounts in credit card transactions.
Special Methods and Multi-Year Contracts
The proposed regulations clarify that when a taxpayer uses a special method of accounting, the special method of accounting determines the timing of the income inclusion.
Proposed regulations also provide guidance for taxpayers with a financial reporting period that is different than the taxpayer's tax year. The taxpayer must use one of three permissible methods in order to determine whether an item of income has been included in revenue on an AFS.
For a contract with multiple performance obligations, the allocation of the transaction price to each performance obligation equals the amount allocated to each performance obligation for purposes of including the item in revenue in the taxpayer's AFS. The proposed regulations clarify that a transaction price does not include amounts collected on behalf of third parties, or amounts that are contingent on the occurrence or nonoccurrence of a future event.
A taxpayer with a multi-year contract applies the all events test by applying a cumulative approach reflecting amounts previously included under Code Sec. 451 rather than an annualized approach.
Under the proposed regulations if the taxpayer does not treat a fee as discount or as an adjustment to the yield of a debt instrument over the life of the instrument (such as points) in its AFS, and the fee otherwise would be treated as creating or increasing original issue discount (OID) for federal income tax purposes (specified fee), then the rules in the proposed regulations under Code Sec. 451(b) apply before the rules in Code Secs. 1271 through Code Sec. 1275. Removing specified fees and specified credit card fees from the calculation of OID will permit taxpayers to apply only the rules of Code Sec. 451(b) to these fees, without also having to apply the rules relevant to OID.
The proposed section regulations would not apply to determine the time at which OID generally is includible in income.
Effective Date
The regulations are proposed generally to apply to tax years beginning on or after the date the final regulations are published in the Federal Register. However, in the case of a specified fee, Proposed Reg. §1.451-3(i)(2) is proposed to apply for a taxpayer's first tax year beginning one year after the date the Treasury Decision adopting these regulations as final is published in the Federal Register.
A taxpayer may rely on the proposed regulations (other than the proposed regulations relating to specified fees) for tax years beginning after December 31, 2017 (after December 31, 2018, for specified credit card fees), as long as the taxpayer: (1) applies all the applicable rules contained in the proposed regulations for specified credit card fees; and (2) consistently applies the proposed regulations to all items of income during the tax year (other than specified fees).
Proposed regulations provide rules for accrual method taxpayers who receive advance payments. The proposed regulations include provisions affecting both taxpayers both with and without applicable financial statements (AFS), and describe and clarify the statutory requirements of Code Sec. 451(c).
Similar to Rev. Proc. 2004-34
The proposed regulations include many provisions similar to those of Rev. Proc. 2004-34, I.R.B. 2004-22, 991. For example the proposed regulations:
- provide a similar deferral method for non-AFS taxpayers;
- provide a list of items excluded from the definition of advance payment;
- provide rules consistent with Rev. Proc. 2004-34 to ensure the acceleration of an advance payment when a taxpayer dies or ceases to exist, or when a taxpayer's obligation is satisfied or otherwise ends; and
- use the short tax year rules of Rev. Proc. 2004-34 for the AFS and non-AFS deferral methods
The proposed regulations also provide additional definitions and clarifications.
Change in Accounting Method
The IRS intends to provide the procedures by which a taxpayer may change its method of accounting to use one of the deferral methods described in these proposed regulations. Until further guidance is issued, a taxpayer may continue to rely on Rev. Proc. 2004-34, as described in Notice 2018-35, I.R.B. 2018-18, 520.
Effective Date
The proposed regulations are to apply to tax years beginning on or after the date the final regulations are published in the Federal Register. Until the date the Treasury Decision adopting these regulations as final regulations is published in the Federal Register, a taxpayer may rely on these proposed regulations for tax years beginning after December 31, 2017, as long as the taxpayer: (1) applies all the applicable rules contained in these proposed regulations, and (2) consistently applies these proposed regulations to all advance payments.
Taxpayers may use the automatic consent procedures to change accounting methods to comply with the recent proposed regulations described above. Rev. Proc. 2018-31, I.R.B. 2018-22, 637, is modified.
Taxpayers may use the automatic consent procedures to change accounting methods to comply with the recent proposed regulations described above. Rev. Proc. 2018-31, I.R.B. 2018-22, 637, is modified.
The proposed regulations provide rules for:
- inclusion in gross income under the all events test for taxpayers with an applicable financial statement (AFS) ( NPRM REG-104870-18); and
- use of the deferral method for advance payments for taxpayers with or without an AFS ( NPRM REG-104554-18).
Certain qualifying taxpayers may apply for a change to comply with the proposed regulations without filing a Form 3115, Application for Change in Accounting Method.
Taxpayers Affected
The accounting change procedures for inclusion in gross income for taxpayers with an AFS generally apply to taxpayers with an AFS that want to:
- change to a method of accounting that treats an item of gross income as meeting the all events test no later than when the item is taken into account as revenue in its AFS under Code Sec. 451(b)(1)(A);
- in certain cases, allocate the transaction price to performance obligations under Code Sec. 451(b)(4);
- change to a method of accounting that complies with Proposed Reg. §1.451-3; or
- change to a method of accounting that complies with Proposed Reg. §1.451-8(c).
The procedures also apply to taxpayers that do not have an AFS and that want to change to a method of accounting that complies with Proposed Reg. §1.451-8(d).
In addition, the procedures apply to a change in AFS in order to apply certain revenue recognition methods of accounting.
Pending Nonautomatic Applications
The IRS will return any Form 3115 requesting a change in method of accounting available under this revenue procedure that:
- was filed on or before September 9, 2019, under the non-automatic procedures for a tax year beginning after December 31, 2017; and
- is pending with the National Office on September 9, 2019.
The National Office will send a letter to the taxpayer acknowledging the return of the Form 3115, and will return the user fee submitted with the form. A timely resubmitted Form 3115 will be considered filed as of the date the taxpayer originally filed the Form 3115 under the nonautomatic change procedures.
Effective Date
This revenue procedure is generally effective for tax years beginning after December 31, 2017. For specified credit card fees, it is effective for tax years beginning after December 31, 2018.
Amendments to have been proposed to update the information reporting regulations under Code Sec. 6033, which generally apply to organizations exempt from tax under Code Sec. 501(a). The proposed regulations reflect statutory amendments and certain grants of reporting relief announced through guidance that has been made since the current regulations were adopted. The amendments and grants of relief apply particularly with respect to tax-exempt organizations required to file an annual Form 990, Return of Organization Exempt from Income Tax, or a Form 990-EZ information return.
Amendments to have been proposed to update the information reporting regulations under Code Sec. 6033, which generally apply to organizations exempt from tax under Code Sec. 501(a). The proposed regulations reflect statutory amendments and certain grants of reporting relief announced through guidance that has been made since the current regulations were adopted. The amendments and grants of relief apply particularly with respect to tax-exempt organizations required to file an annual Form 990, Return of Organization Exempt from Income Tax, or a Form 990-EZ information return.
Annual Return and Reporting Requirements
Code Sec. 6033 outlines various requirements for an annual information return to be filed by organizations that are exempt from tax under Code Sec. 501(a) or are described in Code Sec. 527, including exceptions to the filing requirement. The reporting requirements under Code Sec. 6033(h) mandate controlling organizations to include on their returns:
- interest, annuities, royalties, or rents received from each controlled entity under Code Sec. 512(b)(13);
- any loans made to each such controlled entity; and
- any transfers of funds between such controlling organization and each such controlled entity.
Penalty Relief
Under Code Sec. 6104(b), the IRS must make the filed annual returns available to the public. Under Rev. Proc. 2018-38, I.R.B. 2018-31, 280, tax-exempt organizations (other than charities exempt under Code Sec. 501(c)(3) and Code Sec. 527 political organizations) were no longer required to report the names and addresses of contributors on Schedule B when filing their information returns. This change applied to information reporting for tax years ending on or after December 31, 2018, for donations above certain applicable thresholds.
However, Rev. Proc. 2018-38 has been overturned by a federal district court ( S.C. Bullock, DC Mont., 2019-2 ustc ¶50,245), which held that the IRS failed to follow the notice and comment procedures required by the Administrative Procedure Act (APA).
Code Sec. 6652(c)(1)(A) imposes penalties for a failure to file a return required under Code Sec. 6033, failure to include any required information, or failure to provide correct information. Under Code Sec. 6652(c)(5), the penalty is not imposed if it is shown that the failure was due to reasonable cause. Notice 2019-47 provides that the IRS will consider there to be a reasonable cause based on reliance on Rev. Proc. 2018-38 for any organizations that file Form 990 or 990-EZ and did not include on their 2018 information return such donor information as Rev. Proc. 2018-38 indicated was not required.
Proposed Amendments
The proposed amendments to the regulations would restore relief from the requirement to report contributor names and addresses on the annual returns filed by certain tax-exempt organizations that was previously provided in Rev. Proc. 2018-38 before the federal district court overturned that rule. Therefore, only organizations exempt under Code Secs. 501(c)(3) and 527 would need to continue reporting their donor information on their Forms 990, 990-EZ, or 990-PF.
In addition, the proposed amendments would incorporate into the regulations the existing exception from having to file an annual return for certain organizations that normally have gross receipts of $50,000 or less, found in Rev. Proc. 2011-15, I.R.B. 2011-3, 322.

