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What's the Real News Story?
In our global media age, the role of the news media is coming under ever greater scrutiny. As more news channels and newspapers offer 24 hour news on air, in print and on the internet, there is increasing ability for the media to not only report the news but also influence public opinion.
But just as the reach and importance of the media is growing, there is evidence that it is downplaying the most important political issues of our time in preference for softer "human interest" stories.
This very topic was one of the issues being debated at a conference in September at the University of Strathclyde in Glasgow called "Communication and Conflict: Propaganda, Spin and Lobbying in the media age." Over three days of debate, issues such as war propaganda, war reporting, government spin, and media and the Middle East were hotly discussed.
In a session on "Spin and investigative reporting" an award-winning journalist from the BBC, who had spent months working undercover to expose racism in the British police, described what he thought was the most important "story of the decade".
Was it the war in Iraq, and the bloody carnage that has seen over one million people die? No. Was it the huge issue of climate change, and the increasing occurrence of floods and drought? No. Was it the huge debate about whether Iran should be allowed nuclear weapons or not? No.
It was none of these. The story he deemed the most important was that of Madeleine McCann, a British four year old girl who went missing on holiday in Portugal in May this year. She has not been seen since and there has been wild and vivid speculation as to what has happened to her. Madeleine's parents claim she was abducted, although this month they were named as "official suspects" by the Portuguese police, who are continuing their investigation into her disappearance.
Since May Madeleine's story has gone world-wide and is given a level of news prominence normally only associated with major world events. Indeed, if you log on to the website of the satellite broadcaster, Sky News, you will see in the news topic menu, the single word Madeleine in between UK News and World News. The Madeleine story is deemed to be so important it has its own category.
It seems we cannot get enough of the Madeleine saga. The liberal Guardian newspaper described it last month as "one of the world's biggest media storms." The article continued: "It is hard to overestimate the global reach of the McCann story. The Associated Press, which rivals Reuters as the world's biggest global news agency, took reporters away from a meeting of European Union foreign ministers in northern Portugal to cover the McCanns' sudden change of fortune at Portimao police station. The decision paid off. The AP story was the most-read story on many US newspaper websites that day."
One of its political commentators noted the dichotomy of the saga that is gripping millions: "The McCanns have now either suffered the cruellest fate imaginable - not only to have innocently lost their beloved daughter but also to have been publicly accused of a wicked crime - or they are guilty of the most elaborate and heinous confidence trick in history, deceitfully winning the trust and sympathy of the world's media, a British prime minister, the wife of the American president and even the Pope, to say nothing of international public opinion."
The media obsession with this story has now spiraled completely out of control, to the detriment of other news that is far more important.
Take Iraq. New research out last month calculated that there have been a total of 1,220,580 deaths since the invasion in 2003. A detailed analysis of the figures indicates that almost one in two households in Baghdad have lost a family member, significantly higher than in any other area of the country. The personal loss for a city on this scale is truly unimaginable. Nearly half the population has lost a mother, father, son, daughter, aunt, uncle, niece or nephew. Each death and loss is a human story of tragedy that is worth reporting. But the news of this tragic milestone was barely covered by the media.
Critics of the war have long argued that this carnage was caused by America's desire to get its hands on Iraqi oil. Their voices, often derided and dismissed by the mainstream media, have now found an unlikely ally. Alan Greenspan, the long-term head of the US central bank, has just published his autobiography in which he writes: "I am saddened that it is politically inconvenient to acknowledge what everyone knows: the Iraq war is largely about oil."
Greenspan argues that the removal of Saddam Hussein had been "essential" to secure world oil supplies, a point he emphasized to the White House in private conversations before the 2003 invasion of Iraq. He argues: "I thought the issue of weapons of mass destruction as the excuse was utterly beside the point". In the book, Mr Greenspan writes: "Whatever their publicised angst over Saddam Hussein's 'weapons of mass destruction', American and British authorities were also concerned about violence in the area that harbours a resource indispensable for the functioning of the world economy."
Just as the British and Americans continue to deny that Iraq was about oil, they and their allies continue to overstate the threat posed by Iran over its nuclear programme. Last month, the French Foreign Minister, Bernard Kouchner said that the world should be ready to go to war to stop Tehran getting nuclear weapons. "We have to prepare for the worst, and the worst is war".
The bottom line is that the US is preparing for war with Iran and has been for a couple of years. This is the view of Colonel Sam Gardiner, a retired military planner who also spoke at the Propaganda and Spin conference. In his speech he outlined the propaganda America used to invade Iraq and how it is building a propaganda campaign in order to justify an attack on Iran.
It is a message that Gardner has delivered before. Last year he testified before Congress that America had crossed the "red line" regarding the Iranians. A "red line" is an imaginary line a country crosses before another country has to act in response. He told Congress that Bush's rhetoric on Iran has changed significantly. America's red line with Iran used to be "we cannot allow Iran to develop nuclear weapons".
However, this had now been changed to "we cannot allow Iran to develop nuclear weapons, or the knowledge to produce such as weapon". Adding the last part of the sentence means that the "red line" has already been crossed, argues Gardner. "We have picked and are implementing the military option", he says. If Gardiner is correct, war against Iran is only a matter of time.
There are now others who see access to oil as another "red line" to attack Iran. Last month, ex-Secretary of State, Henry Kissinger wrote: "An Iran that practices subversion and seeks hegemony in the region — which appears to be the current trend — must be faced with red lines it will not be permitted to cross. The industrial nations cannot accept radical forces dominating a region on which their economies depend, and the acquisition of nuclear weapons by Iran is incompatible with international security". And why do our economies depend on the Middle East? Oil.
As they did with Iraq the hawks in America and Europe are pushing for a military solution in Iran. It is as if the lessons of Iraq have not been heeded. Luckily there are still influential voices that are urging caution. Last month, in a perceived riposte to the Bernard Koucher, the French Foreign Minister, the head of the International Atomic Energy Agency, Mohamed El Baradei, urged caution. "We need to be cool," he told reporters. "We need not to hype the issue."
What we do need to do is inform people of the real dangers of what could happen if America attacks Iran. And for that to happen we need the media to understand the seriousness of the situation. The media have a huge role to play in informing the world of the risks of an American-led attack on Iran. Following the fate of a little girl in Portugal may be gripping, but so is what is happening in the Middle East right now. And that should be the priority for the news desks, because if America attacks Iran the consequences would be terrifying.


