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Integra Lustra 28mm Curtain Poles Inspired by Integra Products. Contemporary Curtain Pole in a Chrome finish with a Quaza finial and stylish Curvatura brackets and Kontour curtain rings. Lustra by Integra boasts stunning finials in contemporary colour finishes. This Metal curtain pole range is the perfect finishing touch for a traditional or contemporary room to create the exact opulence your decor demands.
* Available in 28mm diameter.
* Available in 3 colours Satin Nickel, Chrome and Black Nickel.
* Lengths available up to 4.8m, curtain poles of 3.0m and above are supplied in 2 pieces with a joiner and an extra bracket.
* Curtain poles are supplied complete with all fittings including curvatura brackets, Kontour rings and finials.
* Can be used as an eyelet pole and purchased without rings.
* Extra rings and brackets can be purchased.
* Alternative style rings can replace the Kontour rings if required at no extra cost.
* All rings are lined to ensure a smooth, glide action.
* We recommend using 5 brackets on the 4.8m length.
If you are unsure of colour or finish please request a sample, this will then be added to the basket.
There are currently no reviews of this product.


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Assessment and VALUE
AAC&U develops and advances assessment practices that deepen, integrate, and demonstrate student learning, through advocacy of learning-centered assessment policies, support for campus work to develop meaningful assessment approaches, and experimentation with common e-portfolio frameworks. Through its ground-breaking national initiative, VALUE (Valid Assessment of Learning in Undergraduate Education), AAC&U has worked with faculty and assessment expert teams across the country to develop a set of 16 rubrics through which institutions can evaluate cross-cutting capacities students develop across courses and programs. More than 2000 institutions are currently using VALUE rubrics as part of their assessment plans. AAC&U has also developed the "Personal and Social Responsibility Inventory," a campus climate tool designed to assess various campus constituents' perceptions regarding opportunities for education for personal and social responsibility.

subset: commoncrawl


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Storm threatens status of games in Deep South
ATLANTA (AP) The deep freeze which engulfed the Southeast on Tuesday is threatening the status of college basketball and NBA games scheduled for Wednesday.
The winter storm trapped thousands of motorists on Atlanta's frozen interstates, including Atlanta Braves first baseman Freddie Freeman and Georgia Tech sports information director Dean Buchan.
Buchan told The Associated Press on Wednesday morning he had been stuck on I-285 for 19 1/2 hours and was finally moving slowly in his car.
Freeman tweeted he was stuck for 11 hours before being rescued by former teammate Chipper Jones in his 4-wheeler.
"A moment I'll never forget!," Freeman said on his Twitter account before adding that Jones "hugged me the whole way home!"
The Alabama men's basketball game at Auburn scheduled for Wednesday was postponed to Thursday.


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Easton Stealth RS Hockey Stick Review
The Easton Stealth RS stick is the latest and greatest stick from Easton hockey. Easton has a long history of pushing the envelope on hockey stick performance, and has continued that tradition with the Easton RS stick. The RS stick has evolved from the foundation of the former S17 stick and S19 stick. Moving from the S17 to S19, Easton wanted to improve durability and increase the "pop" on shot release, so they stiffened the elliptical profile and re-engineered the blade. Moving from the S19 to RS, Easton wanted to really fine tune the flex profile and perfect the overall stick feel.
Prior to designing the RS stick, Easton wanted to re-visit what their overall goals were for the new stick. What it really came down to was, "making the most out of your opportunities." In a typical hockey game your team might get around 30 shots, and each player may only get a couple of opportunities to get a good look at the net. As a result, Easton really wanted to make a stick that players can trust that has high-end performance and a predictable feel. When your opportunity comes in the game the RS can help you capitalize on it. When Easton fine-tuned the flex profile, they were able to make it smoother and more consistent, while increasing the "pop" to the shot release.
Easton has also introduced some new materials in the Stealth RS stick that has decreased the overall weight while not sacrificing durability at all. The Easton RS stick features slightly different shaft dimensions than the S19 stick. According to Easton a large majority of their NHL pro players were all using the same shaft dimensions, so they decided to take that as a sign and apply those shaft dimensions to the retail version of the RS stick. The new shaft dimensions have straight sidewalls, and rounded corners. In comparing the RS shaft dimensions to the S19 it is a slight difference but seems like the RS is just a little bit narrower.
The RS stick has an extremely light feel. It may not be the lightest stick on the market but it certainly is in that category. As far as the shot release goes it felt amazing. Has a really snappy feel, and felt like the puck was just jumping off the blade. The RS stick excels most on wrist shots and snap shots, but don't let this shy you away from taking clappers from the point or one-timers in the slot.
The Easton Stealth RS hockey sticks are available at IceWarehouse.com.


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- 123 HP Envy 5540
- Envy 5540 Wireless Setup
- HP Wireless Setup
- 123.hp.com/envy5540
- 123 HP Envy Scan to Computer
- HP Envy Driver Install
- 123.hp.com/setup 5540
- HP Envy 5540 Print Documents
123 HP Envy 5540 Printer :
123 HP Envy 5540 Printer Setup is setting up your printer to start up with the printer. Unbox the printer from the 123 HP Envy box and setup the printer. Fix the printer in an near by space of your computer, that you can access the printer easily.Connect your 123 HP Envy 5540 Printer Setup to the power source and start using the 123 HP Setup. The Printer Prompts to enter the country and the region. In some printer you will have to enter the date and time.After setting all these initializations you can proceed further and get started with your 123 HP Envy 5540 Setup.
Setting up 123 HP Envy Printer:
Some of the common steps to setup your 123 HP Envy 5540 Printer,
- Remove the 123 HP Envy 5540 Printer from the HP box.
- Fix the Printer in a feasible position to get easy access through your computer system.
- Connect the 123 HP Envy 5540 Setup to the Power source.Use the power cord to connect the 123 HP Envy 5540 Printer Setup to the power source.
- After connecting the Printer initialize the basic settings.
- Now you can connect your 123 HP Envy 5540 Printer Setup to the computer.
- Get access of your Printer through your computer.You can print, copy, scan your documents through your computer.
123 HP Envy 5540 Wireless Setup:
123 HP Envy Printer are designed to work even without the USB connection. That is you can now connect your HP Envy Printer to any of your devices using wireless setup. Make sure that your personal computer or your laptop has the wireless option. To get connected to your wireless network all you need is a wireless router, personal device and your HP Envy printer Setup. Using these you can get connected to the wireless network setup. The wireless setup can also established even when your connected to the USB.
How to print with HP wireless direct?
- You can get your documents printed from your computer, smart phone or tablet.
- Use wireless 123 HP wireless direct to connect them.
- To start with the wireless direct, Follow the guidelines,
- At the same time, the necessary software should be available in your device.
- Switch ON your 123 HP Wireless Direct.
- 123 HP wireless direct connection supports up to five devices.
- You can use your 123 HP wireless direct even when your computer is using an USB connection.
- You can also convert your USB connection to the wireless connection.
123 HP Envy 5540 PRINT:
The print settings in this HP Envy printer is handled automatically using the printer software applications. To change the settings in the printer you can do it manually using the printer control panel 123.hp.com/setup 5540.
How to Print Documents:
- Load papers to your printer.
- From the software select the print option.
- Make sure your printer is selected.
- Select the properties dialog box.
- Tap the orientation of the paper using appropriate options.
- Select the tray dispenser and paper type from the media drop-down box.
- Click ok in the properties dialog box.
- Click print or OK option to get your document printed.
123 HP Envy 5540 Copy documents:
The copy menu is used to copy the documents along with the number of copies. To print using the 123 HP Envy 5540 Printer Software driver you should install the driver to your computer. You can also perform all other functions using printer driver.
To print a one-sided copy:
- Load the original copy in the scanner printer glass.
- Mention the number of copies that you want to print,
- From your home screen select the copy option.
- Select the number of copies.
- If the 2-sided option is selected then touch the option again to deselect it.
- Select the mode of printing 123.hp.com/setup 5540 that is black or color and select print option.
Envy 5540 Scan to Computer:
With your 123 HP Printer you can start printing using your computer or you can start printing even form your control panel. Scan from the control panel if you wish to get an quick access or in case if your scanning an one passage or one image file.
How to scan from HP Envy 5540?
Steps to scan your document,
- In case if you are scanning your document from the 123 HP Printer control panel.
- Open the scanner lid.
- Place the document that you wanted to print on the right corner of the scanner glass.
- Close the scanner lid.
- Press the scan button on your printer control panel.
- Select the number of copies and select the start button.
- Select the Start scan option.
Envy Ink cartridge Installation
123 HP Envy printer's important tool for printing documents is the ink cartridge. The ink cartridge installation is the initial process in the printer setup. To get started with your HP Envy printer setup first you will need to install the HP ink cartridges.HP also provides you instant ink services on which you can consume upto 50% of ink. You can also get intimated when your loosing out of ink. While you install your ink cartridge your Printer gets sync to the HP ink store and hence when your Envy printer runs out of ink your dealer automatically gets intimated.
Installing ink cartridge to 123 HP Envy Setup:
- To install the ink cartridge to your 123 HP Envy Printer,
- Remove the ink cartridge from the package.
- Open the HP Envy cartridge access door.
- Wait until the cartridge carriage positions itself to the middle of the Printer.
- Now remove the cartridge from its packing and remove the strip from the printing slit.
- Place the cartridge in the carriage and push it until it snaps the corner of the carriage.
123 HP Envy 5540 Driver Install:
With your 123 HP Envy you can now perform your printer actions by installing your HP Driver software. To install your Printer driver you can now download the HP Printer Driver from 123.hp.com/setup.The HP Printer Driver can be installed to your personal device and you can start working on your printer. To get more details about your HP Envy Printer on your Printer Driver Setup you can visit 123.hp.com/envy. After installing your Driver to your device make sure that your device is connected to the internet.
Installing 123 HP Printer Driver:
- To install your HP Printer Driver to your personal device,
- Look out for the HP Printer Driver CD on your HP box.
- Now insert the Driver CD to your computer Driver and run the setup file.
- Now install your driver Setup to your computer.
- After installing you can have direct access of your 123 HP Envy Printer from your personal device.
123 HP Envy 5540 FAX:
Fax to PC and Fax to Mac requirements:
- The administrator computer, the computer that activated the Fax to PC or Fax to Mac feature, must be on at all times.
- Only one computer can act as the Fax to PC or Fax to Mac administrator computer.
- The destination folder's computer or server, must be on at all times.
- The destination computer must also be awake, Hence faxes will not be saved if the computer is asleep or in hibernate mode.
- HP Digital Imaging monitor in Windows Taskbar must be on at all times.
- Yet, Paper must be loaded in the input tray.
Activate Fax to PC:
- Use the Fax to PC Setup Wizard to activate Fax to PC.
- The Fax to PC Setup Wizard can be started from the Solution Center.
- Because the Fax to PC Setup Wizard is on the control panel.Most of all To set up Fax to Mac on Mac OS X, use the HP Setup Assistant which can be launched from the Utility.