subset: commoncrawl


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Brian Wilson tries his hand at campaign management
Brian Wilson can do the math:
Melky Cabrera trails Ryan Braun by about 125,000 votes for the final starting slot in the NL All-Star outfield.
42,000 fans x 3 votes per fan + free WiFi at AT&T Park = A Giants outfielder starting in Kansas City.
Cast your ballot RIGHT HERE by 11:59 PM on Thursday.


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Live HPA Dumbledore's Army Meeting Tonight On Ustream
Aug 19, 2009
Attention Dumbledore's Army! The Harry Potter Alliance is holding another live DA meeting tonight very soon on Ustream at 8:30pm (Eastern). On the agenda: recap of the "What Would Dumbledore Do" campaign, plus exciting news about a new project called "Campaign Nine and Three Quarters." You can listen in here via the Ustream channel, but remember you must register (free) to take part in the chat. As always, be sure to send your questions via Twitter @hpalliance. Plus for those that can stick around, a short "Late Night Snack with Andrew Slack: will follow, starting at 9:45pm (Eastern).


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Associated Press WASHINGTON (AP) They've long been known as devil dogs, leathernecks and "the first to fight." But U.S. Marines, with their self-described expertise in "killing people and breaking things," now want to promote their kinder side as well.
A new Marine Corps advertising campaign starting this weekend takes its cue from research showing today's recruit-age generation is interested in helping people. So the campaign is crafted to show Marines not only as warriors but as humanitarians and peacekeepers; not only as courageous but also as compassionate.
Photos and videos to be distributed on television, in American movie theaters, on YouTube and elsewhere show Marines talking with children; bringing food, water and medical supplies to Haitian earthquake victims, and clearing rubble from a tsunami-devastated Japanese village. These missions aren't a new role for the Marines, but they are ones the force expects to do more of as it's freed from a decade of fighting land wars in Iraq and Afghanistan and returns to its seafaring, expeditionary roots.
Entitled "Toward the Sounds of Chaos," the campaign seeks to explain that in an uncertain world, Marines "need to be ready to engage in whatever activity our country needs us to engage in," Brig. Gen. Joseph L. Osterman, head of the Marine Corps Recruiting Command, said in a recent interview.
"That may go all the way from a combat-type environment, as we've been doing for the last 10 years, to what we did before ... emergent chaotic situations ... catastrophes ... natural disasters or failed-state-type situations where people need help," he said.
The smallest of the service branches, at 202,000, the Marine Corps trains and equips itself with the aim of being light and agile enough to get to any crisis on a moment's notice. They sometimes call themselves "The 911 Force," at the ready to restore order, come to the rescue or evacuate those in danger. A Marine in one of the new advertising videos runs toward an unidentified city under a smoke-filled sky amid sounds of people screaming.
"There are a few who move toward the sounds of chaos ... toward the sounds of tyranny, injustice and despair," a voice says. "Which way would you run?"
The question is a subtle appeal to the generation known as millennials, who said in a survey that they believe in giving back to society, voting in national elections and "helping people in need, wherever they may live," said Marshall Lauck, director of the Marine Corps' advertising account at JWT ad agency.
The JWT ad agency does year-round research and periodic larger efforts with the Corps to keep an eye on what the pool of potential American recruits is thinking. It found in the late 2010 survey of 17- to 24-year-olds that roughly 70 percent believed helping others was essential to being a good citizen today.
Only 31 percent of the same 5,000 surveyed thought serving in the military was important to being a good citizen.
"We have a large number of young people who are very interested in doing good ... yet they don't necessarily realize that the military in general and the Marine Corps in particular is a great way to do that," said Lauck, a former Marine.
The survey included another 5,000 people the military calls "influencers," parents, coaches, teachers and similar role models. Many said they had a very favorable view of the military but did not respond in the same high numbers on whether they would recommend the services to the young people in their lives.
The new campaign will launch during the March Madness college basketball tournament.
"They may not have realized it when they expressed that desire to help people, but the roles and mission of the Marine Corps today and in the near future were really converging very specifically with those youth interests" in the survey, Lauck said. "We saw it immediately ... the convergence."
How many others will see it and embrace the idea is the question.
The Marine Corps has brought in between 30,000 and 40,000 new recruits annually for most of the last 30 years, recruiting command spokesman Maj. John O. Caldwell said. The Corps bulked up to 202,000 Marines largely because of the war in Afghanistan. It's expected to draw back down to 182,100 over the next five years a loss of several thousand more than it had planned in line with federal budget cutting efforts.
Though they'll be drawing down, keeping the Corps supplied with new men and women is a tough business for the 3,100 Marine recruiters. Recruiters make roughly 10,000 contacts through phone calls and canvassing to bring in 104 prospects, Caldwell says. That's winnowed down along the way some change their minds, others fail to make it through basic training or infantry school and ultimately 57 Marines emerge from the process out of the original 10,000 contacts.