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Blackfriars, an ancient Dominican refectory, is the home of the Art Department. This historic building is the powerhouse behind a host of artistic disciplines: painting, drawing, sculpture, ceramics, and textile design. There are two multi-purpose studios and a textile studio, the 'Cleary Gallery' for hosting exhibitions, and a departmental library/tutorial room.
Notable former pupils include the sculptor Henry Weekes (KS 1816-22), and the ceramicist Edmund de Waal (KS 1977-81) who in 2012 opened the state-of-the-art photography and pottery studios on nearby King Street. This consists of a ceramics studio, with plaster and sculpture area and kiln room, and a photography studio with digital suite, full film processing and dark room facilities.
Art and Design is taken by all Shell pupils. It is an optional subject at GCSE, where there is a choice between Art & Design or Photography courses. At A Level pupils can also choose between Art & Design or Photography.
The proximity of Canterbury to both London and Paris permits regular visits to art galleries and museums.
In recent years the Department has operated an Artist-in-Residence scheme, which gives an insight into the working methods of professional practitioners.
Director of Art:
Mr Peter Cordeaux
The Drama Department works in three studio spaces in the Milner Hall and in St Mary's Hall, the latter being used for major school productions and for examination performances.
Shells follow a half year compulsory programme of Drama lessons which leads to the IGCSE option of Drama in the Remove and Fifth Form years. In the Sixth Form Theatre Studies is offered as an AS and A level option.
The development of presentation skills, co-operation and team work lies at the heart of the IGCSE curriculum. Pupils learn through preparation of devised pieces and through performance of scripted extracts. Their analysis of theatre is assessed through an end of course written examination. Study in the Sixth Form builds on the skills previously acquired. Although an IGCSE in Drama is not a pre-requisite for A Level study, a passion for theatre is necessary as the course looks in detail at the practice of theatre from the viewpoint of an actor, a director and a designer. Performance is central to the 6b year, while a director's eye is developed through devised work in the 6a year. The course culminates in a written paper which focuses on the study of a prescribed text and conditions of period drama production.
The recently acquired Victorian Malthouse building, located close to the main school campus, is being transformed into a stunning Performing Arts Centre comprising a 334-seat theatre complete with orchestra pit, dance and drama studios, bar and dining facilities. This state of the art school facility will also be available for community use.
Director of Drama:
Mrs Rebekah Beattie
Academic Music is taught in the Edred Wright Music School.
Many former pupils have pursued a successful music career: Stephen Barlow (KS 1968-72), Harry Christophers (KS 1967-72) and Christopher Seaman (KS 1955-60) conductors, Michael Law (KS 1973-78) founder of The Picadilly Dance Orchestra, and Stephen Varcoe (KS 1963-67) classical bass-baritone singer and Sacha Skarbek (KS 1985-90) double Ivor Novello award winning songwriter and record producer.
Pupils in the Shell year follow a music appreciation course. Music is then offered as both a GCSE and A Level subject, with Music Technology also being taught at A Level.
Music plays a prominent part in the co-curricular life of the school through a variety of orchestras and choirs.
Overseas tours feature regularly: The Crypt Choir and Chamber Orchestra travelled to Rome in October 2017.
In addition to the information on the school website, the Music Department maintains its own website at The King's Music School.
Director of Music:
Mr Will Bersey

subset: commoncrawl


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Boots hit the floor.
Boots hit the floor.
A new day, a new dawn,
A journey across the turning sea
Turned one to three.
A new day, a new dawn,
And from that we sway through the slight breeze.
Only then will a mountain halt our march
As we travel over a timeline mark
Till we arrive at the end.
A new day, a new dawn,
The journey's done
For the end of the journey is a place we call Home.
--Nathan, T., 7th-8th Grade


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The IRA and the 401(k) I Comparing their features, merits, and demeritsSubmitted by Coastal Financial Advisors LLC on July 9th, 2019
How do you save for retirement? Two options probably come to mind right away: the IRA and the 401(k). Both offer you relatively easy ways to build a retirement fund. Here is a look at the features, merits, and demerits of each account, starting with what they have in common.
Taxes are deferred on money held within IRAs and 401(k)s. That opens the door for tax-free compounding of those invested dollars – a major plus for any retirement saver.
IRAs and 401(k)s also offer you another big tax break. It varies depending on whether the account is traditional or Roth in nature. When you have a traditional IRA or 401(k), your account contributions are tax deductible, but when you eventually withdraw the money for retirement, it will be taxed as regular income. When you have a Roth IRA or 401(k), your account contributions are not tax deductible, but if you follow Internal Revenue Service rules, your withdrawals from the account in retirement are tax-free.
Generally, the I.R.S. penalizes withdrawals from these accounts before age 59½. Distributions from traditional IRAs and 401(k)s prior to that age usually trigger a 10% federal tax penalty, on top of income tax on the withdrawn amount. Roth IRAs and Roth 401(k)s allow you to withdraw a sum equivalent to your account contributions at any time without taxes or penalties, but early distributions of the account earnings are taxable and may also be hit with the 10% early withdrawal penalty.
You must make annual withdrawals from 401(k)s and traditional IRAs after age 70½. Annual withdrawals from a Roth IRA are not required during the owner's lifetime, only after his or her death. Even Roth 401(k)s require annual withdrawals after age 70½.
Now, on to the major differences.
Annual contribution limits for IRAs and 401(k)s differ greatly. You may direct up to $18,500 into a 401(k) in 2018; $24,500, if you are 50 or older. In contrast, the maximum 2018 IRA contribution is $5,500; $6,500, if you are 50 or older.
Your employer may provide you with matching 401(k) contributions. This is free money coming your way. The match is usually partial, but certainly, nothing to disregard – it might be a portion of the dollars you contribute up to 6% of your annual salary, for example. Do these employer contributions count toward your personal yearly 401(k) contribution limit? No, they do not. Contribute enough to get the match if your company offers you one.
An IRA permits a wide variety of investments, in contrast to a 401(k). The typical 401(k) offers only about 20 investment options, and you have no control over what investments are chosen. With an IRA, you have a vast range of potential investment choices.
You can contribute to a 401(k) no matter how much you earn. Your income may limit your eligibility to contribute to a Roth IRA; at certain income levels, you may be prohibited from contributing the full amount, or any amount.