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Suppose one morning two crows land on the wire, each at a random spot (the probability is uniformly distributed). With a bucket of paint and a brush you mark the stretch of wire between them. A certain length of wire will have been painted.
On average, what length of wire would you expect to have painted? Assume that each bird is a single point along the line, and so has no width.
Suppose instead that a dozen crows landed on the wire, each at an independent, random location, and you painted the stretch of wire between each bird and its nearest neighbor. On average, what total length of wire would you expect to have painted now?
And if a thousand crows landed?
A computer-generated solution could be found, but bonus points will be awarded for a formal proof!


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Jamaica NY's Best Choice For Cremation Memorials
Custom Cremation Memorials For Your Loved Ones By Supreme Memorials.
Since 1951 Supreme Memorials has been helping families preserve the memories of their loved ones with cremation memorials that are beautiful and one-of-a-kind. Throughout the years we have preserved the same values and skills that our founders based the company on. Between our locations throughout Brooklyn and Staten Island we're proud to be one of the largest gravestone, mausoleum and columbaria provider throughout New York!
Mausoleums For Your Loved Ones in Jamaica
If you do not have a cemetery plot, arrangements can be made to assist you in picking the right cemetery plot. We will go to the cemetery with you and your family to help you determine what type and location are right for your mausoleum. We also offer sarcophaguses and columbaria.
Custom Options For Your Mausoleum
There are many options available to help make your mausoleum custom. A custom mausoleum, when planned right, will reflect your own personal visualization. The options include bronze doors, stained glass windows, alters, entranceways, lobbies, sitting areas, and landscaping.
Your private entrance to your family eternal estate can be enhanced by different mausoleum door options, granite benches, planters, steps, vases, sculptures, and art. We can even add marble sculptures and marble artworks if the cemetery allows. We can inform you if these options are available to you depending on the cemetery restrictions of the plot where your family mausoleum will be placed. Stained glass windows for the entranceway of your mausoleum can also be created.
Bronze mausoleum doors are the standard today, and there are many options you can choose from. We offer a full selection of mausoleum doors and can assist you in choosing the right one for your private estate.
Stained Glass
With every walk-in mausoleum you purchase from Supreme Memorials, Inc., you can select one of the many stained glass windows we offer. Supreme Memorials, Inc. also helps protect the windows of your family mausoleum from chipping cracking with a protective cover. Stained glass windows for your family mausoleum are installed by our professional staff at the time of construction. All of the windows we install come with a guarantee that they will not leak. If you would like to have a custom-made stained glass window for your eternal home, we will help you design it.
Columbariums & Cremation Memorials Jamaica
Columbaria are growing in popularity as a unique and stunning option for memorialization. Consisting of any number of bronze vaults that contain cremated remains, columbaria can be anything from small monuments to elaborate structures.
Interior Columbaria
We often get requests to build custom columbaria inside of existing mausoleums and other structures, such as churches and chapels. At Supreme Memorials, Inc., we will work with you to create a design that fits seamlessly within any existing structure and work carefully and diligently as to not disrupt the surroundings in any way.
Exterior & Freestanding Columbaria
Freestanding columbaria can be designed as single or double-sided structures, curved walls, or as complete walk-in structures. No matter what design you're looking for, Supreme Memorials, Inc. has the expertise and skill needed to build any freestanding columbarium from the ground up. From drafting the initial design and constructing the foundation to carving the last finishing touches, our team can handle any size of project from start to finish.
Unlike the many providers of stock columbaria, the artists at Supreme Memorials, Inc. specialize in creating custom designs that can include engravings, statues, faceplates, and any number of unique features. We also assist in choosing the ideal site for your columbarium and design a layout that perfectly integrates with the existing landscape and surroundings.


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Campaign has ended
85.00 € *
* Original price 85.00€ - 45% offCampaign ends November 29, 2018
Sweater Pepita Alice in black and white pepita print.
Material: VI + EA
Care instructions: washing machine
Product is made in Estonia.
Regular fit.
Tallinn Dolls is a playful designer brand. Our magic recipe is: A little bit of courage 100g of elegance Killer amount of style Pinch of spice Clothes with character!
Fashion trade shows-selling


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And because it comes at the end of the year,
my birthday was sometimes forgotten and faded into a fog.
So I'm extremely delighted that I'm surrounded by my family and
close friends this year, celebrated with beautiful cuisine and
endless laughter. Nothing is more happier for me to be with
my loved ones.
Last but not least, thank you so much for reading my blog.
I'm so grateful for your support, your hearty comments always
encourage me to step forward.
With love,
jacket: vintage Chanel
knit top: Minusey(here)
pants: H&M(old)
earrings: Vivienne Westwood
bangle: asos(here)
clutch: Elisabetta Franchi
boots: Chiristian Louboutin


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On Wednesday, July 25, batters, fans and a plethora of volunteers came out to the Peoples Natural Gas Field, home of the Altoona Curve, to participate in the second-to-last home run derby of the season. Take a Swing Against Breast Cancer® at the Altoona Curve started out with a group of "little sluggers" stepping up to the plate to take their turn at the batting cage. This group, comprised of 3 batters under the age of 15, knocked off the socks of spectators as they made some incredible hits to the outfield and truly held their ground. Look out for this group in the years to come at Altoona!
Thanks to all of our teams, and the groups of volunteers who stayed with us throughout the day to shag balls in the outfield as the sun beat down on them…that's dedication! We had groups from AT&T, Best Buy, YTI Career Institute and the Altoona Curve Junior. We couldn't have been there without you, thanks for your support!
Check out the list of teams below, and our solo home run hitter!
- Community State Bank of Orbisonia – 1,580 points (Altoona Winners!)
- Central PA Community Foundation – 1,170 points
- PSU Altoona Grounds Crew – 785 points
- The Sky's the Limit – 780 points
Home Run Hitters:
- Scott Knepper from Community State Bank of Orbisonia—1
Thanks to everyone who came out, including the staff of the Altoona Curve for their help and enthusiasm at our event. View all of the photos from the Altoona Derby at Peoples Natural Gas Field here.Tags: #PBCCderby, Altoona, Altoona Curve, Awareness, baseball, bat, breast cancer, event, free, home run, survivors, swing, Volunteer


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We believe in the idea that you can come to work, and help make the world a better place in the same day. Nature's Path is a family-run, independent, privately owned company. The company was founded with strong entrepreneurial spirit and that spirit is a part of everything that we do. Our goal is to be a trusted name for quality organic foods in every home; because we believe that everyone should have access to delicious food that is both good for people and the planet.
What are we looking for?
Our team members are passionate about our mission and vision. Additionally, we have five core competencies that form the basis of our recruitment, training and performance management philosophy. We strive to build a culture that is:
- Performance Driven
- Always Improving
- Team Focused
- Honourable & Respectful
- Sustainably & Socially Conscious
Why would Nature's Path be a good fit?
Our recruitment philosophy is that as much as we're looking for the right people to join our team, we recognize that you are also looking for the right company for you. We offer a number of benefits that support our company culture:
- Benefits programs including medical, dental and vision coverage (most costs covered by Nature's Path)
- RRSP (Canada) and 401(k) (US) with matching programs after one year of employment
- Employee Assistance Programs
- Wellness programs at each location including a Get Fit program where we reimburse team members for fitness and health activities
- Subsidies for greener modes of transportation
- Onsite organic food gardens for staff to use
- Awards and gift certificates to recognize length of service
- Training programs including internal training (eg. Sustainability, Performance Management, LEAN) and reimbursement for approved external training.
All of those are important benefits, and the most exciting part of working at Nature's Path is the ability to work with an amazing team of people who are contributing to something really important. Bringing healthy, organic food to the world in a way that supports our communities and our environment is a powerful thing, and we love what we do!


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From Cursed to Blessed
God often waits to intervene and rescue us when things seem to be their darkest, so we should never despair that our circumstances are too far gone for Him to respond. Still, there are times when the Lord does not ...Read More
Always Reforming
Consistent preaching of the gospel both to ourselves and to the world around us is necessary if reformation is to endure. We need to be reminded of the gravity of our sin and the greatness of our Savior in order ...Read More