All the services use recruiting ads and all do some kinds of humanitarian missions. But the current "Army Strong" campaign, started in 2006, focuses on the development of the individual soldier. The Navy campaign started in 2009 calls the service "A Global Force for Good." Some of the Air Force's "It's Not Science Fiction" ads have a slick Hollywood feel and are used to show off technologies, like remotely piloted aircraft, that are used today but were considered fantasy only years ago. It wasn't immediately clear whether any other services plan changes to their campaign any time soon.
Though spending can fluctuate over the years, the Marine Corps likes to budget about $100 million annually for ads and some other recruiting costs
It cost about $3.2 million to produce the new ads for TV, print and the online effort, Caldwell said.
Of course, many need no prompting to join the Corps, and part of the recruiting dynamic is managing expectations. There are a lot of young men and women out there who want to join specifically for "that adventure and action" that they see in combat operations, Osterman said. "So we want to make sure that they understand that it's still going to be a very busy world in front of us, but more on responding to chaos ... than to a traditional combat role."
The new campaign has plenty for the gung-ho to like. There are familiar warrior scenes of troops on the go, landing on beaches, firing weapons, dropping bombs. Some of the video was borrowed from Marines who shot it themselves in overseas missions, Caldwell said.
The campaign expands on old ones that focused more on the themes of what it takes to become a Marine, the fact that they come from communities across the nation and that they protect at home and abroad. It maintains the motto "Marines. The Few. The Proud."
Lauck said he thinks the new campaign will show people things they may not have realized the Corps has been doing on a daily basis.
Some may interpret it at first as a sign the Corps is going soft, he said. "And we would say to that: `Absolutely not."'
On the Web: The ads www.Facebook.com/MarineCorps
Marine recruiting www.Marines.com


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Use the form on the right to subscribe to Connection , our monthly public roundup of fuel cell and hydrogen energy news
1211 Connecticut Ave NW, Suite 650
Washington, DC, 20008
United States
The Fuel Cell and Hydrogen Energy Association (FCHEA) is the trade association for the fuel cell and hydrogen energy industry, and is dedicated to the commercialization of fuel cells and hydrogen energy technologies. Fuel cells and hydrogen energy technologies deliver clean, reliable power to leading edge corporate, academic and public sector users, and FCHEA members are helping to transform our energy future. FCHEA represents the full global supply chain, including universities, government laboratories and agencies, trade associations, fuel cell materials, components and systems manufacturers, hydrogen producers and fuel distributors, utilities and other end users.


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Broncos players spent the morning working up an appetite, and the afternoon filling their bellies.
The Broncos treated the players who made the regular season roster to afternoon meals at local steakhouses. The defense, offense and specialists went to three different restaurants. It was time for the players and coaches to interact socially away from Dove Valley.
This is the second year of the Labor Day steak tradition under head coach John Fox.
Let's take the specialists out of the equation here: Who do you think threw down hardest at the upscale steakhouse? Picture an offensive group with 10 offensive linemen. Or what about the defense, with those 300-something-pound defensive tackles?


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Our advertising and marketing law attorneys, including a number who have worked at the FTC, are well equipped to assist clients on all aspects of advertising or marketing campaigns: from conception to legal and regulatory review; from preparing the necessary talent, agency, joint marketing, and other agreements to execution and through litigation, if necessary.
Our attorneys handle any client advertising and marketing need, from counsel on regulatory issues and compliance matters to transactional work, such as advertising, agency, and national and global media buying agreements and promotional and direct marketing services, as well as dispute resolution. We advise clients on substantiation, comparative advertising, and direct marketing issues, and on "Slack-fill," "Green," "Free," "Made in the USA," and many other types of claims that are subject to unique regulatory requirements. We also advise on online advertising issues, including affiliate and incentive marketing, and on emerging issues, such as behavioral advertising. Additionally, we handle various entertainment-related agreements relating to large sponsorships and public events, celebrity endorsements, and SAG/AFTRA issues. Our attorneys defend clients before the FTC, state attorneys general, and in arbitration before the National Advertising Division (NAD) of the Council of Better Business Bureaus. Our group includes the recognized authority on California's Unfair Competition Law, Business & Professions Code section 17200, et seq., and the author of an amendment to 17200 known as Proposition 64. We regularly handle matters in federal courts related to false advertising practice under the Lanham Act, as well as lawsuits alleging deceptive or false advertising claims throughout the U.S. state courts, including under the California Consumer Legal Remedies Act, and regulatory defense involving FTC and state investigations and enforcement actions. In addition to years of experience before the NAD of the Council of Better Business Bureaus, we also represent our clients before the National Advertising Review Board (NARB), and the Children's Advertising Review Unit (CARU).
We have special expertise in retail, ecommerce, technology, consumer products, media, entertainment, food and beverage, and financial services industries.
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©1996-2019 Morrison & Foerster LLP. All rights reserved.