If you leave your job, you cannot take your 401(k) with you. It stays in the hands of the retirement plan administrator that your employer has selected. The money remains invested, but you may have less control over it than you once did. You do have choices: you can withdraw the money from the old 401(k), which will likely result in a tax penalty; you can leave it where it is; you can possibly transfer it to a 401(k) at your new job; or, you can roll it over into an IRA.
You cannot control 401(k) fees. Some 401(k)s have high annual account and administrative fees that effectively eat into their annual investment returns. The plan administrator sets such costs. The annual fees on your IRA may not nearly be so expensive.
All this said, contributing to an IRA or a 401(k) is an excellent idea. In fact, many pre-retirees contribute to both 401(k)s and IRAs at once. Today, investing in these accounts seems all but necessary to pursue retirement savings and income goals.
For more information, contact Coastal Financial Advisors today!
This material was prepared by MarketingPro, Inc., and does not necessarily represent the views of the presenting party, nor their affiliates. This information has been derived from sources believed to be accurate. Please note - investing involves risk, and past performance is no guarantee of future results. The publisher is not engaged in rendering legal, accounting or other professional services. If assistance is needed, the reader is advised to engage the services of a competent professional. This information should not be construed as investment, tax or legal advice and may not be relied on for the purpose of avoiding any Federal tax penalty. This is neither a solicitation nor recommendation to purchase or sell any investment or insurance product or service, and should not be relied upon as such. All indices are unmanaged and are not illustrative of any particular investment.
Investment advisory services are offered through Foundations Investment Advisors, LLC, an SEC registered investment advisor.


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We Wish You Christmas Cards
$12.00 – $32.00
We Wish You Christmas Cards
$12.00 – $32.00
|8 or 24 folded cards with envelopes
|4.25 x 5.5 inches
|100 lb. cover stock with blank interiors
We wish you a Merry Christmas! Each hand illustrated card features a classic Christmas sentiment in hand lettered calligraphy over a bright Christmas tree topped with a twinkling star. Sets are printed in full color with blank interiors and packaged with white envelopes in a clear resealable sleeve.


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Run Modern Kitchen
For decorative things on white cherner counter stools contemporary kitchen, simply put small vase with single blossom so you still can speak and face each other across the vase.
L-shaped as its name, has L shape for the kitchen. This shape will suit for those that have small space for the kitchen. There are many designs which may be used. For instance white kitchen with island. If you employ this design, this will maximize the space because when apply L shape, it means there will be empty space on the center of the space and it may be used for island or even consume . Separate the 1 foot of L for the heating and cleaning along with the other one for the storage spaces. However if the L is used together with island afterward the cooking area or the cleaning region can be put there.
Discussing about kitchen appliance packages, the packages usually contain refrigerator, microwave oven, range and dishwasher. You simply have to pick the brand which matches together with your will. Thus, you ought to know the ideal brand that may make you fulfilled when working with kitchen appliance package of this new. Those are some advice for you personally concerning kitchen equipment packs homedepot. You have to consider the bundle you will chose ahead of visiting homedepot. And afterward, you can choose the best one among white cherner counter stools contemporary kitchen that matches your own demand.
The very best part of kitchenAid's offer is the dishwasher that's very silent with just 3-9 decibels. Additionally, it offers zone concentrated sprays to assist cleansing stubborn stains. The French door refrigerator using Star vitality tech additionally becomes still yet another great feature inside this white cherner counter stools contemporary kitchen.
Use two clean cloths when you re-oil the dining table and seats. Use first cloth to oil the table and seat. Leave oil sit for 10 minutes. Then use second cloth to wipe oil. It may a hassle to do this and make your elbow fatty, but it sure make your white cherner counter stools contemporary kitchen stay shining and look great.
Kitchen is one of the most important part in a home, this is the place where the occupant especially who with so many families use. Therefore, the layout, furniture and others kitchen stuff must pay for all the needed without reduction its look and visual appeal. Among so many options that are accessible, white kitchen will be a part that produces the kitchen appear unusual and make it more comfortable than before.
The simplest KIWOTE is by simply following the theme and select the right colour. Besides that, how and where you put the furniture and the other stuff also will affect. This will determine the end result of the plan.
white cherner counter stools contemporary kitchen getting Guides
Minimalist layout and style of kitchen household furnishings will be the first important factor for youpersonally. This form of design and style may help you to support the contemporary minimalist concept of your house. You may already probably know, minimalist-style will be dominated with white and black shade. Thus, you will color your kitchen look with white and black ribbon. In this instance, you may also support other things within your kitchen by black and white colors.
This White Cherner Counter Stools Contemporary Kitchen the gallery form White Kitchen Stools. Hopefully you can find the best inspiration from our gallery here.


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United States President Donald Trump's son-in-law Jared Kushner's proximity to Saudi Arabia is well documented, and when Qatar discovered that they might have unintentionally bailed out a building owned by Kushner's family, it created a bit of a stink. Saudi Arabia's crown prince Mohammed bin Salman counts Jared Kushner among his key advisors. Considering the fact that Saudi Arabia was responsible for the boycott of Qatar and Kushner is close to the Saudis, the Gulf nation has now decided to revamp its investment strategy. The Saudis had accused Qatar of financing terrorist activities.
Qatar has used its considerable wealth in investments throughout the world, and all of it is managed by the Qatar Investment Authority (QIA), one of the world's biggest sovereign wealth funds. The fund manages around $320 as of today, and much of its money for real estate investment has been placed with the Canadian property investor Brookfield Asset Management. It has now emerged that in 2018, Brookfield completed a deal in which the Kushner family's imperiled tower located on Fifth Avenue was bailed out. In 2007, Kushner's family had acquired the tower for $1.8 billion, but that expenditure severely hamstrung the business. The debts mounted and it was only in 2018 that Brookfield came up with a package to take it off their hands. Although the financial details of the deal have not been disclosed, Brookfield apparently got a 99-year lease on the tower and made the entire payment at one go.
It has come as a source of consternation in Qatar, and although no one at QIA made any comment, it has now become clear that a change in investment strategy is going to be implemented. Broadly, the powers that be in Qatar have now decided that the QIA is only going to put its money with investment vehicles over which they have some sort of control. A source who spoke to Reuters, said, "Qatar started looking into how its name got involved into the deal and found out it was because of a fund it co-owned. So QIA ultimately triggered a strategy revamp."