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Snyder & Sarno LLC is now Snyder Sarno D'Aniello Maceri & da Costa LLC
Meet the Experienced Attorneys of Snyder Sarno D'Aniello Maceri & da Costa LLC
New Jersey Family, Divorce, Medical Malpractice and Personal Injury Law Firm
About Snyder Sarno D'Aniello Maceri & da Costa LLC
The law firm of Snyder Sarno D'Aniello Maceri & da Costa LLC was formed in 2009. Combining the skills of our proven attorneys has allowed us to provide strong, personalized representation in many legal matters, including family law, medical malpractice, and personal injury. With each case, clients receive strong legal counsel from an experienced attorney at any of our three offices located in Essex, Somerset and Bergen Counties. Our attorneys understand how difficult this time can be for you and your family, so with each case, we will ensure that you receive counsel that is cognizant of your needs, while maintaining the strong, aggressive representation needed to win your case.
Our Attorneys
The extensive knowledge and experience of our attorneys have allowed us to deliver extraordinary counsel by providing a strong, well-respected attorneys of legal counsel. A primary focus of our law firm is to provide each client, no matter the size of their case, direct access to our attorneys. We are committed to offering honest guidance, helping our clients through every step in their case, while respecting and honoring their decisions. A combination of compassion, empathy, and aggressive representation when necessary is what helps separate our firm from others. We are dedicated to putting the needs of our clients first.
What Sets Us Apart
The complexity of family law issues, personal injury, and medical malpractice suits can be a long and taxing time for everyone involved. To help relieve some of the stress, our firm is made up of attorneys with vast knowledge in handling a wide range of family law issues, such as divorce, domestic violence, child custody, alimony, and more. Additionally, our attorneys have been specifically built to represent clients in various personal injury and medical malpractice cases, including birth injuries, surgical errors, motor vehicle accidents, product liability, and others. We have attorneys who speak Spanish and Portuguese, so if you or a family member is more comfortable speaking in one of these languages, please let us know.
View More Family Law Testimonials
"Angelo represented me in a complicated and adversarial divorce matter. His expertise is top notch. His court manner is commanding, persuasive, and effective. He knows the law and the judicial system backwards and forwards. I highly recommend Angelo for your family law matter."
Medical Malpractice and Personal Injury Testimonials
Medical Malpractice and Personal Injury
Verdict & Settlements
Areas of Practice
Family Law
- Divorce
- Mediation & Arbitration
- Prenuptial, Postnuptial and Reconciliation Agreements
- How to Prepare for a Divorce
- Domestic Violence and Marital Torts
- Child Custody and Relocation
- Alimony
- Palimony
- Child Support
- Domestic Partnerships
- Equitable Distribution
- Property Division
Medical Malpractice
- Birth Injuries
- Surgical Error
- Misdiagnosis/Failure to Diagnose
- Wrongful Birth
- Anesthesia Malpractice
- Hospital Malpractice
- Failure to Diagnose Stroke
- Lack of Informed Consent
- Cerebral Palsy
- Shoulder Dystocia
- Veteran Affairs
- Post-Operative Negligence
- Prescription Errors
Personal Injury
Professional Affiliations
Blog Articles
Family Law Forms
- Case Information Statement
- CIS Corporate Benefits/ Fringe Benefits of Employment Statement
- CIS Commissions, Bonuses Not Included Statement
- CIS Prior Pending Family Actions Involving Support, Custody or Domestic Violence Statement
- Confidential Litigant Information Sheet
- Certificate of Insurance Sheet
Medical Malpractice Forms
- 5 50a Duty And Negligence
- 5 50b Common Knowledge May Furnish Standard Of Care
- 5 50c Informed Consent (competent Adult And No Emergency)
- 5 50e Pre-existing Condition - Increased Riskloss Of Chance - Proximate Cause
- 5 50f Wrongful Birth And Life (updated)
- 5 50h Alteration Of Medical Records1
- 5 50i Fraudulent Concealment Of Medical Records1
- 8 30b Damages — Per Quod Loss Of Spouse's Services, Society And Consortium
- 8 30c Damages — Per Quod Loss Of Child's Services And Earnings
- 8 42 Survival Action
- 8 43 Wrongful Death
- Appendix Ii. — Interrogatory FormS
"I was involved in a VERY complicated and tumultuous child custody, divorce, domestic violence case for two full years. I was fortunate enough to be represented by one of the top matrimonial teams in the state of NJ, and the outcome in my case exceeded my every expectation." - Former Client"Paul personally stood by my side and represented me throughout my injury case. Whether it was business at hand, advice, or a late night phone call to help me understand what was going on; he never took a step back towards helping me. I knew that I could call on him at any time . My case was very successful and I attribute that to Paul's dedication . He even came to me during a snow storm when I could not make it to his office. I certainly would recommend him to anyone." - Former Client


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Japanese 102 class: Taiyaki-making event. (Taiyaki is a Japanese fish-shaped griddle cake)
April 22, 2016 (7th Street Studio)
Japanese 102 class: Taiyaki-making event. (Taiyaki is a Japanese fish-shaped griddle cake)
April 22, 2016 (7th Street Studio)
Our students learned the art of Japanese calligraphy and how to make Taiyaki, a fish-shaped griddle cake.
First-year Japanese language students engaged in traditional brush calligraphy. (February 2016)
We recently made decorations to celebrate the "Year of the Monkey." Being together with family and watching the new year gala are traditional new year activities.
Chinese post the fu characters ("good fortune" and "luck") and new year decorations on walls, doors and windows in hopes to have great fortune and good luck in the coming new year.
In fall of 2015, Prof. Elizabeth Armstrong held a workshop/tutorial on the basics of Japanese cuisine. Students from all disciplines gathered at the 7th St. Studio to learn how to prepare, cook and present an elegant and simple meal.
Dumpling making has been an essential event in the history of the Chinese Culture and Student Association.
We are able to reach out to many groups of students and teach them how to make dumplings as well as the history of dumpling making.
EAST 120 ("Intro to Chinese Culture") students learned and practiced the "regular script" of calligraphy, showcasing particular features of Chinese philosophy and religion, such as Dao and "Good will be rewarded with good," and universal values of human experience, such as love, "Practice what you preach," and "Actions speak louder than words."
The following links are virtual breadcrumbs marking the 27 most recent pages you have visited in Bucknell.edu. If you want to remember a specific page forever click the pin in the top right corner and we will be sure not to replace it. Close this message.


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I've been looking for an effective Haskell elevator pitch for some years now, but the only thing I was able to come up with was just that you can deliver software better, faster and cheaper because you need fewer lines of code. This just sounds like hype.
However I think I've now got something better. Here it is:
Conventional languages make the programmer construct both a control flow and a data flow for the program. There is no way to check they are consistent, and anytime they are inconsistent you get a bug. In Haskell the programmer just specifies the data flow: the control flow is up to the compiler. That simplifies the program, cutting down the work and completely preventing a big class of errors.