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Man Blames Motorcycle Crash on Boogeyman
Hey, these are tough times, so even the boogeyman, long known for his work scaring little kids, has had to take a second job.
A Florida man who crashed his motorcycle and is accused of being drunk at the time told police the boogeyman was responsible for the crash.
Forty-nine-year-old James Scarborough was taken to a hospital with minor injuries last Sunday when someone found him pinned under his bike after he had crashed into some trees.
When authorities arrived at the hospital, they couldn't help but notice his breath smelled like alcohol. Scarborough denied being in an accident that day, but when cops asked him how he wound up stuck under his motorcycle he replied the "boogeyman" did it.
Scarborough also refused to take a field sobriety test and then got hostile towards officers.
Eventually, he wound up arrested on several charges, including DUI, resisting a law enforcement officer, refusal to submit DUI test, operating a motor vehicle without a valid license and operating a motorcycle without a license.
Let's hope the boogeyman doesn't cause any more trouble for him when the case heads to court.


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Listen: Grab a root and growl
The Citizens Band (Press Hear Records, 2012)
Pop music and musicians have long been an integral part of our presidential election circus. The non-partisan "Rock the Vote" campaign has rolled along in the mainstream for two decades now, but Grab a Root and Growl is the most unlikely presidential election year pop music project you could possibly imagine.
The founders of The Citizens Band were inspired by the play Cabaret, set in 1930s Berlin, that married avant garde style and sophistication to heart-on-the-sleeve human rights advocacy. That wasn't an unusual combination during the Great Depression, when intellectuals and artists of every stripe rallied around America's New Deal and Europe's Popular Front.
For the bohemian singers, musicians, models, actors, dancers, and acrobats of The Citizens Band, the time for such all-hands-on-deck unity has come again. The Citizens Band is more of a performance collective than a recording act, but even without the band's wacky visuals, a consistent soundscape emerges on this collection. It's often hard to tell period covers such as Jimmy Dorsey's "This Is Worth Fighting For" and Glenn Miller's "I Swung the Election" from The Citizens Band's originals.
The contemporary numbers tackle issues such as deficits ("The Debt Rattle"), fuel prices ("Gasoline"), and religious intolerance ("I Ain't Afraid . . . of your Yahweh, your Allah, your Jesus"). But the band's deepest and truest contribution to the 2012 political scene comes on anthems to human solidarity such as the rollicking, "You Just Can't Make It by Yourself," which reminds today's "We built that" crowd that "mother, sister, brother, you're bound to need each other."
It's stirring stuff, and if you can fight the good fight in a stylish tutu or a vintage tuxedo, so much the better.
This article appeared on the November 2012 issue of U.S. Catholic (Vol. 77, No. 11, page 42


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Pharmacy director of assessment selected
KINGSVILLE, Texas — Fadi M. Alkhateeb, B.S.Pharm., MBA, Ph.D., director of assessment and associate professor of economic, social and administrative pharmacy at the Texas A&M Health Science Center Irma Lerma Rangel College of Pharmacy, has been selected as a Commission on Accreditation of Health Care Management Education Fellow for 2013-2015.
The accreditation fellowship program is designed for individuals with the potential to make significant contributions to health services administration education.
"During my appointment, I will have opportunities to work with highly regarded practitioners from significant organizations in the pharmaceutical and health care industry and academicians from leading health care education programs who serve as commissioners," Dr. Alkhateeb said.
Fellows participate in commission activities, which offer them the opportunity to learn about the process, achievements and challenges of evaluating professional education. Fellows serve as the secretary for three to four accreditation surveys during the term of their appointment, attend two commission meetings over an approximate two-year period and participate in the fellowship training programs.
Interested in this topic? Contact us for more information.


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Formatting Text Boxes and Shapes in Office 2011 for Mac
Office 2011 for Mac has all kinds of shapes, including text boxes, shapes, SmartArt shapes, and content placeholders in PowerPoint. But that's just the beginning. In addition to using the Font tab offerings, you can apply an incredible amount of interesting text effects.
The moment you click on or into a shape, the Format tab appears to the right of the Home tab on the Ribbon. Click the Format tab to display the formatting options in this tab of the Ribbon.
Selecting shapes and text to format in Office 2011 for Mac
Knowing what's currently selected is very important when formatting text that's inside a shape of some sort. You can format the text inside a shape as well as format the shape containing the text independently.
When the shape itself is selected, the resize handles are shaded with color.
Text within shapes responds nicely to the Font section of the Ribbon, regardless of whether the shape or the text within the shape is selected. Because you can apply formatting options such as reflection and shadow to both the entire containing shape as well as text inside the shape, it's important to pay attention to what you have selected, the shape or the text within a shape, before applying formatting.
Applying shape styles in Office 2011 for Mac
Like the Font group, when you use the Shape Styles tools in the Format tab of the Ribbon, the formatting changes are applied to the shape itself, as well as the text inside the shape. Many of the tools have an option that takes you to the Format Shape, Picture, or Text dialog. On the Ribbon's Shape Styles group, you can find these interface options:
Arrow buttons: Click the round arrow buttons at each end of the Shape Styles group to display more of the available styles.
Submenu: Click at the bottom of the group near the middle to display all the styles on a submenu palette as a drop-down gallery.
More Options: Click to display the Format Shape dialog.
Fill format: Displays the color palette with a Fill Effects option. Choosing Fill Effects displays the Format Shape dialog.
Line format: Formats the line that surrounds a shape.
Clicking the Effects button produces a submenu divided into five categories, each of which has additional submenu palettes with a wide variety of formatting effects. A click on a palette is all it takes to apply an effect. The categories are:
3-D Rotation
Transparency is a measure of how much you can see through something when it is on top of another object or the background. Something that is adjusted to 100% transparent is invisible. When adjusted to 0% transparency, it is completely opaque. The fun comes in when you adjust transparency somewhere in between and pile objects on top of one another.