The QIA owns 9% of Brookfield Asset Management, but the deal was down through a subsidiary known as Bookfield Property Partners. The shift in strategy was apparently decided upon by the authorities in Qatar last year, but it is important to note that a change in strategy from the QIA could have far-reaching consequences at a global level. The sovereign wealth fund has been responsible for billions of dollars in investment in the United States and Europe over the past decade, or so and hence, this change in strategy is going to be watched closely by people across the world. The QIA had also engineered bailouts for banks in the United Kingdom and Switzerland at the height of the financial crisis back in 2008.


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Make It Happen...Online
eBook (PDF), 289 Pages
Price: $19.95
A comprehensive guide to Making It Happen...Online. Whether you are just starting your own online business or taking your existing Internet business to the next level, this guide will catapult you above and beyond basic creative marketing strategies as successfully proven by a guy who started working out of his garage and has done more than $15 million in online sales.
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Product Details
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- Louis Jay (Standard Copyright License)
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- First Edition
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- Louis Jay Silberman
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- September 30, 2011
- Language
- English
- Pages
- 289
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- 17500089
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Susi was born, and also adopted, in Boston Massachusetts, then raised in Pittsburg, PA along with her 2 adopted siblings. After graduating from the Winchester-Thurston School, she attended Gordon College in Wenham, MA. There she met her husband, Gary, to whom she has been married for over 25 years. They have 2 sons whom Susi homeschooled to graduation. Susi spent a number of years working for American Express in Boston, then worked several years in a county social services office in North Dakota. She still reports that her favorite and most fulfilling job was being a stay-at-home Mom. Susi has been involved in youth ministry for many years through Young Life and at Calvary Lake Ozark church. Her unique life experience as someone who has struggled with past trauma and attachment issues is just part of the reason she feels so at home at Calo. She loves to see young people and their families find healing and joy. Susi often tells people that since beginning her journey at Calo in 2010, she has never "gone to work", and considers this her second home. She cannot imagine "working" anywhere else!
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I just saw Disney's Tangled over the weekend and I was amazed at how great it was! Looking back, I think the marketing for the movie was pretty terrible, because I had no idea what I was missing! Now I'm on the lookout for hot deals for pre-ordering Tangled, and I think I found one:
Right now Amazon's offering an extra $10 off when you buy the Tangled Blu-Ray/DVD combo and one other Disney Blu-Ray/DVD combo. Disney's Beauty & the Beast is just $14.99 right now, and Tangled is available for $27.99. That means you'll get Tangled and Beauty & the Beast in DVD and Blu-Ray format for just $32.98 after the $10 discount is applied at checkout!
Another perk of the deal: you'll get a free $5 Amazon video-on-demand credit when you buy either one of those DVDs. The credit will come in the form of an Amazon coupon code that will be emailed to you after you buy these DVDs.
Finally, the Tangled Blu-Ray/DVD set is currently priced for pre-order at $27.99. If the price happens to drop between now and when the movie is released and shipped to you, you'll automatically get the lowest price for the DVD. That means you can place your order now and you won't have to worry about future price drops!


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The Color Purple
3826 views
Celie Johnson gives birth to a child at the age of only 14. She has been abused by her father and the child is his. When the second child comes, her father forces her to leave the child and come to live with "Mister" - a local farmer. Later, with the help of "Mister"'s lover, Celie gets united with her 2 children and her sister.
Genres: Drama
Actors: Danny Glover,Whoopi Goldberg,Oprah Winfrey
Directors: Steven Spielberg
Country: United States
Duration: 154 min
Quality: HD
Release: 1985
IMDb: 7.8


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Action Plan for the Implementation of Recommendations from Money Laundering Risk Assessment and Terrorism Financing Risk Assessment
Home > Activities > News
APML signs MOU with FIC of South Africa
Friday, 24 August 2012On 24 August 2012, Mr. Aleksandar Vujičić, Head of Serbian FIU, signed an MOU with the Financial Intelligence Centre of South Africa. The MOU will serve to raise the level of cooperation with this FIU to an even higher level. This is Serbian FIU&rs ... ... More
First ACAMS seminar in the Western Balkans
Monday, 20 August 2012Association of Certified Anti-Money Laundering Specialists ACAMS (Miami, USA, www.acams.org ) is organising the First ACAMS Seminar in Wester Balkans Region to be held in Belgrade from 25-26 February 2013. For more information go to http:/ ... ... More
Application to sit the professional examination in Pančevo
Tuesday, 7 August 2012The professional examination for legal entities and entrepreneurs offering accounting services in the region of south Banat will be held in Pančevo on 4 September 2012 on the premises of the Pančevo Regional Chamber of Commerce, at 1a Zmaj Jovina S ... ... More
BECA competition acknowledgment
Friday, 13 July 2012During the 20th Egmont Group Plenary held from 9 to 13 July 2012 in Saint Petersburg, Russian Federation, the Administration for the Prevention of Money Laundering was commended for its presentation of a specific money laundering case that it had suc ... ... More
Implementation of the AML/CFT Law by Postal Service Providers
Thursday, 12 July 2012Serbian Chamber of Commerce and its Transport and Telecommunications Association organized on 12 July 2012 an interactive presentation on some specific aspects of application of the Law on the Prevention of Money Laundering and Terrorist Financing by ... ... More
APML signs 4 MOUs
Wednesday, 11 July 2012On 10 July 2012, during the 20th Egmont Group Plenary in Saint Petersburg, Russian Federation, Mr Aleksandar Vujičić, director of the Serbian Administration for the Prevention of Money Laundering, signed four memorandums of understanding concerning ... ... More
Serbia Leader in National ML Risk Assessment
Friday, 6 July 2012Serbian delegation on the Council of Europe MoneyVal Committee continues with successful work. Serbia is amongst the first countries to undergo a national money laundering risk assessment. On 6 July 2012, at the invitation of the MoneyVal Committee, ... ... More
39. Plenary Meeting of Moneyval
Thursday, 28 June 2012In the period between 2-6 July 2012 the 39. Plenary Meeting of the Council of Europe Moneyval Committee will be held in Strasbourg. The Serbian delegation consists of th representatives of the Administration, Ministry of Interior, Ministry of Justice ... ... More
Professional exam postponed to 28 June 2012
Friday, 15 June 2012The professional exam initially planned for 27 June 2012 will actually be held on 28 June 2012. The exam will take place at Belgrade University's Law School, at Bulevar Kralja Aleksandra 67, amphitheatre no 5 on 1st floor. Candidates will be in ... ... More
Terrorism Financing Risks in NPOs
Monday, 11 June 2012On 14 June 2012 in Belgrade a workshop on money laundering and terrorist financing risks in NPO sector (that is, in associations and civil society organizations) will be held, risks which albeit present seem to be insufficiently addressed, both by so ... ... More


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Posting: 049
Morality, Taxation, and Morning Coffee
This is a special edition of the Arnold Report, jointly prepared by Brian Arnold and Larry Chapman
Over and over again the courts have said that there is nothing sinister in so arranging one's affairs as to keep taxes as low as possible. Everybody does so, rich or poor, and all do right, for nobody owes any public duty to pay more tax than the law demands: taxes are enforced extractions, not voluntary contributions. To demand more in the name of morals is mere cant. (159 F 2d. 848 (2d Cir. 1942)).