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The IRS has issued the luxury car depreciation limits for business vehicles placed in service in 2019, and the lease inclusion amounts for business vehicles first leased in 2019.Luxury Passenger Car D...
The IRS has released the 2020 inflation-adjusted amounts for health savings accounts (HSAs) under Code Sec. 223. For calendar year 2020, the annual limitation on deductions under Code Sec. 2...
The IRS on May 31 unveiled a new preliminary draft of the 2020 Form W-4, Employee's Withholding Allowance Certificate. Although an earlier version of the Form W-4 had been released last June, Tr...
The IRS will be ceasing its tax transcript faxing service, and will also amend the Form 4506, Request for Copy or Transcript of Tax Form, series to end third-party mailing of tax returns and transcrip...
The new actuarial tables are delayed, the IRS told Wolters Kluwer on May 30. "We are currently working on new actuarial tables, but we cannot predict when they will be published."Generally, the I...
The IRS posted updated instructions for 2018 Schedule D (Form 1040), Capital Gains and Losses, that include a corrected worksheet. The revised worksheet corrects a rate error that may have calculated ...
The IRS has finalized regulations that increase both the enrollment and renewal user fee for enrolled agents from $30 to $67. The rules also increase the renewal user fee for enrolled retirement plan ...
A married couple had unreported taxable income in the form of distributions received from casino revenue. However, the IRS did not obtain written supervisory approval before the first formal communica...
The IRS was allowed to assert its authority under the abuse of entity rule of Reg. §1.701-2(e) to treat a partnership as an aggregate of its partners. Treating the partnership as an agg...
The IRS has published the reference price under Code Sec. 45K(d)(2)(C). The credit period for the nonconventional source production credit under Code Sec. 45K ended on December 31, 2013...
The Treasury Department and the IRS have requested general comments on issues arising from the Bipartisan Budget Act of 2018 (BBA) ( P.L. 115-123) amendments to the Code Sec. 45Q credit...
The IRS has provided four examples of the interaction of the new limit on the deduction on state and local taxes (SALT) under Code Sec. 164(b)(6) with the tax benefit rule for refunds under&...
The tax credit for new qualified plug-in electric drive motor vehicles sold by General Motors, LLC, will begin to phase out April 1, 2019. The credit begins to phase out in the second calendar quarter...
The IRS has provided the adjustments to the limitation on foreign housing expenses for specific locations for tax year 2019. Generally, a qualified individual whose entire tax year is within the appli...
The IRS has provided a waiver for any individual who, for the 2018 tax year, failed to meet the eligibility requirements of Code Sec. 911(d)(1) due to war, civil unrest, or similar adverse c...
As part of its ongoing security review, the IRS is revising the application process for obtaining an employer identification number (EIN). Starting May 13, 2019, only individuals with social security ...
The IRS has published the nonconventional source fuel reference price for calendar year 2018. The credit period for the nonconventional source production credit under Code Sec. 45K ended on ...
Recently enacted California legislation makes a number of changes to corporate and personal income tax law, including:conforming to a number of federal Tax Cuts and Jobs Act (Public Law 115-97) (TCJA)...
Connecticut enacted personal income tax legislation that:extends the sunset date for the angel investor credit, increases the credit cap, and raises the amount reserved for certain businesses;maintain...
For Massachusetts corporate excise tax purposes, the Appellate Tax Board (board) properly rejected a corporation's (taxpayer's) request for a tax abatement using the cost-of-performance me...
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The Senate has approved a bipartisan IRS reform bill, which now heads to President Trump's desk. Trump is expected to sign the bill into law.
The Senate has approved a bipartisan IRS reform bill, which now heads to President Trump's desk. Trump is expected to sign the bill into law.
The reworked Taxpayer First Act ( HR 3151) cleared the Senate on the evening of June 13. The revamped measure had been approved unanimously in the House on June 10.
"After years of good-faith, bipartisan work, our IRS reforms are finally going to become law," House Ways and Means Committee Chairman Richard Neal, D-Mass., and ranking member Kevin Brady, R-Tex., said in a joint statement. "In this historic legislation, we focused on putting taxpayers first."
Likewise, Senate Finance Committee (SFC) Chairman Chuck Grassley, R-Iowa, praised the passage of the bipartisan, bicameral IRS reform bill. "It's a big first step toward strengthening taxpayer protections and turning the IRS into the customer service organization it ought to be," Grassley said in a statement. "I look forward to President Trump signing it into law so the IRS can begin implementing long overdue reforms that will put taxpayers first," he added.
Reworked Bill
The reworked IRS reform bill, originally introduced in the last Congress, was revised earlier in June after the House passed a prior version in April. However, the original House-approved Taxpayer First bill (HR 1957) was deemed doomed in the Senate by May because of recent controversy surrounding the IRS's Free File program. Thus, the provision codifying the Free File program was stripped from the original bill; the measure was reintroduced as HR 3151. It then quickly cleared each chamber.
Service Improvements
Generally, the Taxpayer First Act aims to reform the IRS for the first time in 20 years to better meet the needs of taxpayers. It requires the IRS to develop a comprehensive customer service strategy, as well as a plan to redesign its structure, modernize its technology, and enhance its cyber security. In addition, the new law will:
waive the application fee for an offer in compromise (OIC) by a low-income taxpayer;
clarify information available about low-income taxpayer clinics (LITCs);
codify the Volunteer Income Tax Assistance (VITA) Program;
require notice regarding the closure of taxpayer assistance centers (TACs);
improve the IRS whistleblower program; and
modify the private debt collection program.
Identity Protection
The legislation includes a number of provisions to help protect taxpayers from tax ID theft and improve taxpayer interaction with the IRS should they become a victim. For example, the IRS must provide a single point of contact for victims of identity theft, notification of suspected identity theft, and guidelines for stolen identity refund fraud cases.
The IRS is required to expand its current program that allows victims of tax ID theft to obtain a personalized PIN. Any individual must be allowed to request an identity protection personal identification number (IP PIN) to confirm a taxpayer's identity on tax returns.
Electronic Filing
The IRS reform bill directly impacts taxpayers and other persons by reducing the threshold for filing electronically from 250 or more returns during the year. The threshold is 100 or more returns for 2021, and 10 or more return after 2021. The IRS can waive the e-file requirement for tax return preparers in areas with limited internet access.
The e-filing threshold for a partnership with 100 or fewer partners remains unchanged before 2022. The threshold is 150 returns for 2019, 100 returns for 2020, and 50 returns for 2021.
E-filing requirements are also extended to all tax-exempt organizations that file returns or statements, regardless of amount of assets, gross receipts, or number of returns to be filed. In addition, the IRS is directed to develop an internet portal to allow taxpayers to file series Form 1099, similar to the portal used to file series Form W-2 with the Social Security Administration.
Other Electronic Services
To help increase the use of electronic services, the IRS must publish within six months uniform standards for accepting electronic signatures on requests for disclosure of taxpayer information (Forms 2848, 4506-T, and 8821). It must also limit the redisclosure of return information by a designee to only those expressly consented to by the taxpayer.
The new law increases the penalty for improper disclosure or use of information by return preparers. It also puts new limits on access to returns and return information by non-IRS employees.
Overall, the IRS must develop procedures to authenticate users of its suite of electronic services, to prevent tax refund fraud. Included in these services, the IRS must develop an automated version of its Income Verification Express Service (IVES) for third-parties.
Planning Note: The legislation also allows the IRS to accept credit and debit card payments for the payment of taxes directly, as opposed to through a third party. In addition, the IRS must establish procedures for taxpayers to report misdirected deposits of refunds.
Other Changes
Additional changes made by the Taxpayer First Act include:
clarifying procedures for equitable relief from joint liability;
establish new safeguards on the seizure of funds believed to be structured to avoid the $10,000 financial reporting requirement; and
modify procedures for the issuance of summons and notice of third party contacts by the IRS.
To help pay for these changes, the minimum penalty for failure to file returns is increased after 2019 to the lesser of $330 (indexed for inflation) or 100 percent of the amount required to be shown on the return.
Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons:
Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons:
Proposed regulations provide detailed rules for coop patrons and specified cooperatives to calculate the deduction.
A proposed revenue procedure provides three methods for specified cooperatives to calculate W-2 wages.
199A Deduction for Cooperatives and Patrons
The 199A deduction, also known as the pass-through deduction or the QBI deduction, generally allows individuals, estates and trusts to deduct up to 20 percent of their qualified business income (QBI) from sole proprietorships and pass-through entities. Since most coops are C corporations, they cannot claim the deduction. However, their members may receive patronage dividends that are included in QBI.
Despite these general rules, certain agricultural or horticultural coops, known as "specified cooperatives," can claim their own version of the a deduction under Code Sec. 199A(g). A specified coop can also pass through any portion of this deduction by making qualified payments to its patrons. The patrons must reduce their own QBI accordingly.
For specified coops, the 199A(g) deduction retains many of the rules that governed the Code Sec. 199 domestic production activities deduction before it was repealed at the end of 2017. For example, the 199A(g) deduction is based on the specified coop's domestic production gross receipts (DPGR) and qualified production activities income (QPAI), rather than its QBI.
Sec. 199A Deduction for Coop Patrons in General
Under the proposed regulations, any coop patron's QBI may include patronage dividends and an exempt coop's non-patronage dividends that:
are related to the patron's trade or business,
are qualified items of income, gain, deduction or loss at the coop level,
are not from a specified service trade or business (SSTB), and
are properly reported to the patron.
The proposed regulations provide detailed rules for how coops must report the required information to their patrons. However, the coop does not report any W-2 wages or unadjusted basis in qualified property immediately after acquisition (UBIA). The W-2/UBIA limit that can reduce QBI for higher-income taxpayers is calculated only at the patron level.
Sec. 199A(g) Deduction for Specified Cooperatives
Code Sec. 199A(g) allows specified coops to claim a 199A deduction and pass through any portion of it by making qualified payments to its members. However, as mentioned above, a specified coop's deduction is largely based on the pre-2018 domestic production activities deduction (DPAD). This means that the 199A(g) deduction for specified coops is effectively separate from the general Code Sec. 199A(a) deduction for other taxpayers.
Since specified coop patrons might be able to claim both the general 199A(a) deduction and the passed-through portion of the coop's 199A(a) deduction, they must reduce their 199A(a)deduction by nine percent of QBI (or if less, 50 percent of W-2 wages) that is allocable to the qualified payments from the specified coop.
The proposed regulations offer a safe harbor that patrons can use to calculate this reduction. The patron allocates aggregate business expenses and W-2 wages between qualified payments and other gross receipts by ratably apportioning them based on the ratio of qualified payments to total gross receipts in QBI.
The proposed regulations also define several terms that are relevant to the 199A(g) deduction for specified coops, including:
Specified cooperative,
Agricultural or horticultural products (though the IRS is also considering broader definitions), and
In whole or significant part.
Sec. 199A(g) Deduction and DPAD
The proposed regulations also provide four steps to determine the amount of a specified coop's 199A(g) deduction. A specified coop that is not tax-exempt must:
separate patronage and non-patronage gross receipts and related deductions;
identify patronage gross receipts that qualify as DPGR,
use the patronage DPGR from step (3) to calculate QPAI, and
calculate the 199A(g) deduction, which is generally nine percent of the lesser of QPAI from step (4), or taxable income
These last three steps are virtually identical to the pre-2018 DPAD rules.
A tax-exempt specified coop calculates two separate 199A(g) deductions: one based on gross receipts and related deductions from patronage sources, and one based on those items from non-patronage sources.
The proposed regulations also apply DPAD-types rules to:
determine the coop's DPGR,
reduce a specified coop's 199A(g) deduction to reflect oil-related QPAI, and
pass through the deduction to patrons.
In addition, the proposed regulations provide special rules for partnerships and expanded affiliated groups (EAGs).
Specified Coops and W-2 Wages
Although the proposed regulations treat the 199A(g) deduction as largely independent from the general 199A(a) deduction, both deductions generally use the same rules for W-2 wages. However, under the proposed regulations, W-2 wages for the 199A(g) deduction cannot include wages paid with respect to employment in Puerto Rico.
As mentioned above, a wages/UBIA limit may reduce the 199A deduction for higher-income taxpayers. A proposed revenue procedure provides three methods for calculating W-2 wages for purposes of the 199A(g) deduction:
unmodified Box method
modified Box 1 method
tracking wages method.
These methods are largely identical to the methods provided in Rev. Proc. 2019-11, but are intended to better reflect changes that may be made in the underlying Form W-2, Wage and Tax Statement.
Effective Dates for 199A Proposed Regulations and Revenue Procedure
The regulations are proposed to apply to tax years beginning after the date they are published as final. However, taxpayers may apply them in their entirely before that date.
The notice of the proposed revenue procedure is effective on June 18, 2019. Specified cooperatives may rely on the proposed procedure before it is published in its final form.
IRS Invites Comments on Proposed Rules for Sec. 199A
The IRS requests comments on the proposed regulations and the proposed revenue procedure. In particular, the IRS invites comments on the following elements:
A coop's reporting of W-2 wages and UBIA,
The safe harbor for coop patrons,
A specified coop's separation of patronage and non-patronage income,
DPGR treatment of minor assembly and contract work, and
W-2 wages and Puerto Rico.
Comments are due by August 19, 2019. They may be mailed or hand-delivered to the IRS, or submitted electronically via the Federal eRulemaking Portal at www.regulations.gov. Comments on the proposed regs should reference "IRS REG-118425-18" and comments on the proposed revenue procedure should reference "Notice 2019-27".
The IRS has issued final regulations that require taxpayers to reduce the amount any charitable contribution deduction by the amount of any state and local tax (SALT) credit they receive or expect to receive in return. The rules are aimed at preventing taxpayers from getting around the SALT deduction limits. A safe harbor has also been provided to certain individuals to treat any disallowed charitable contribution deduction under this rule as a deductible payment of taxes under Code Sec. 164. The final regulations and the safe harbor apply to charitable contribution payments made after August 27, 2018.
The IRS has issued final regulations that require taxpayers to reduce the amount any charitable contribution deduction by the amount of any state and local tax (SALT) credit they receive or expect to receive in return. The rules are aimed at preventing taxpayers from getting around the SALT deduction limits. A safe harbor has also been provided to certain individuals to treat any disallowed charitable contribution deduction under this rule as a deductible payment of taxes under Code Sec. 164. The final regulations and the safe harbor apply to charitable contribution payments made after August 27, 2018.
SALT Limit
An individual's itemized deduction of SALT taxes is limited to $10,000 ($5,000 if married filing separately) for tax years beginning after 2017. Some states and local governments have adopted laws that allowed individuals to receive a state tax credit for contributions to certain charitable funds. These laws are aimed at getting around the SALT deduction limit by creating a charitable deduction for federal income tax purposes. Regardless of state and local law, however, federal law controls when determining charitable deductions for federal income tax purposes.
Return Benefit
The final regulations generally adopt the rule in proposal regulations ( NPRM REG-112176-18) that the receipt of a SALT credit for a charitable contribution is the receipt of a return benefit (quid pro quo benefit). If a taxpayer makes a payment or transfers property to Code Sec. 170(c) entity, he or she must reduce any charitable contribution deduction for federal income tax purposes if he or she receives or expects to receive a SALT credit in return. A taxpayer is generally is not required to reduce the charitable deduction on account of its receipt of state or local tax deductions. However, the taxpayer must reduce its charitable deduction if it receives or expects to receive state or local tax deductions in excess of the taxpayer's payment or the fair market value of property transferred.
De Minimis Exception
The final regulations retain the de minimis exception that a taxpayer's charitable deduction is not reduced if the SALT credits received as a return benefit do not exceed 15 percent of the taxpayer's charitable payment. The 15-percent exception applies only if the sum of the taxpayer SALT credit received or excepted to receive does not exceed 15 percent of the taxpayer's payment or of the fair market value of the property transferred.
Safe Harbor
The IRS has also issued Notice 2019-12 providing a safe harbor for certain individuals if any portion of a charitable contribution deduction disallowed due to the receipt of a SALT credit. Under the safe harbor, any disallowed portion of the charitable deduction may be treated as the payment of SALT taxes for the purposes of deducting taxes under Code Sec. 164.
Eligible taxpayers can use the safe harbor to determine their SALT deduction on their tax-year 2018 return. Those who have already filed may be able to claim a greater SALT deduction by filing an amended return if they have not already claimed the $10,000 maximum amount ($5,000 if married filing separately).
Final regulations address the global intangible low-taxed income (GILTI) provisions of Code Sec. 951A. The final regulations retain the basic approach and structure of the proposed regulations published on October 10, 2018. The final regulations address open questions and comments received on the proposed regulations.
Final regulations address the global intangible low-taxed income (GILTI) provisions of Code Sec. 951A. The final regulations retain the basic approach and structure of the proposed regulations published on October 10, 2018. The final regulations address open questions and comments received on the proposed regulations.
Final regulations on the foreign tax credit also adopt proposed regulations published December 7, 2018. These rules were issued to ensure that the applicability dates coincide with the applicability dates of the Code sections to which they relate. The final foreign tax credit regulations also retain the basic structure and approach of the proposed regulations.
Also, a number of provisions were substantially revised.
Domestic Partnerships
The final regulations treat a domestic partnership as an entity for purposes of determining whether a U.S. person is a U.S. shareholder and whether a foreign corporation is a controlled foreign corporation (CFC). But the final rules treat a domestic partnership as an aggregate for purposes of determining whether and to what extent a partner of a domestic partnership has a GILTI inclusion.
Transfers During Qualified Period
The final regulations allow taxpayers to make an election that eliminates disqualified basis in property, by reducing a commensurate amount of adjusted basis in the property for all purposes of the Code.
Specified Tangible Property
A CFC may elect to use its non-ADS depreciation method for property acquired before enactment of the GILTI rules. A special rule requires depreciation of the salvage value: the portion of the basis in the property that would not be fully depreciated under the non-ADS depreciation method.
Anti-Abuse Rule
Under a "per se" rule in the proposed regulations, property was deemed to be held for the principal purpose of reducing a GILTI inclusion if held by the CFC for less than a 12-month period. The final regulations convert the per se rule to a rebuttable presumption. Under a second presumption, property held for more than 36 months is not subject to the rule. A safe harbor applies for certain transfers.
Foreign Tax Credit
The foreign tax credit proposed regulations contained a rule for determining the adjusted basis of the stock of the foreign corporation for purposes of allocating expenses to stock of certain foreign corporations. The final regulations provide that a taxpayer should not have an adjusted basis below zero in stock of a foreign corporation. A taxpayer's adjusted basis may be reduced below zero as a result of an adjustment for earnings and profits deficits, as long as the adjustment for earnings and profits increased the adjusted basis of the foreign corporation above zero.
Applicability of Final Regs
The final GILTI regulations generally apply to tax years of foreign corporations beginning after December 31, 2017, and to tax years of U.S. shareholders in which or with which such tax years of foreign corporations end.