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Set on a hill farm with wonderful far reaching views across the moor to the mountains beyond with spectacular sunsets. These four very comfortable cottages offer a very peaceful location with an abundance of wildlife around. Woodend Cottage has a cosy living room with period style open fire while Tuath Cala and Curlew Cottage both have a vaulted ceiling in the living room. Excellent walking and cycling from the doorstep with the Estate's forest amenities to explore and the ancient Caledonian Forest of Glen Affric and Plodda Falls only a short drive. Excellent golf only 20 miles to Castle Stuart 'Scottish Open Course' and many other courses to play within 30 minutes drive. The 'Bonnie Black Isle' is a good day out with lovely seaside villages to explore including the village of Cromarty and possible dolphin spotting at Chanory Point. Inverness 13 miles has city attractions riverside theatre boat trips on Loch Ness and Moray Firth with Culloden Battlefield worth visiting. Only 3 miles from Loch Ness with pub serving food shop at Dromnadrochit 7 miles with Loch Ness Exhibition and the haunting beauty of Urquart Castle.
Non Smoking Enclosed Garden Wheelchair Access Short Break
This property sleeps up to 4.
All on ground floor: Living/dining room with vaulted ceiling beams French doors and wooden floor. Kitchen. 2 bedrooms: 1 double (5ft) with en-suite shower room and toilet 1 twin. Bathroom with shower over bath and toilet..


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Business development companies ("BDCs") are special investment vehicles designed to facilitate capital formation for small and middle-market companies. BDCs elect to be subject to certain provisions of the 1940 Act and benefit from favorable tax treatment. Given the dislocations caused by the financial crisis, BDCs are playing an increasingly significant role as providers of capital to small and emerging companies that may not be able to obtain bank financing or do so at attractive levels. Morrison & Foerster's leading securities practice, combined with our knowledge of the 1940 Act, the Advisers Act and the tax considerations applicable to BDCs, make us a regular choice for private equity and other sponsors of BDCs and for the underwriters and advisers to BDCs.
Morrison & Foerster has for decades been known as a leading firm advising issuers and underwriters on initial public offerings. Given our depth of capital markets experience, and our expertise in some of the most active industries for offerings, we are a key partner for issuers transitioning to public ownership. With our tax and investment management colleagues, we assist sponsors, management and boards of directors in structuring and forming their BDCs. We help our clients to anticipate potential accounting and regulatory issues; plan the company's financing strategy several steps beyond the IPO; structure intercompany relationships; adopt the requisite compliance policies and procedures; obtain requisite exemptive relief; and, of course, draft disclosure. Given our roots in Silicon Valley, we are committed to emerging companies, and have championed many of the reforms that made their way into the JOBS Act. Once the JOBS Act was enacted, we promptly launched various dedicated JOBS Act resources.
We regularly represent issuers, underwriters and placement agents in all aspects of equity capital markets transactions, including advising on public (IPO and follow-on) and private offerings, including confidentially marketed public offerings, at-the-market offerings, shelf offerings, private placements of equity securities and PIPE transactions. We also are one of the preeminent firms advising on debt issuances.
We advise clients on a full range of disclosure, governance and regulatory matters relating to the federal securities laws, including the 1940 Act and the Advisers Act. We prepare registration documents, and help our clients in all phases of their operations, including disclosure, compliance, risk management, record-keeping, and oversight by independent directors. We also advise BDCs on best practices regarding compliance policies and procedures. In addition, we provide practical advice on matters relating to capital structure, including compliance with the asset coverage test, the issuance of securities below net asset value, transactions with affiliates, the valuation of securities, social media and related matters.
Our financial transactions group and our bankruptcy and restructuring group also provide support for our BDC clients. Our financial transactions group works with BDCs to negotiate and establish credit facilities. We also have extensive experience structuring and negotiating investments in BDC portfolio companies. This includes first and second lien loans, unitranche and other first out/last out loans, covenant-lite loans, PIK debt, subordinated loans, debtor-in-possession loans, high-yield debt securities, convertible debt, preferred equity and other mezzanine financings. Our bankruptcy and restructuring group advises BDCs and other lenders in connection with distressed investments, including restructurings, out-of-court workouts, foreclosures and bankruptcy proceedings.
Finally, our tax department is an integral part of the Morrison & Foerster team advising BDCs. As such, the tax team focuses on creating the most tax efficient structure depending on the facts and circumstances of any particular BDC or company looking to become a BDC. Our tax department has significant experience with both private and public BDCs. In addition, members of our tax team have decades worth of experience with the taxation of regulated investment companies that are eligible for favorable tax treatment. This experience is of particular significance to public BDCs since they typically elect to be treated as regulated investment companies.
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Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our Privacy Policy, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.
©1996-2019 Morrison & Foerster LLP. All rights reserved.