While believing that all taxation is state-sanctioned "theft" may "outrageously nutty", I question whether if it still "nutty" to view incremental taxes(e.g., temporary surtaxes on high income) in that light.
Brian, I'm concerned about the use of "we", particularly in respect of the "libertarian" comment. Who is "we"? If you mean the entire body of the CTF, I am certain you lack unanimity on that point, or even necessarily consensus.Tax may be the price we pay for a civilized society, but government is the great fiction through which everybody endeavors to live at the expense of everybody else [Frederic Bastiat]. Seen in this light, tax is at best a game played for advantage by everyone, and at worst, legalized theft by the politically astute (or lucky).
KevynSorry for the confusion. The recent addition to the posting hopefully will clear it up. This version of the Arnold Report is a jointly prepared opinion piece written by Brian and me (Larry Chapman). Hence the frequent use of "we" throughout the text. It represents Brian's and my personal views and is in no way intended to be an expression of the collective views of the Canadian Tax Foundation. Brian and I hope that this report will spawn a less simplistic debate than has been seen to date in the media which has overlooked the complex issues involved in finding the difficult and often imprecise boundaries of acceptable tax planning. Larry
This piece is extraordinarily useful for starting an informed and intelligent discussion around the issues. I know that reading The Arnold Report is one of privileges of membership in the CTF, but if you'd like your call to action to resonate with the media, you may wish to consider making this particular piece more widely available.
Most advisors do not want to be associated with planning that is not successful in court. That used to provide a reasonable limit to what got sold. Around 25 years ago, the courts swung towards "if it's not prohibited by specific words, it's fine", removing that limit. It put professionals in a bind, since many things that have an aroma of artificiality (weak currency loans?) provided great tax savings, to which their clients were entitled. How could they not participate in finding the next scheme? A lot of tax advisors would probably be overjoyed if the courts (buttressed by legislative amendments?) retired the Duke, struck down some planning and allowed them to act more as professionals and less as sales agents for magic beans.
April 29, 2013Dear Brian and Larry:The topic of morality and tax practice is one that surfaces periodically. I recall that one of my earliest appearances on a CTF Annual Conference panel (1976) was on the subject of "Professional Responsibility in Tax Practice." Let me add a few comments to those that your note is provoking.I believe the tension here is due to the very uneasy marriage of our moral obligation to share in the cost of maintaining the community in which we live and our legal right to minimize our own taxes. This is in many ways a forced marriage because as individuals we have very little practical input into how the taxes we pay benefit our communities, but we do have the legal right to take steps to minimize the taxes that are levied to support them. Add to that the fact that the parties to the marriage are far from perfectly reasonable, and often disagree on what is morally right, and you have a very confused public when it comes to questions such as the ones raised in your note. I'm not smart enough to provide a philosophical answer to the question: what's my fair share of the tax burden? But I do have some thoughts about it.My starting point is the belief that you don't get very far in trying to legislate morality. So trying to define a "fair share" that each of us should pay on moral grounds is doomed to failure. Some people think taxes are too low, others think they are too high. In this context, I don't want my obligation to pay based on either of their personal beliefs. For me, this is what the rule of law is about when it comes to taxes. I don't think we should apologize for saying, as we do as tax professionals, that tax planning is a morally neutral activity. Anything else leaves us at the mercy of the politics of the mob.The logical consequence of this view is that some of us will be perceived as paying less than we should, notwithstanding that our actions are perfectly legal. So be it. As Starbucks is learning, loss of reputation can be harmful to your (business) health. I happen to think that the way Starbucks has chosen to respond is naïve, but that's not the point. If they feel shamed into contributing something more to the public purse, then they are morally free to do so. But their response should not be taken as a condemnation of anybody else's right to take a different approach to tax planning.Let me conclude (at least for now) with a comment about the tax advisor's role as enabler. Each of us will have a personal view as to what is acceptable when it comes to tax planning. I don't believe that the more aggressive minded among us need apologize. It goes without saying in this discussion that we are talking about planning that does not cross the line into evasion. We should feel free to advise on aggressive tax plans as long as we continue to respect this line. However, it is not just the client that has to be concerned about reputational risk. Tax advisors should also expect to be examined in public when their involvement in aggressive planning becomes known. But it is up to each of us to decide whether accepting that risk is worthwhile in any particular case, not because of a misplaced sense of moral obligation, but based on our own view of what is appropriate to do in the circumstances.Thomas E. McDonnellThorsteinssons LLP,Toronto
Here are my random thoughts, not over coffee but over a fine Woodford. And I preface my comments by saying that ethics is far outside my area of expertise, which at every Budget seems to barely cover tax. I fully agree that characterizing taxation as theft or confiscation is unhelpful in this debate because it leads to a fallacy. In a democracy, if taxation were a form of theft then citizens would be stealing from themselves to redistribute the funds back to themselves. I think governments legislate morality all the time. Isn't the Criminal Code based on what society thinks is immoral? Isn't the Charter based on what society thinks is moral? Isn't the in-field fly rule in baseball based on fairness to the base runner? Religion is often cited as the source of morality. With respect to the issue of whether there's a moral obligation to pay tax, the Bible is no help. There's no eleventh commandment Thou Shall Pay Tax! Unless it was on the third tablet that Moses broke in Mel Brooks' History of the World Part 1. Regardless, it didn't make it into the final version of the Book.If ethics is to help distinguish right from wrong, then doing no harm would seem to be a guiding principle. If no one paid tax, then the negative consequences seem obvious. It seems to follow that if not paying tax would be harmful, then one could conclude it's immoral. Conversely, paying tax is moral because it is beneficial.However, harm may depend on what the tax authority does with the money. At the sake of proving Godwin's Law, arguably it was immoral for Germans to pay tax to the Nazi regime (and therefore moral for them to reduce tax). It would follow that it's moral for citizens to pay tax in a free and democratic society where the tax authority uses the money for a beneficial public purpose. I question whether spending $10 million on the Shania Twain museum in Timmins was a beneficial public purpose, but let's just leave it that "beneficial" is an elastic concept depending on the eye of the beholder. Like GAAR.On the other hand, the example of paying tax to fascist regimes versus democracies assumes the taxpayer has the freedom to make the ethical choice to pay the tax. Choosing to pay tax to the Nazis would be immoral. However, the question of moral choices would seem to go out the window if citizens in either 1943 Germany or 2013 Canada are compelled to pay the tax. If taxpayers can go to jail for non-payment of tax, then in paying the tax have they really made an ethical choice? I think not.In fact, in distinguishing a gratuitous payment from a tax, Canadian courts have said that the essentials of a tax are that (1) it must be enforceable, (2) imposed by a public body under legislative authority and for a public purpose, and (3) compulsion is an essential feature. (Meyer v. The Queen 2004 TCC 199).It seems, then, that it may not be possible to conclude whether there is a moral obligation to pay tax. If one is compelled to pay the tax, then it's not a moral choice. It wasn't immoral for Germans to pay tax then and it's not moral for Canadians to pay tax now – they have to pay it.And if there is no compulsion, then it's a gratuitous payment and not a tax at all!Which leads me to think that if paying tax is not a moral choice, then the only framework is what the law allows and requires. Judge Learned Hand captured it precisely when he said that no one owes a public duty to pay more tax than the law demands. That also means the fisc can enforce no more tax than the law requires. Tax planning, even aggressive tax planning, is legal. Robert KepesMorris Kepes Winters LLPToronto