Proposed Regulations
The Treasury Department and the IRS also issued proposed regulations on the treatment of domestic partnerships for determining amounts included in their partners' gross incomes under Code Sec. 951 with respect to CFCs owned by the partnership, and the GILTI treatment of gross income that is subject to a high rate of foreign tax under Code Sec. 951A.
The proposed regulations would affect U.S. persons that own stock of foreign corporations through domestic partnerships and U.S. shareholders of foreign corporations. The Treasury Department and the IRS request timely comments on all aspects of the proposed rules. A public hearing will be scheduled if requested in writing by any person that timely submits written comments.
Aggregate Treatment Adopted
To be consistent with the treatment of domestic partnerships under Code Sec. 951A, Treasury and the IRS determined that a domestic partnership should also generally be treated as an aggregate of its partners in determining stock owned under Code Sec. 958(a) for Code Sec. 951 purposes.
Expansion to Exclude Other High-Taxed Income
Treasury and the IRS also determined that the GILTI high tax exclusion should be expanded (on an elective basis) to include certain high-taxed income even if that income would not otherwise be foreign base company income (FBCI) or insurance income. Further, taxpayers should be allowed to elect to apply the Code Sec. 954(b)(4) exception (the "GILTI high tax exclusion") for certain classes of income that are subject to high foreign taxes.
Newly issued temporary regulations limit the application of the Code Sec. 245A participation dividends received deduction (the participation DRD) and the Code Sec. 954(c)(6) exception in certain situations that present an opportunity for tax avoidance. The temporary regulations also provide related information reporting rules under Code Sec. 6038.
Newly issued temporary regulations limit the application of the Code Sec. 245A participation dividends received deduction (the participation DRD) and the Code Sec. 954(c)(6) exception in certain situations that present an opportunity for tax avoidance. The temporary regulations also provide related information reporting rules under Code Sec. 6038.
Participation Exemption Regime
The transition to the participation exemption system introduced by the Tax Cuts and Jobs Act, P.L. 115-97 (the Act) is effected through several interlocking provisions – Code Secs. 245A, 951A, and 965. All three provisions have different effective dates so there are periods in which some but not all of them apply. The participation exemption system operates alongside the subpart F regime.
Code Sec. 245A generally allows a domestic corporation a 100-percent dividends received deduction (a participation DRD) for the foreign-source portion of a dividend received after December 31, 2017, from a specified 10 percent-owned foreign corporation (an SFC). Generally, only earnings that are not taxed under the subpart F or the global intangible low-taxed income (GILTI) regime can, upon distribution, give rise to a dividend eligible for the participation DRD. Distribution of earnings and profits that is taxed under the subpart F or GILTI regime is a distribution of previously taxed earnings and profits (PTEP) that is not treated as a dividend and cannot qualify for the participation DRD. The participation DRD applies to distributions made after December 31, 2017.
The participation DRD does not apply to untaxed earnings of U.S. shareholders as of December 31, 2017. Instead, such earnings are subject to a transition tax under Code Sec. 965. For fiscal year CFCs, there is a gap period during which certain of their earnings may escape taxation.
Code Sec. 951A (the GILTI regime) taxes a U.S. shareholder on its global intangible low-taxed income, or GILTI, with respect to its CFCs at a reduced rate. The GILTI regime applies in the first tax year of a CFC beginning after December 31, 2017.
Code Sec. 954 generally provides that a dividend received by a CFC is included in the CFC's foreign personal holding company income (FPHCI). Under Code Sec. 954(c)(6), however, a dividend received by a CFC from a related CFC is not included in the CFC's FPHCI if certain requirements are satisfied (the section 954(c)(6) exception).
Scope of the Temporary Regulations
The temporary regulations limit the availability of the participation DRD and the section 954(c)(6) exception in specific and narrow cases where the deduction or exception, respectively, effectively eliminates subpart F income or GILTI from the U.S. tax system. Specifically, the temporary regulations address transactions that have the effect of avoiding tax under Code Sec. 965, 951A, or 951by inappropriately converting income that should have been subject to U.S. tax into nontaxed income. The temporary regulations also include information reporting rules under Code Sec. 6038 to facilitate administration of certain rules in the temporary regulations. The temporary regulations do not include general rules relating to dividends eligible for the participation DRD since those rules will be included in separate guidance.
Overview of the Temporary Regulations
Code Secs. 245A, 951A, and 965 generally act to tax foreign source income equivalently across taxpayers and sources so long as a U.S. shareholder owns the same amount of stock of a calendar year CFC throughout the CFC's entire tax year. However, deviations from this condition potentially allow taxpayers to avoid tax by claiming a participation DRD in situations where otherwise identical income would be subject to U.S. tax. The following two situations may present such an opportunity for tax avoidance: (1) a U.S. corporation is the shareholder of a fiscal year CFC during 2018, or (2) a CFC pays a dividend and experiences a direct or indirect change in ownership during a tax year. The temporary regulations limit the application of the participation DRD in these situations.
With respect to the first situation, described above, as a result of a gap in the effective dates of these related international tax provisions, the difference between calendar year and fiscal year CFCs is significant and presents the potential for substantial tax avoidance when utilized to artificially generate earnings and profits in non-ordinary course transactions between related parties.
The temporary regulations refer to the portion of a dividend attributable to earnings and profits arising from such a transaction during this period as an "extraordinary disposition amount." An extraordinary disposition amount consists of certain earnings and profits resulting from transactions between related parties during the disqualified period. Although the period during which extraordinary dispositions may have occurred has passed, the regulations will potentially apply to any distributions of the associated earnings and profits after 2017.
In the second situation, described above, the participation DRD could facilitate the avoidance of the subpart F and GILTI regimes by allowing a U.S. shareholder to transfer, before the end of a CFC's tax year, stock of the CFC to a new shareholder who will not be taxed on the CFC's subpart F income or tested income.
The earnings and profits representing the portion of a dividend of a CFC attributable to subpart F income or tested income that, absent a transfer of the CFC stock pursuant to an extraordinary reduction, would have been subject to the subpart F or GILTI regimes are referred to as an "extraordinary reduction amount" in the temporary regulations. An extraordinary reduction amount consists of certain earnings and profits generated during a CFC's tax year beginning after 2017 in which a domestic corporate U.S. shareholder reduces its ownership of the CFC by certain threshold amounts (e.g., a decrease in ownership of more than 10 percent). For this purpose, "certain earnings and profits" refers to income generally subject to inclusion under the subpart F or GILTI regimes.
Results similar to the ones described in the context of extraordinary disposition amounts and extraordinary reduction amounts can be achieved using the exemption from subpart F income under Code Sec. 954(c)(6) and lower-tier CFC dividends to upper-tier CFCs. Thus, the temporary regulations limit the application of the section 954(c)(6) exception in order to prevent similar results in circumstances in which a lower-tier CFC pays a dividend to another CFC, instead of directly to a U.S. shareholder.
Operation of the Temporary Rules
The temporary regulations do not permit the participation DRD for the portions of dividends made by CFCs that are attributable to ineligible amounts, which comprise extraordinary reduction amounts and 50 percent of any extraordinary disposition amounts.
To accomplish this, the temporary regulations disallow a deduction for transactions that have the effect of avoiding tax under Code Sec. 965, 951A, or 951. The extraordinary disposition rules accomplish this by denying the participation DRD for a narrowly and objectively defined class of earnings and profits generated by transactions undertaken in the disqualified period in circumstances that raise abuse concerns.
The extraordinary reduction rules accomplish this by denying the participation DRD for certain earnings distributed in the same year as reductions in ownership of CFC stock by a controlling Code Sec. 245A shareholder. The temporary regulations contain similar rules with respect to the section 954(c)(6) exception.
Information Reporting under Code Sec. 6038
Ineligible amounts, tiered extraordinary disposition amounts, and tiered extraordinary reduction amounts must be reported on the appropriate information reporting form in accordance with Code Sec. 6038. A transition rule mandates that taxpayers report the required information on the first return filed following the issuance of revised forms, instructions, or other guidance with respect to reporting such information. The transition rule also requires a corporation to report the information with respect to a predecessor corporation.
Applicability Dates
The rules in the temporary regulations relating to eligibility of distributions for the participation DRD apply to distributions occurring after December 31, 2017. The rules in the temporary regulations relating to the eligibility of dividends for the section 954(c)(6) exception also apply to distributions occurring after December 31, 2017, subject to a transition rule.
Final regulations reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The regulations are intended to ensure that Code Sec. 956 is applied consistently with the participation exemption system under Code Sec. 245A.
Final regulations reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The regulations are intended to ensure that Code Sec. 956 is applied consistently with the participation exemption system under Code Sec. 245A.
Subpart F Rules
Under the subpart F rules, U.S. shareholders of a CFC are currently taxed on their pro rata shares of the CFC's subpart F income without regard to whether the income is distributed to the shareholders ( Code Sec. 951(a)). Subpart F income generally includes passive income and other income that is readily movable from one taxing jurisdiction to another ( Code Sec. 952). A U.S. shareholder is a U.S. person (e.g., individual citizen, domestic corporation, etc.) that owns or is treated as owning 10 percent or more of the voting power or value of a foreign corporation ( Code Sec. 951(b)).
The U.S. shareholders of a CFC are taxed on their pro rata share of the CFC's earnings that are invested in U.S. property during the tax year and not distributed or otherwise taxed (the "section 956 amount"). U.S. shareholders are effectively taxed on foreign source earnings brought back into the United States, on the theory that the returned earnings are substantially the same as a dividend. This rule is intended to create symmetry by taxing effective repatriations of earnings in the same manner as actual repatriations of earnings are taxed.
Participation DRD
The Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97) added Code Sec. 245A, which allows a 100-percent participation exemption deduction—a participation dividends-received deduction (DRD)—for the foreign-source portion of dividends received from a specified 10-percent owned foreign corporation by a domestic corporation that is a U.S. shareholder of the foreign corporation. A specified 10-percent owned foreign corporation is any foreign corporation (other than certain passive foreign investment companies) in which a domestic corporation is a U.S. shareholder.
However, a domestic corporation cannot claim a participation DRD for a dividend on any share of the foreign corporation's stock:
that the domestic corporation holds for 365 days or less during the 731-day period that begins on the date that is 365 days before the date when the share becomes ex-dividend with respect to the dividend; or
to the extent the domestic corporation is obligated to make related payments on positions in substantially similar or related property ( Code Sec. 246(c)).
Under the TCJA, a Code Sec. 956 inclusion is not eligible for the DRD because it is not a dividend.
Tax Treatment Symmetry
The participation exemption system has made the current broad application of Code Sec. 956 to corporate U.S. shareholders inconsistent with the Code section's purposes and the scope of the transactions it is meant to address. In response, the regulations:
exclude corporate U.S. shareholders from the application of Code Sec. 956 to the extent necessary to maintain symmetry between the taxation of actual repatriations and the taxation of effective repatriations, so that neither an actual dividend to a corporate U.S. shareholder nor the shareholder's Code Sec. 956 amount will result in additional U.S. tax; and
reduce the Code Sec. 956 amount otherwise determined regarding a U.S. shareholder for a CFC's tax year ( "tentative Section 956 amount") to the extent that the shareholder would be allowed a participation DRD had the shareholder received a distribution from the CFC equal to the tentative Code Sec. 956 amount (the "hypothetical distribution").
The regulations include an ordering rule to address the previously taxed earnings and profits (PTEP) rules in Code Sec. 959. Under the ordering rule, the hypothetical distribution is treated as:
first attributable to earnings and profits (E&P) described in Code Sec. 959(c)(2) (amounts attributable to subpart F inclusions); and
then attributable to E&P described in Code Sec. 959(c)(3) (all other E&P).
The regulations also address the tentative section 956 amount with respect to domestic partnerships. The regulations provide that the tentative section 956 amount with respect to a domestic partnership is reduced to the extent that one or more of the domestic corporate partners would be entitled to a participation DRD if:
the partnership received the amount as a distribution; and
the remaining amount of the inclusion under Code Sec. 956 is allocated to the partners in the same proportion as net income would result to partners upon a hypothetical distribution.
Applicability Date
The regulations will apply to tax years of CFCs beginning on or after July 22, 2019, and to tax years of U.S. shareholders in which or with which such tax years of CFCs end.
The regulations may be applied to tax years of CFCs beginning after December 31, 2017, and to tax years of U.S. shareholders in which or with which such tax years of CFCs end, provided the rules are applied consistently by the taxpayer and U.S. related persons.
Final rules allow employers to use health reimbursement arrangements (HRAs) to reimburse employees for the purchase individual insurance coverage, including coverage on an Affordable Care Act Exchange. The rules also allow "excepted benefit HRAs," which would not have to be integrated with any coverage. The rules generally apply for plan years starting on or after January 1, 2020.
Final rules allow employers to use health reimbursement arrangements (HRAs) to reimburse employees for the purchase individual insurance coverage, including coverage on an Affordable Care Act Exchange. The rules also allow "excepted benefit HRAs," which would not have to be integrated with any coverage. The rules generally apply for plan years starting on or after January 1, 2020.
HRA Use Expanded
The final rules expand the use of HRAs by:
allowing integration of an HRA with individual health insurance coverage and thereby satisfy the Affordable Care Act's annual dollar limit and preventive care cost sharing requirements;
creating "excepted benefit HRAs" limited in amount and to the types of coverage for which premiums may be reimbursed;
providing new premium tax credit eligibility rules for individuals who are offered an HRA integrated with individual health insurance coverage;
clarifying that individual health insurance coverage, the premiums of which are reimbursed by an HRA or qualified small employer HRA (QSEHRA), does not become part of an ERISA plan when certain conditions are met; and
adding new special enrollment for the individual market for individuals who gain access to HRAs integrated with individual health insurance coverage or who are provided a QSEHRA.
The final regulations add conditions on individual coverage HRAs intended to prevent a negative impact on the individual market.
Integration With Individual Coverage
Almost any employer can satisfy Affordable Care Act reimbursement requirements by having employees buy their own individual coverage. An employers may integrate an HRA with individual health coverage only if:
participants and dependents are actually enrolled in individual health insurance coverage (though not coverage that consists solely of excepted benefits) for each month they are covered by the HRA;
coverage is offered to a class of employees to whom a traditional group health plan is not offered;
coverage is offered on the same terms in amount and conditions to all employees within each class (though certain variations based on age are allowed);
an opt out option is provided for individuals who prefer Affordable Care Act Exchange coverage, but would not be eligible for the premium tax credit if enrolled in an employer health plan such as an HRA; and
substantiation and notice requirements are met.
To guard against adverse selection, the final rules add a minimum class size requirement that will apply to certain classes of employees in certain instances. Classes of employees may include full-time employees; part-time employees; seasonal employees; employees who are included in a unit of employees covered by a collective bargaining agreement in which the plan sponsor participates; employees who have not satisfied a waiting period for coverage; employees who have not attained age 25 prior to the beginning of the plan year; nonresident aliens with no U.S.-based income; employees whose primary site of employment is in the same rating area; and groups combining any of these classes of employee.
Excepted Benefit HRAs
An employer that wants to offer an HRA that is not integrated with non-HRA group coverage, Medicare, TRICARE, or individual health insurance coverage may do so as an excepted benefit. As excepted benefits, these HRAs would not be subject to the employer group plan rules, including the market reforms under the Affordable Care Act. An excepted benefit HRA:
must not be an integral part of the plan;
must provide benefits that are limited in amount ($1,800 per year, adjusted for inflation after 2020);
cannot provide reimbursement for premiums for certain health insurance coverage; and
must be made available under the same terms to all similarly situated individuals.
Final regulations provide requirements that a person must satisfy to become and remain a certified professional employer organization (CPEO), as well as the CPEO's federal employment tax liabilities and other obligations.
Final regulations provide requirements that a person must satisfy to become and remain a certified professional employer organization (CPEO), as well as the CPEO's federal employment tax liabilities and other obligations.
Some employers contract with PEOs to complete and file tax returns, pay and withhold employment taxes on wages paid to employees, or provide other employee benefits. Code Sec. 3511 and Code Sec. 7705 provide certification requirements for PEOs, and codify the employment tax consequences of being CPEO.
For federal employment tax purposes, a CPEO is generally treated as the employer of any individual who is:
performing services for a customer of the CPEO; and
covered by a contract between the CPEO and the customer.
Employer treatment applies only to remuneration paid to the covered employee by the CPEO. If an individual covered by a CPEO contract performs services for a customer at a work site that meets certain coverage requirements, only the CPEO is treated as the employer for federal employment tax purposes for remuneration its pays to that work site employee.
A person must apply to the IRS to become a CPEO, and the IRS must certify that the person meets certain requirements. A CPEO must:
meet tax status and background requirements;
meet bond, financial review, and quarterly reporting requirements; and
notify the IRS of any change that materially affects the continuing accuracy of information it has provided to the IRS.
The Treasury Secretary can suspend or revoke CPEO certification if the person does not satisfy certain agreements or applicable requirements.
Final Regs
The final regulations adopt and amend proposed regulations published in 2016 ( NPRM REG-127561-15), and reflect and address certain interim guidance ( Rev. Proc. 2016-33, 2016-25 I.R.B. 1034; Notice 2016-49, 2016-34 I.R.B. 265; Rev. Proc. 2017-14, 2017-3 I.R.B. 426). In finalizing the regulations, the IRS reviewed and analyzed a variety of issues affecting CPEOs, including:
maintaining a separate annual FICA tax and FUTA tax wage base and withholding threshold for each customer for which a covered employee performs services during a calendar year;
the treatment of tax credits, including the addition of the employer credit for paid family and medical leave and certain employee retention credits to the list of specified credits that apply to the CPEO customer and not the CPEO;
the treatment of self-employed individuals under the CPEO rules;
CPEO reporting to the IRS, such as reporting the commencement or termination of CPEO contracts and service agreements;
the meaning of key terms such as "responsible individuals" (certain owners, officers, and other persons of the CPEO), "work site," and "work site employee";
the CPEO application process, including when an applicant may reapply for certification;
CPEO "suitability" requirements, including domestic disregarded entity and sole proprietorship certification, fingerprint cards and background checks, and the waiver of confidentiality and privilege;
working capital requirements, including a limited exception to the positive working capital requirement;
bond requirements, including a provision that the IRS Commissioner may provide exceptions to the rule that a CPEO must meet the bond requirements without posting collateral; and
maintaining employee records.
The final regulations are effective on May 28, 2019.