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Citizen-Soldiers, Airmen Making Difference on Border
By Sgt. Jim Greenhill, USA
Special to American Forces Press Service
ALBUQUERQUE, N.M., Sept. 20, 2006 - The Department of Homeland Security has seen a drop in the number of illegal immigrants crossing the U.S. border with Mexico for the first time, and the National Guard has made the difference, Homeland Security Secretary Michael Chertoff said here Sept. 18.
"For the first time, we are seeing a reduction in the flow of illegal immigrants," Chertoff said during the 128th General Conference of the National Guard Association of the United States. "This is the first real ... sign we've had of success since we began this effort. It could not be done without the National Guard."
The National Guard's support to the U.S. Border Patrol through Operation Jump Start -- "dramatic help," Chertoff called it -- is just one reason Americans hold Guard members in high esteem, he said.
"Perhaps never has the critical role of the National Guard -- at least in my lifetime -- been demonstrated to the people of this country as it has during the past year," the secretary said. "The National Guard is now recognized by the public as a group of heroes, a group that can step up and handle all missions, whether it's something that nature throws at us or something that terrorists throw at us, overseas or here at home, or whether it's just the pressure of economic migration at the southern border."
Calling the Sept. 11, 2001, attacks a turning point in Americans' lifetimes and a reflection of a war that was already under way between a radical ideology of hate and the United States and the West, Chertoff said the Guard immediately stepped up. "I remember what a comfort it was to see the National Guard on duty," he said.
Because the Guard faces so many important missions, it will not stay on the border any longer than necessary, he said. Chertoff also outlined how his department is permanently boosting border security.
"We face a very significant challenge," Chertoff said, "thousands of miles, some of it through some very inhospitable terrain and a problem with respect to managing the border that goes back 20 years."
The DHS fix includes using new technology such as sensors and vehicle barriers, increased manpower, additional tactical infrastructure such as fences, roads and lights and stronger enforcement of the nation's immigration laws.
"We have at long last ended the pernicious policy of catch-and-release," Chertoff said. "That was demoralizing, and it was self-defeating. Now we catch, detain and remove everybody who is here illegally that we catch at the border."
Some 9,000 Border Patrol agents were on duty Sept. 11; more than 12,000 are now; 18,000 are promised by the end of 2008, he said.
"Within a short period of time, we will be announcing (a) new 21st century high-tech program to bring the kinds of tools that we've refined in other areas in national defense to the border," Chertoff said.
Ramping up a permanent improvement in border security takes time, he said. "The National Guard has stepped in to give us the kind of immediate support that we have long expected the Guard to be able to offer."
Guard members are providing surveillance, operating detection systems, working in entry identification teams, analyzing information, assisting with communications, and giving administrative support to the Border Patrol.
"This literally multiplies the eyes and ears that help the Border Patrol agents on the front line deter and respond to illegal entries," Chertoff said. "What this allows us to do is to take the Border Patrol away from these critical but back-office missions and put them on the line where they can actually intercept, apprehend and remove the migrants ... coming across illegally."
Up to 6,000 troops have been helping the Border Patrol since August, a mission expected to continue for about two years. "As we bring the Border Patrol on line, we will be excusing you from duty at the borders of this country," the secretary said.
Meanwhile, the National Guard is working with DHS on a second vital task. "The second is getting our emergency preparedness and response capabilities ready for another catastrophe, whether it be a natural catastrophe or a manmade catastrophe," he said.
Chertoff said local response takes the lead. "State and local governments have the primary lead in a disaster," he said. "That includes the National Guard when called up by the governor."
However, the secretary said, synchronization between all agencies must improve. "Never again do we want to have federal, state and local officials introducing themselves for the first time when the hurricane is hitting," he said.
Several improvements are under way, including:
-- The National Guard Bureau and DHS are synchronizing assessment and communications capabilities;
-- NGB and DHS have completed joint training exercises;
-- NGB and DHS have worked together on evacuation planning;
-- NGB liaison officers are stationed full-time at DHS headquarters in Washington and at the Federal Emergency Management Agency and in Louisiana, where Hurricane Katrina recovery continues;
-- NGB is supporting information collection and reconnaissance; and
-- The Guard has participated in pre-hurricane exercises in five FEMA regions.
Chertoff thanked Guard members for what they do for America. "You blend uniquely," Chertoff said, "and your civilian skills and your military determination and training are wrapped together in a spirit of volunteerism which has characterized this nation from its founding over 200 years ago."
(Army Sgt. Jim Greenhill is assigned to the National Guard Bureau.)
[Web Version: http://www.defenselink.mil/News/NewsArticle.aspx?ID=1052]


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Twitter is such an everyday part of daily life and tech news that it's kind of hard to imagine what it was like way back in its infancy. Fortunately you don't have to; Buzzfeed dug up some ancient nuggets from the "tech elite" for your perusal.
There are plenty more to check out over at Buzzfeed. And who knows what else is hiding back there in the annals of tweet-history. Maybe it's time to do a little of your own amateur archaeology. [Buzzfeed]


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Forms Jobs
Posted: Tuesday, June 3, 2014Department: Fire
Fire Department - June 3, 2014
The Winston-Salem Fire Department will honor the area's World War II veterans by providing a special send-off for their trip to the National D-Day Memorial in Bedford, Va., on the 70th anniversary of the Normandy invasion, and is inviting citizens to join them.
Two ladder trucks will suspend a large U.S. flag between their extended ladders and form an arch for the bus convoy to drive under as they depart for the memorial at 7 a.m. Friday, June 6, from Hanes Mall. The firefighters who staff the trucks will salute the veterans as they pass.
The Fire Department was happy to assist when contacted about participating, said Assistant Fire Chief Harry Brown. "To give back to the World War II veterans who gave so much for this country and this community – it's an honor to have our guys salute them.''
The fire trucks will be staged in the parking lot between the mall and the Carolina Ale House. Off-duty firefighters, family members and citizens are encouraged to come out and show their support.