Dear Brian and LarryI have read with great interest your thoughts on morality and taxation, and the thoughtful comments that have been offered in response. As a tax professional of more years than I care to remember, advising clients from multi-nationals to shopkeepers, I have frequently wrestled with this issue on a practical as well as philosophical basis. With regard to the latter I fully subscribe to the principles outlined in your article.It is the application of these principles in practice that is more troubling to me. Generally speaking I have had no trouble with aggressive tax planning except when it is designed to achieve results that clearly are contrary to the spirit and intent of income tax law. As Brian well knows from his involvement with the development of GAAR, clearly delineating this spirit and intent is often the problem. That is where the rubber meets the road, so to speak!Terry WichmanDube & Cuttini
You went to lunch with about twenty other tax practitioners. Everybody ordered several courses; you had four. At the end, one bill came for everyone. Larry and Brian decided that the only fair way to divide it was that everyone pay $25 for each plate they had ordered, regardless of what each one actually cost. You kicked in $100. But when Larry and Brian totalled the cash, it was short. They told everyone to kick in another $5, which you did. As you were all leaving, a smiling colleague commented to you that it had been a great $5 lunch. When you looked surprised, he explained that the direction from Larry and Brian had been to pay for each plate he ordered. "I ordered food. It came on a plate, but I did not order the plate. So I didn't have to pay anything on the first round. I only paid the $5." "Goodness" you replied "that IS a valid interpretation of what they said. That was very clever of you, and I admire your creativity!"When 33 million Canadians share the meal, and the directions of what each diner is to pay get more complex, it is less obvious but no less true that one person's excellent tax planning increases everyone else's lunch tab. It's legal. But what would you really have said to that colleague? It goes to Thomas' comment about what is appropriate.
Every once in awhile I search back to see if anyone has come up with any refutation of Phil Jolie's very simple way of framing the issue. So far, no one has. A question not addressed by Jolie is what is the "fair share" of each citizen. In his example, it is rather simple, everyone would agree that the "fair share" was $100 per person (with the possible exception of the one who not only contributed just $5 but admitted to it). Much of this is how we look at the world, whether we have a Hobbesian view of life that it is a "dog eat dog" world and "every man for himself" or whether we take a more positive view of our social contract with the state by recognizing that we get a lot out of our society and it is only right that we contribute our "fair share" to maintain it. So who then determines "fair share"? In a democracy that determination has to be made by our elected representatives. If you do not like the government we have then either you become active politically to change the government or its policies or you search for another country that is more to your liking. If you prefer living on an isolated island in the Caribbean then that is your choice. Adios. Just pay your bill when you leave. I do not think we have the right to decide for ourselves what is our "fair share" and then engage in aggressive tax planning to get our tax burden down to what we personally consider to be an acceptable level. That is anarchy. People who use this justification to engage in tax avoidance for themselves or their clients are in my mind no different (or better) than the "sovereignists" who dot the country burning their driver's licences and denying that they are subject to the laws of Canada. For tax professionals there is obviously a difficulty with discussing morality in tax practice and this may explain why not many tax practitioners have taken up the offer by Brian and Larry to engage in this discussion. Large fees are not made by advising how to stay within the spirit of the Act but instead how to avoid the provisions of the Act in a way that does not land your client in jail or subject to large penalties. When did we start using the term "filable position"?There are only two rationalizations I have seen for engaging in tax avoidance. First of all, by "tax avoidance" I mean taking steps that are clearly outside the spirit of the Act. I find the term "abusive tax avoidance" as too pejorative. "Tax planning" is the term I would use for steps that are within the spirit of the Act. One can argue whether a Singleton transaction is or is not within the "spirit of the Act" but how many tax practitioners felt that the Lipson transaction (turning an anti-avoidance provision "upside down" to use the words of Bowman CJTC) was within the "spirit of the Act"? Without being disingenuous, I suspect there are not many who believe that "reverse attribution" is within the spirit of the Act (although admittedly this "not many" does include Binnie J. in Lipson).The first rationalization for engaging in such tax avoidance is that the Act is a very detailed statute and who knows what any specific provision means until the Supreme Court of Canada tells us? But we have moved past the "literal interpretation" approach of Shell Canada and Antosko and since Canada Trustco the Supreme Court of Canada has made it clear that the provisions of the Act are to be given a "textual, contextual and purposive interpretation". After Canada Trustco should not any tax professional have to be fully satisfied in his mind that his tax plan accords with the "spirit of the Act"? In other words, when advising or writing an article on a "planning opportunity" should there not be a discussion in the advice or article as to why the "planning opportunity" accords with the "spirit of the Act" using a textual, contextual and purposive interpretation of the relevant provisions? The second rationalization for such tax avoidance is the attitude that I have described above which allows the planner to justify taking steps that the planner knows are outside the spirit of the Act as a way of fighting back against an intrusive state. This rationalization is not openly admitted but seems to underlie a lot of the justification for tax avoidance at least in its more aggressive forms. As argued above, this cannot be a legitimate reason for engaging in tax avoidance. To be engaged in a tax plan that the planner believes is outside the spirit of the Act is, in my view, not moral. Yes, it is immoral. There, I said the word. PS. With respect, I do not agree with Thomas McDonnell's comment above that the line on "aggressive tax planning" is drawn at whether the advice can be construed to be counselling tax evasion. Certainly, as a lawyer, the ethical test is one that requires a lawyer not to counsel someone to contravene the law, not just the criminal law. There is no question that the line is not clearly demarcated when attempting to interpret a statute using a TCP approach but surely the line is not just where you cross into tax evasion.