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Research on Two Supplements Addresses HIV-Driven Inflammation in the Gut
Probiotic Supplementation Could Potentially Decrease Resistance, Micronutrient Deficiencies, Viral Replication and Immune Suppression
Gastrointestinal (GI) health is proving to be a vital, though often ignored, component of HIV infection. Recent research presented at the 7th International AIDS Conference on HIV Pathogenesis, Treatment and Prevention (IAS 2013), which took place this past July in Kuala Lumpur, Malaysia, showed that microbial translocation and the damage done to gut-associated lymphoid tissue (GALT) during primary HIV infection has a dramatic effect on the pathogenesis of HIV, including the disruption of microflora, resulting in ongoing and damaging inflammation. While more research on the effects of HIV on the GI system is sorely needed, the consequences of sequestration on the National Institutes of Health (NIH) budget, along with the growing competition to prioritize directions in therapeutic investigation, ranging from viral host restrictive factors to preventive vaccines, make putting anything else on the table an enormous challenge.
The data being presented on addressing microbial translocation, HIV-associated enteropathy and gut inflammation are compelling. HIV-associated enteropathy often accounts for diarrhea and malabsorption in patients who lack an identifiable cause and includes mucosal dysfunction as a defining characteristic. HIV-associated enteropathy results in microbial translocation and subsequent chronic inflammation as well as malabsorption, which may result in drug resistance.
HIV-associated enteropathy affected a high percentage of people with HIV in the pre-HAART (highly active antiretroviral therapy) era and continues to be a problem for some even in the presence of HAART. HIV-associated enteropathy can also cause weight loss and structural and functional damage to the GI tract. Despite effective treatment with HAART, it continues to be drastically underestimated.
The only available drug for HIV-related non-infectious diarrhea is Fulyzaq. Fulyzaq, made by Salix Pharmaceuticals, was approved by the U.S. Food and Drug Administration (FDA) in 2012. In a 374-patient study, incidences of diarrhea were reviewed over a 20-week period. Results found that 17.6% of patients taking Fulyzaq had two or less watery bowel movements per week compared to only 8% of patients on placebo. Fulyzaq was found to be less effective in African Americans who participated in the study. Due to continual production issues, this drug is not widely available and appears to only help a small number of people.
Few other potential treatments for HIV-associated enteropathy are currently being studied despite the great need for interventions. One study, however, that showed promise was published in the journal AIDS (Asmuth et al., 2013) and presented at the 19th International AIDS Conference (AIDS 2012) last July in Washington, D.C., and at the 20th Conference on Retroviruses and Opportunistic Infections (CROI 2013) in March of this year in Atlanta, Ga. David M. Asmuth, M.D., reported on a pilot study of the effects of serum-derived bovine immunoglobulin/protein isolate (SBI; brand name EnteraGam, made by Entera Health, Inc.) on patients with HIV-associated enteropathy. According to previous studies in porcine and murine models, SBI has been shown to improve gut health and function and reduce markers of inflammation.
All eight participants in this study were on HAART. Administration of SBI improved GI absorption and increased the density of CD4 T lymphocytes in GALT. Although markers of microbial translocation remained unchanged, D-xylose, a direct measure of proximal small bowel function, suggested improvement in diarrhea in seven out of eight study participants. The utility of SBI was significantly associated with increased intestinal CD4+ cell counts and function and demonstrated evidence of intestinal repair in patients experiencing HIV-associated enteropathy. A longer, larger, blinded study is said to be forthcoming on this medical food.
Another approach to addressing HIV-associated diarrhea is the utility of probiotics. Probiotics can alter gut bacteria, which can cause diarrhea. Probiotics have also been found to increase CD4+ cell counts, as seen in a study published in the Journal of Clinical Gastroenterology (Irvine et al). A second study conducted by AIDS Healthcare Foundation (AHF) on Ganeden BC30, which collected data that were later evaluated and published in the journal Retrovirology (Selbovitz et al), also found probiotic supplementation to increase CD4+ cell counts.
"We are learning more and more about the interaction between our gut and our immune system. It is such complex machinery that keeps bacteria inside the intestines and, in a majority of the cases, very tightly controlled. Occasionally it gets out of control and that's why people get illnesses. There is more and more evidence that most likely some fragments of bacteria occasionally escape -- they make their way to our systemic circulation, our bloodstream -- and, of course, being a foreign object, the body will try to attack it and neutralize it. That leads to inflammation," Homayoon Khanlou, M.D., Chief of Medicine at AHF and lead investigator of this pilot study, stated in an article that appeared in A&U magazine.
Inflammation in the gut can cause bone loss and probiotics can improve bone density. A new study from Michigan State University, which was sponsored by the NIH and published in the Journal of Cellular Physiology, found that probiotic supplementation utilizing Lactobacillus reuteri, a probiotic shown to reduce inflammation, produced healthier bones. Lead author Laura McCabe, Ph.D., a professor in the departments of physiology and radiology at Michigan State University, said, "We know that inflammation in the gut can cause bone loss, though it's unclear exactly why."
Studies by the AIDS Clinical Trials Group (ACTG) on new interventions for HIV-associated enteropathy, as well as other HIV-associated GI conditions, are long overdue. With the formation of the Delaney AIDS Research Enterprise at the NIH, the opportunities to advance research on gut inflammation, its effect on HIV pathogenesis and HIV's mechanisms for evading viral host restrictive factors have never been better.
With more data being generated on interventions such as SBI and GanedenBC30 in HIV patients, the important task of ensuring access to these supplements falls partly on state legislators through their support of legislation and efforts that would enable physicians to implement exception to policy in public health insurance programs such as Medicaid for people with HIV in all states throughout the U.S. This would allow for beneficial supplements, which would not otherwise be covered, to be made available to patients with a doctor's prescription through enteral formularies. In these times of sequestration, cost-effective measures are of more importance than ever. Therapeutic supplementation may be among the best of these interventions.
An unspoken complication of HIV-associated enteropathy is the disruption in treatment pharmacokinetics, which is the difference between successful and unsuccessful treatment. As the efficacy of HIV medications is dependent upon nutritional status, any malabsorption results in varying levels of a drug in the blood that could predictably result in treatment failure.
HIV-associated enteropathy may be one of the driving factors behind the deeply disturbing data presented at AIDS 2012 by the U.S. Centers for Disease Control and Prevention (CDC) that three out of every four people living with HIV in the U.S. are not able to achieve durable viral suppression. Addressing this alarming condition in a cost-effective manner is of critical importance to achieving widespread viral suppression, which in turn would decrease the number of new HIV infections.
[CORRECTION 11/22: This article has been updated to include additional information and context regarding the potential effects of probiotic supplementation in patients with HIV.]