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ChemTube3D contains interactive 3D animations and structures, with supporting information for some of the most important topics covered during an undergraduate chemistry degree.
Explore the various sections using the menu bar above to find the content of interest to you.
Please send any feedback to Nick Greeves
To download the guides for creating 3D animations, 3D crystallography structures and animated 3D polymers click here


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Each week a nutritionist from the University of Maryland Medical Center provides a guest post to The Baltimore Sun's health blog Picture of Health (baltimoresun.com/pictureofhealth). This week, Christine Dobmeier offers nutrition lifestyle tips.
The second leg of the Triple Crown, the 137th running of the Preakness Stakes, takes place this Saturday. With Memorial Day right around the corner, it's also the "home stretch" as you get yourself healthy for the summer season.
When running the race to good health, look to the "Triple Crown" of nutrition tips: Include more vegetables and fruits, be mindful of portion sizes and become more active.
Vegetables and fruit
It's no secret that vegetables and fruits are good for you, though many people don't achieve the recommended intake. (For a 2,000-calorie diet, one should consume two cups of fruit and 21/2 cups of vegetables per day). Increasing vegetable intake is a great goal for anyone looking to improve their health or lose weight.
Non-starchy vegetables (think mixed greens, tomatoes, cucumber, peppers, asparagus) are low in calories, yet rich in vitamins, minerals and fiber. Starchy vegetables, which include potatoes, corn, yams and peas, are still good for you but are comparable in calories to starches such as rice or pasta.
When trying to lose weight, an excellent goal is to make half your plate non-starchy vegetables. Fiber in vegetables helps keep you full, even though you are eating fewer calories. Try to incorporate vegetables into other foods as well: Mix shredded zucchini into lean ground beef or turkey dishes, or toss grilled peppers, onions and tomatoes with a cup of whole-wheat noodles.
Plan the course
Picking portions wisely is the key. Any healthful food, such as almonds, quickly can become a deterrent to weight loss when the portions aren't on point.
The first rule of thumb in portion control is to read the food label. Pay attention to the portion size as well as the calories. When looking at the bag of almonds, you'll see that 20 almonds provide 160 calories; portion out those 20 almonds and include them as a healthy snack. Many "small" bags of nuts that you might assume are low in calories actually have well over 300 calories. While they are a great source of healthful fats and protein, that may be more calories than you want for a snack. A good way to keep you from eating larger portions of snacks is to portion out a few servings in bags.
Fruit is another nutrition powerhouse, yet even with fruit, portion control is important. Some prepackaged fruit salads can contain up to four cups of fruit; instead, choose a small piece of fruit or up to one cup of berries or melon. Be vigilant on portions of dried fruit because they are denser in calories. A cup of raisins packs in more than 400 calories, while a cup of grapes is around 60 calories.
When planning meals, the culprit often is starches. Starch choices include rice, pasta, corn, potatoes, peas and bread. For meals, try to limit starch portions to about one-quarter of your plate, or no more than one cup. When you are dining out, it is difficult to accurately measure portions; one cup will look to be about the size of a baseball.
A wonderful visual for portion sizes can be found at
Be like a horse: run
Challenge yourself to sign up for a 5K or a half-marathon. Check out
for local events. If running isn't your thing, try to find activities and exercise that you enjoy and can consistently do. Exercise is easier to maintain when it is fun.
As in horse racing, competition can be good. Most of us know a few friends or co-workers we could team up with for a friendly weight-loss challenge or a walking group after work or at lunch.
Biking is an excellent option, whether it is a 20-mile ride or just wheeling around the neighborhood for a few loops each evening. Everything counts.
Do you enjoy dancing? That can be great exercise too. A popular dance-oriented exercise class is Zumba, offered at many local gyms or available on DVD. Make it a goal to include at least 30 minutes of activity most days of the week.
Now you're at the finish line. One last thing to remember when racing to good health: Always stay hydrated. Aim for at least 64 ounces of water a day. By incorporating more vegetables and fruits, being mindful of portions and becoming more active, you'll end up in the winner's circle.


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Nation & World
Injured spelunker rescued from deep cave under Bavarian Alps
Just before noon Thursday, German rescuers brought spelunker and physicist Johann Westhauser into the light, ending an 11 day rescue effort that had millions in this nation holding their breath, and debating the difficulty of keeping him alive as a rescue team moved from bivouac to bivouac deep under the Bavarian Alps.
Westhauser, a researcher, had been injured and trapped more than half a mile underground on June 8 in a recently discovered cave named only "the Giant Thing."
He had descended into the unmapped and relatively unknown cave as part of an effort to fully map the thing, which was first discovered only in 1995. The cave opens into the mountains not far from Adolf Hitler's notorious Eagles Nest, a mountain hideaway. While never fully explored, the cave is thought to be about 12 miles long, though he was not quite half way in when injured.
"Rescued" was the one word headline in the online edition of the newspaper Bild Thursday as the news broke. The news magazine Focus noted the end of "the chronicle of the cave drama."
Across Germany, from the day when the accident became public knowledge, broadcasters would open nightly newscasts by relating the impossibly slow progress of rescue teams, and the dire nature of Westhauser's injuries. The story dribbled out, complete with graphics showing the extent of the cave, and the danger.
Westhauser had been injured during an underground rock slide. The head injury he'd sustained when at least one rock hit him was said to require the intensive care ward of a hospital. The rock strike was intense enough to injure him despite protective gear, including a helmet.
Instead, he had to survive for three days after the injury without medical attention, in the near freezing and lightless rock walls, as a doctor made his way through the cave to him. The doctor was able to stabilize Westhauser, but unable to fully treat him so far from a hospital, or even light.
The cave drama was the only story capable of knocking World Cup soccer news (where the German team is among the favorites to win) from the top spot of newscasts and newspapers. The news here took on an element of an evening soap opera.
By the end, 728 workers from five Alpine countries helped rescue the technician and speleologist at the Karlsruhe Institute for Applied Psychics, a part of Karlsruhe Technology University.
The drama unfolded in stages, or bivouacs. But news stories always mentioned the last as the most difficult, a 180 meter straight fall, or climb. Westhauser, one of the discoverers of the cave and one of its most frequent explorers, had to be placed in a high tech Styrofoam stretcher that was formed around his body in the cave. The cave was too narrow and cramped to allow workers to carry him, so he had to be hauled over the cave floor, and up and down the many drops and climbs.
His head was encased both to protect him from further injury, and shield him from the sound of his encased body being dragged through the rocky and uneven cave floor.
The cave boasts several waterfalls, and a 30 yard long lake, which requires an inflatable raft to cross. And the temperatures in the cave varied between about 33 and 43 degrees, making it cold rescue work.
News reports Thursday noted that he was still alive, though no long term prognosis was available so soon after leaving the cave.