The previous contributor to this thread (9/17/2013) raises an important question about the morality of tax planning. I have some thoughts on this, and on Phil Jolie's post of 5/2/2013 in which he sets out an example of what he suggests is unacceptable tax planning. First to the question of whether tax planning is immoral. The previous contributor suggests that it is, based on his definition of tax avoidance as involving steps that are clearly outside the spirit of the Act. I have difficulty with this hypothesis. Speaking generally, we speak of a moral act as one that is "right," in the context of an action being either right or wrong. What do we mean by right or wrong? The answer may depend on the subjective views of the questioner. Some actions are accepted as morally as well as legally wrong in this country - murder is an easy example. But others are not so clear. For example, some people believe that consuming alcohol is immoral. While most in this country do not, those that do feel pretty strongly about the wrongness involved in drinking. In this example, the determinative factor in deciding whether an action is immoral is essentially a subjective one. I don't think this sort of subjectivity is an appropriate way to measure the consequences of an action governed by a statute such as the Income Tax Act.Consider another example. Some people feel pretty strongly that personal tax rates ought to be higher than they are now (or lower, if you prefer). Does either belief make the current rate structure immoral? I don't think so. Why not? - Because the current rate structure is the one in force as a matter of duly enacted law. So suppose I file my tax return and apply a higher rate to my taxable income than required because I personally feel an obligation to pay a higher rate of tax. May I be accused (among other things) of acting immorally? I very much doubt it. But this illustrates (to me) the danger of looking at tax decisions as either moral or immoral. That characterization depends on a personal, rather than an objective, standard and as such is of little relevance where the consequences of an action are dictated by law. To anticipate my conclusion here, a tax avoidance step of itself is neither moral nor immoral. The only objectively relevant question here is whether the step is based on a supportable interpretation of the Act. This brings me back to the previous contributor's definition of immoral tax planning as one that involves steps that are clearly outside the spirit of the Act (my emphasis). This recognizes that there is often uncertainty whether a particular step is, or is, not in accord with the spirit of the Act. I assume that the contributor would agree that where the interpretation is unclear, there is nothing morally offensive in adopting a position that is favourable to the taxpayer. A more difficult case is one in which the plan depends on an interpretation that the planner feels is contrary to the spirit of the provision, but is nonetheless open on a literal reading of it. An example of this might be the case where Parliament did not consider the fact situation when the provision was enacted. The planner says to himself: it's clear to me that Parliament never would have left this gap if they had been aware of this particular set of facts. But he proceeds with his plan on the basis that the courts have been clear that it's not the court's job to fill in the gaps in the guise of interpretation. And let us suppose, as was the case in Spruce Credit Union, or in Collins & Aikman, that the CRA disagrees but the court refuses to support CRA's interpretation of the provisions. On what basis could it be said that the planner had acted immorally in putting forward the plan? As determined by the court, the steps involved were in accordance with the provisions of the Act then in force. But suppose the court does find for the CRA, does this make the plan retroactively immoral? It means that the planner was wrong in thinking there was a gap in the Act, but is this the kind of wrongness that we want to describe as immoral? What does saying so add to the argument against aggressive tax planning? Not much in my view, so I disagree with the contributor's analysis on this point.Although I disagree with the suggestion that it is useful to label certain types of tax avoidance as immoral, I do think that such planning raises a different question, which I would put as follows: assuming a tax plan that is on the right side of the planning/evasion line, are there nonetheless non-moral constraints on proceeding with it? I think there are and that they can be found in the ethical standards that govern the legal and accounting professions. Both groups require their members to act with integrity and good faith. As a lawyer, I am ethically bound to advise my client on what the law is. If there is some uncertainty about its application in a particular case, I must advise accordingly. It's not my professional responsibility to suggest that the client act in accordance with what the law might or should be. If I honestly believe that a certain position is supportable, even if I think it may not be a clear winner if it is taken to court, I should advise my client of this, and am ethically free to assist if the client decides to proceed with the plan. The fact that some other person may characterize the plan as aggressive (and immoral) is irrelevant. The ultimate approval of the planning in the Canda Trustco Mortgage and the Shell Canada cases illustrates this.But there will be other times when I believe that a proposed tax plan is not supportable on any reasonable basis. If so, I am ethically bound to so advise the client and to refuse to assist in implementing it. An example might be an individual or a Canco that wishes to reduce Canadian taxes by setting up an offshore subsidiary in a tax haven. If I believe that the client will not take the steps necessary to make the subsidiary legally and factually resident in the haven, but will file tax returns as if it were, then I cannot ethically assist in the implementation of the plan.With these thoughts in mind, let me turn to the example of unacceptable planning postulated by Phil Jolie in his comment of 5/2/13. Phil says that the colleague who refused to pay for lunch on the basis that Larry and Brian asked for a payment of $25 "per plate" and he only ordered food, not a plate, was complimented by Larry and Brian for his creativity and cleverness on the basis that his interpretation of "plate" was a valid interpretation of what they said. I don't think so. Brian for sure and probably Larry, too, would have pointed out that "plate" is to be interpreted by applying a textual, contextual, and purposive analysis. Clearly, the clever colleague did not intend to buy a "plate;" he was only interested in the food that was served on it. The clearest indication of this is the fact that he didn't leave the restaurant with the plate! I think the colleague would be forced to admit that his purported interpretation was unsupportable. So I don't think this example adds much to the discussion. But Phil uses the example for another purpose, which is of a more serious nature.He says that when one taxpayer reduces tax otherwise payable in some way, the rest of us have to pay more to make up the shortfall in revenues. Conclusion: those who actively plan to reduce their taxes are not acting in the best interests of society as a whole. This is superficially appealing, but I don't think it stands up to analysis. Suppose, for example, that I make a contribution to a RRSP. This entitles me to a deduction. If I reduce my taxes by claiming the deduction, am I acting contrary to the best interests of society as a whole? If you answer yes, then you're really saying that each of us has an obligation to maximize our taxes by not claiming deductions otherwise permitted. Isn't the conclusion to be drawn from this that I act properly whenever I claim a deduction (or credit, or favourable characterization of an amount) allowed by the Act? If so, the issue here isn't one of morality, or ethics. As long as the claim for the deduction, etc. is supportable, nothing is gained by attaching some other label to it. What is important here is the principle that in a democratic society such as ours, we are governed by the rule of law. If, as a society, we don't like the way the law operates in a particular case, we change the law. But when we act in accordance with the law as it is, we should not be criticized on the basis of some alleged moral or ethical principle.Thomas E. McDonnell Thorsteinssons LLP, Toronto