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Chester Trent Lott, Sr. (born October 9, 1941) is a former United States Senator from Mississippi. He has served in numerous leadership positions in both the House of Representatives and the Senate, including House Minority Whip, Senate Majority Leader, Senate Minority Leader, and Senate Minority Whip.
On December 20, 2002, after significant controversy following what were viewed by some as racially insensitive comments, and by others as respectful comments that did not reference race, regarding Strom Thurmond's presidential candidacy, Lott resigned as Senate Minority Leader in the Senate. In December 2007, he resigned from the Senate entirely and became a Washington-based lobbyist. Lott ruled out any health concerns affecting his resignation. At a press conference on December 31, 2007, Mississippi Governor Haley Barbour appointed Roger Wicker to fill temporarily the Senate seat vacated by Lott. On November 4, 2008, a special election Senate race was held to replace him. The election was won by Republican Roger Wicker.
Lott was born in Grenada, Mississippi. His father, Chester Paul Lott, was a shipyard worker; his mother, Iona Watson, was a schoolteacher. He attended college at the University of Mississippi in Oxford, where he obtained an undergraduate degree in public administration in 1963 and a law degree in 1967. He served as a Field Representative for Ole Miss and was president of his fraternity, Sigma Nu. Lott was also an Ole Miss cheerleader, coincidentally on the same team with U.S. Senator Thad Cochran. He married Patricia Thompson on December 27, 1964. The couple has two children: Chester Trent "Chet" Lott, Jr., and Tyler Lott.