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This month Google, leader in worldwide Internet domination, launched what they hope will become the Facebook – Google Plus.
Of course the Ninjas at Ninja Central were atwitter about this new social media platform. What would it mean for our clients? What would it do for brand management? How will it potentially help search engine optimization (SEO)? And, most importantly, how in the heck do we get an invite? Well, I'm happy to report we scored the coveted Google+ invitations. Why? I guess because Ninjas lead a charmed life. Oh, and we spend a heck of a lot of time on the Internet and Google appreciates that.


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I agree that "it behooves all job seekers to have back-up plans in place."
However, it would be nice to see a discussion thread devoted simply to this topic on this blog. I am in the middle of finishing my PhD at a strong school, but after watching many friends get ravaged on the job market, I have been forced in to thinking about my back-up plans. But it is tough. One natural back-up plan I always had in the back of my mind was law school. But my research suggests that the law market is pretty bad right now too, so I no longer know how good of a back-up that is. Coming out of my PhD program I won't have any debt, but I have read many horror stories of people coming out of law school, even good ones, with over $100k in debt that can't find a job in this market.
In any event, it would be nice to see a thread started where people could offer up thoughts on backup plans for those finishing up their PhDs, so that those of us in this position can get some fresh ideas for how to think about this tough issue.
I'll be honest with you. I don't have any sort of viable backup plan. I feel like I'm too old to start law school, plus I don't want to be a lawyer at all. You could try to tell me to be a law school professor, but you'd just be playing with my emotions at that point. I've got a few other ideas, but nothing that represents a significant improvement over this line of work.
What's your backup plan, Smokers?
--Mr. Zero


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- Model Number: PR-756M
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- Weight Capacity: 375 lb
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- For People Taller Than: 5' 4"
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- Chaise Seat Included: Yes
- Head Rest Cover Included: Yes
- Arm Covers Included: No
- Battery Back Up Included: Yes
- Meets CAL 117 Fire Retardant Code: Yes
- Back Height: 29"
- Overall Height: 44"
- Overall Width: 36.5"
- Seat Height: 19"
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- Back Angle Seat Reclined: 174°
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- Foot Rest Angle Opened: 180°
- Space Needed for Full Recline: 24"
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* Chair specifications may vary plus or minus one inch due to home owners environment, fabric selection, foam and other variables in the manufacturing process.
Product Reviews
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|Mother-in-Law SO happy!
Aug 29, 2010 7:15 AM
|Pickonme from West Bend, Wisconsin would recommend this to a friend.
|A Little About Myself
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|Mom is very happy with the Chair. She is the "talk of the town" now. She is inviting everyone over to see her new addition.
|10 of 10 people found this review helpful


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For over a year Pinarello Lab technicians and engineers, in close collaboration with Team Sky, have worked to improve the time trial bike which swept the 2012 Tour de France. And they have created a real BOLIDE. If it is true that all bike manufacturers start from aerodynamics to create a time-trial bike, only a few go so far as to investigate the impact of the air flow on every single component with the manic approach as it was for us on this project. An extraordinary labor that allows the BOLIDE to reduce by 15% the total aerodynamic impact, compared to the Graal.
The major developments for the aerodynamics are:
the use of new airfoil tube sections, that are designed to ensure the lowest aerodynamic resistance in all wind conditions (frontal, lateral, etc.), as well as, in certain conditions, to generate a forward thrust; The use of a "concave back" on the seat tube, to allow a closer position of the rear wheel, significantly improving the air flow in that area; complete integration of the brakes, which "hides" them from the air flow, greatly reducing aerodynamic resistance internal cable routing that optimizes the interaction between the airfoils and the air flow, in addition to an aesthetic impact, innovative for a racing bike;
integrated handlebar, which gives a unique continuity with the frame and greatly reduce the resistance, compared to a traditional stem and bar; the integration of battery and electronic controllers, completely hidden inside the frame of the BOLIDE;
electronic shifter controls integrated into the handlebar, which further reduces the turbulence in the frontal area of the bike.
Another important improvement is the stiffness of the frame.
This, allows the rider to utilize all the power he generates.
This stiffness is a "trademark" of Pinarello and has been obtained through the structural optimization of the tubes: unlike traditional aerodynamic airfoils, the sections we have developed to optimize the aerodynamics, while maintaining almost constant stiffness compared to the Graal; a tapered headset with 1" 1/8 and 1" 1/4 bearings, which gives a perfect compromise between handling and aerodynamic performances; asymmetric chainstays, Pinarello's DNA, oppose the asymmetric forces created by the power applied to the chain;
the lay-up optimization of the carbon layers, to reinforce specifically the more stressed areas of the frame; the use of our new and unique Torayca 65HM1K, which allows an overall weight reduction of the frame, with unequalled structural characteristics compared to the conventional fibers.
BOLIDE is special also for the myriad of small details that can be seen: the most noticeable are the hidden brakes: completely designed by Pinarello LAB, they disappear under two covers to reduce the incidence of wind that, create uncontrollable turbulence in those areas; a new bottom bracket BB86 to maximize the stiffness in this crucial point of the frame; a new removable front derailleur hanger: for flat races the derailleur can be completely removed, replacing it with a special plate;
Think2: the BOLIDE is fully compatible with both mechanical and electronic groupsets; the position of the water bottle can be lowered towards the bottom bracket to increase aerodynamic performance; the sections of the down tube are optimized to "hide" the bottle from the airflow; horizontal rear dropouts (as normally used on track bikes), in order to adjust and move the wheel closer to the frame; in the bottom bracket there is a special area designed to accommodate the SRM ® sensor.
BOLIDE is obviously a frame approved by the UCI, and it is therefore may be raced in any international competition recognized by the UCI.
BOLIDE has reduced the aerodynamic drag by 15% and the total weight by 5%, from the Graal.
A technological BOLIDE, a concentration of innovation and Italian craftsmanship, a new accomplishment for Pinarello.
"Bolide has been essential in Chrono Tour de France 2013. Fast, powerful, explosive, my secret weapon!"
"Bolide is a true two-wheeled Bolide ... I like it!"
CICLI PINARELLO SRL reserves the right to make improvements and/or modifications to their products without prior notice.