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"Gotham" star Donal Logue took to Twitter to ask for help in locating his missing son. The actor posted the news Tuesday that his 16-year-old Jade Logue disappeared in Brooklyn, New York on Monday.
The 51-year-old, who has also been on "Law & Order: SVU," posted the alert on social media to his nearly 100K followers.
The actor also posted a photo of the teen to his Twitter account. According to Logue, the high-school-aged youngster appears to have last been seen wearing a parka near Brooklyn's Barclays Center. Logue has given out no further information about the teen since the alarming post.
However, NYPD has told E! News that there is no formal complaint about the disappearance on file.
The character actor has starred in a plethora of film and television roles over the decades, appearing in "Ghost Rider," "Sons of Anarchy," and "Grounded for Life."
Logue joined the cast of "Gotham" in 2014.


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Sale Price: $12.47
Sale Price: $92.41
»» Description:
In-ground Pool Safety Fence
Drill Guide - This item is used to help you secure your in-ground safety
fence. It is used with a rotary hammer drill (not included) and will drill
only 5/8" holes.
INCLUDES: (1) Drill Guide, RECOMMENDED
if not available at local hardware / tool rental store.
»» Application:
In-ground Swimming Pool Fence Installation
»» Features:
Includes 1 Drill Guide
Works for drilling 5/8" hole
Used with rotary hammer drill
»» Product Notes / Warranty /
Manufactures Website:
Sale Price: $104.36
Sale Price: $360.84
Sale Price: $424.62


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Choose this traditional European copper foil box in several sizes from just two chocolates (an intimate treat) to 72 chocolates (a Friends and Family Celebration). Each size of our Copper Boxes includes an assortment of milk, dark, and white chocolates with fruit, nut and ganache fillings. There is no better way to treat yourself and friends to a range of delights from Cococo Chocolatiers!
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I made this coconut and tamarind flavored chutney to go along with a rice-based dish known as pongal that will leave you begging for seconds. It is adapted from "Mysore Style Cooking" by V. Sandhya, an essential book for those curious about the intricate and healing properties of South Indian cooking. We are told it works well as a spread for flatbreads and sandwiches. My chutney had a bit drier consistency than the creamier ones I usually prepare in anticipation of serving it with the pongal.
|Coconut-Tamarind Chutney
|Recipe by Lisa Turner
Adapted from Mysore Style Cooking
Cuisine: Indian
Published on June 1, 2011
Simple and delicious coconut chutney seasoned with tamarind and chilies
More Coconut Chutneys from Lisa's Vegetarian Kitchen you are sure to enjoy:
Shredded Mango and Coconut Chutney
Coconut and Mint Chutney
Roasted Toor Dal and Coconut Chutney
On the top of the reading stack: Ethnic Vegetarian: Traditional & Modern Recipes from Africa,& the Caribean by Angela Shelf Medearis


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There is nothing more boring than a blog post that starts "Sorry you haven't heard from me for a while, it's all just been so busy...."
It's as boring as settling down to read someone's diary and the entries go:
"2nd Feb...
... Dear Diary, gosh it's been so long since my last entry!...."
"5th July...
... Dear Diary, gosh it's been so long since my last entry!....."
So I won't start this blog post like that. And anyway, I'm not sorry. It's a miracle I update Recipe Rifle at all, what with my chronic heartburn and never making a penny out of it and being totally and utterly fed up with both cooking and writing.
If you are looking for some sort of explanation then it's because at first I couldn't think of anything to say. All I could think was how annoying Kitty was being, but that was what the last post was about. And then whenever I was about to sit down and do something, awful things would happen. Like Kitty got really ill. And I mean REALLY ill this time, a temperature of 104 and terrible eczema all over her and I had to see about a million different doctors and urgh, I feel quite ill myself thinking about it. AND my husband was away in America and the whole thing was so stressful I was sent running into the arms of a strip of Valium I nicked off my Dad. It was really Seventies.
And then we went on holiday for a bit, which was lovely but I wasn't going to blog from THERE. And now my husband's in trouble again for saying something or other on Twitter, which I won't go into because it's too dementing.
Anyway I am as I write this waiting for him to finish off some work before we go out for a Chinese to drown our sorrows in spring rolls and neon orange sauce, and I'm pacing about and worrying about him and feeling sad that it's all gone bonkers (again) and vaguely wondering if he can ever be persuaded not to say just exactly precisely whatever's in his brain .... and I realised with shock that Recipe Rifle is now an entire month out of date and as it so happens I've got something to say about lemon posset.
I don't like lemon puddings - at all. I've said it before. The acid of the lemon combined with the sweetness and sugariness of other ingredients reminds me powerfully of vomit. But there's something different about lemon posset, maybe it's the really serious creaminess of the thing.
We had this at my sister's house in Oxford over the weekend, made by a terrific fellow called Rory Dorman. Ah yes, the weekend, back when life was still nice and Twitter hadn't fallen on our heads. It seems a golden time, the one sunny day we've had for ages. Maybe the memory of it and the deliciousness of the posset will change my mind about lemon puddings for ever. But I suspect not.
Lemon Posset by Rory Dorman
For about 6 or 8
500ml double cream
lemon and zest of 2 lemons
100g sugar
1 Bubble the cream in a pan gently for 3 minutes
2 Add the sugar and your lemony stuff and whisk
3 Pour into ramekins or glasses and chill for 3 hours
We had ours with raspberry coulis and little posh french biscuits and it was delicious.


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Because the board is growing so fast and it's hard to keep up, we would like to know if anyone would like to help out as a moderator.
If you feel you would be able to help us out and have a desire to keep the board as a positive and informative outlet for promoting ND high school athletics then please send me a private message. [user=1]NDSportsFan[/user]
You would be given editing abilities in all the forums and access to a Moderators Only forum, which is kinda neat. There is no time commitment, but preference can be given to those with a lot of log-time and have demonstrated an ability to post appropriately in the past.
We will probably add about 2 new moderators, depending on how many are interested, thanks everyone.


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How Wall Street made Paul Ryan
Paul Ryan may be best known for Washington budget wonkery, but it was also his Wall Street ties that fueled his meteoric rise from Hill staffer 15 years ago to vice presidential nominee today.
The finance, insurance and real estate sector has been Ryan's top backer over the course of his career — to the tune of $3 million, records show.
Story Continued Below
( PHOTOS: Paul Ryan over the years)
When he stepped into politics he quickly became an industry darling thanks to his hard-line free-market, anti-regulation, pro-business stance.
"I, like many others, saw a rising star and wanted to keep him in the Congress," said John Magill, a lobbyist at the Credit Union National Association who was a House GOP aide during Ryan's first few years in Congress.
( Also on POLITICO: Full coverage of the 2012 race)
It was a near-perfect combination that made Ryan gain Wall Street's favor.
He earned street cred from being a speechwriter for Jack Kemp's Empower America, a favorite of fiscal conservatives. Then he scored prime committee assignments when he made it to Congress, like banking in his first term and the powerful Ways and Means Committee in his second — seats that put him on the receiving end of Wall Street largesse.
The Wall Street cash not only shored up Ryan's own war chest, but let him donate money to colleagues' campaigns — a classic Washington move that built up Ryan's influence in the Republican conference.
Ryan is now one of the top contributors in Congress through his leadership PAC. So far in the 2012 cycle, he's donated about $840,000 to fellow lawmakers, according to the Center for Responsive Politics.
When Ryan launched his political career, he fast emerged as an attractive member of a new breed of House Republicans — young and savvy — who caught the eyes of donors.
"He had a deep thirst for the nuances of the tax code, and then he got on Ways and Means Committee and those were the years that Republicans were in charge and people gravitated toward bright members of Congress, and Paul happened to be one of those," said Richard Hunt, president and CEO of the Consumer Bankers Association who was chief of staff to Rep. Jim McCrery (R-La.), who served on the committee with Ryan. Hunt also served as a lobbyist at the Securities Industry and Financial Markets Association.
The Wisconsin Republican also made friends within the industry when he sided with them on the Gramm-Leach-Bliley Act in 1999, a watershed vote for financial services that repealed prohibitions on the consolidation of commercial banks and investment banks.
He even turned on hardline conservatives during the financial meltdown, voting to bail out the banking system. He later took a more populist tone, accusing the Treasury of mishandling the program.
And in 2010, Ryan voted against the sweeping Dodd-Frank financial reform bill. He penned an op-ed for Real Clear Politics in 2010 berating Obama and Democrats for pushing through the overhaul.
"Its fundamental architecture expands and centralizes power in Washington, doubling down on the root causes of the 2008 crisis," he wrote.
But Ryan isn't always in lock step with Wall Street. He was prepared to allow the United States to default on its bills during the debt ceiling debate. And he has criticized a piece of Dodd Frank that is actually somewhat popular among banks that deals with dismantling financial firms and is aimed at avoiding bailouts.
On the campaign trail, Ryan's running mate Mitt Romney has vowed to repeal the Dodd-Frank overhaul, but the campaign has been murky about how exactly it would be replaced.
During his career, Ryan has raked in more than $3 million from finance, insurance and real estate sector employees and political action committees, according to data compiled by the Center for Responsive Politics, making it the top industry sector to shell out for his campaign.