I would first like to commend the above tax practitioners for engaging in this debate. As a lawyer who does not practice tax law but who has a reasonable understanding of the Income Tax Act, I find that I am in the unique position of not being on either "side" so to speak. I have to admit that I often tend to find myself on the Phil Jolie side but on the other hand I fully understand that we have to have a system that does ensure certainty and predictability for the taxpayer. As an aside, I do wish that commentators on decisions on GAAR would limit their constant references to the House of Lords 1936 decision in Duke of Westminster and focus on the requirement that the rule of law requires that its citizens are able to plan their affairs knowing what the tax consequences of those actions will be. I find it especially ironic that the 80 year old Duke is quoted when the House of Lords itself has at least in one of the Ramsay line of cases questioned whether the Duke would have fared so well today in England given the changing views (morality?) about what is and what is not acceptable tax planning. No one argues that a taxpayer has a right to arrange his affairs to reduce the amount of tax payable as long as he plays within the rules. The devil is in the details.Where I disagree with a number of commentators is that the law must be clear and concise when we are dealing with transactions that have a primary focus on reducing tax rather than simply carrying out a commercial transaction. I would have thought that this is exactly where there should be a "fuzziness" to discourage such transactions. What public purpose is served by having clear words to assist in aggressive tax planning? The key issue is to ensure that our laws allow most commercial transactions to proceed without hindrance from uncertain provisions. In my corporate commercial practice it is very seldom that the provisions of the Act create a level of uncertainty that in any way impacts the progress of business. It is only when tax accountants and lawyers attempt to recast the transaction in some way to make it more "tax-efficient" that questions arise. Having said this, it may be argued that the Canada Trustco and Copthorne decisions on the extended definition of a "series of transactions" have complicated too many legitimate commercial transactions. So back to morality. Is there a place for morality in a day to day tax practice? I appreciate that Brian Arnold's question starts out asking as to whether there is a moral obligation to pay tax. I think the more interesting question is whether tax professionals, accountants and lawyers, have a moral obligation not to assist clients in a transaction that they believe to be contrary to the law. Of course, if the law is unclear then things are rather simple. There is no question that in the "real world" outside of the two professions, there is a strong belief that tax advisors have assisted their clients to avoid paying what should be their "fair share" (whatever that means). When the leaders of the OECD have on their agenda "Agressive Tax Planning" you know that they are not happy with the lawyers and accountants who assist in these transactions. As well, we have the "advisor penalties" in our Act and, although I am not familiar with the specifics, I understand that the IRS has rules that will limit certain advisors from practising US federal tax law if they have previously engaged in aggressive tax planning. So I find it hard to say that issues of "right and wrong" (ie morality) do not enter into the world of the tax planner unless he has blinders on. Morality may be subjective but when a majority hold the same moral views they often become the law.Having argued that "morality" should enter into a consideration of what a tax planner should or should not recommend to his or her client, the question is then how does it impact tax planners. For professionals, our legal "morality" is based upon the ethical requirements of our profession. I appreciate that Thomas McDonnell has above made a distinction between morality and "non-moral' constraints" in which he includes (or equates) ethical standards. I think that the ethical standards of a profession have their underpinning on morality so I think we are talking about the same thing. But I would agree with him that what I would call our "legal moral obligations" are those found in our ethical standards. But when we discuss the ethical standards of a lawyer there are two duties. The one he rightly points out is the duty to fully represent the interests of the client and provide him with full information on his rights and not exclude some option that you find morally objectionable. However, an equally important ethical requirement for a lawyer is his or her duty to the state to uphold its laws and not to participate in transactions that are intended to get around those laws. I have often thought for that reason that tax litigation was a much easier area for lawyers than tax planning.I will follow up on what I think the duties are of a lawyer whether they are cast in the terms of ethics or morality but I would first like to suggest some areas of interpretation of the Act where tax planners do have some moral or ethical issues that they have to face. There are in my mind at least two principal ways in which the Act may be unclear. The first is where a specific provision of the Act could apply literally to a particular transaction but on a textual, contextual, purposive analysis, the advisor is quite sure that the provision was not meant to apply. Matthew is an example of this kind of uncertainty. The second is where there is clearly a "gap" in the legislation. Had the drafter thought about the fact situation, he would have dealt with it but he did not consider it. I would put Copthorne in this category.I would tend to agree with some of the commentators that in the Copthorne case there is a serious question as to whether GAAR should have been extended to "fill in the gap" based upon a textual, contextual and purposive interpretation of the provisions dealing with paid up capital. I would have no problem in representing a client wishing to preserve its paid up capital in that situation, advising the client that there could be a risk under GAAR. I think "fill the gap" cases at least in the past were much easier to deal with. But given Rothstein J's approach to GAAR in Copthorne they may become somewhat more difficult because my reading of Copthorne suggests that Rothstein J is returning to his analysis found in the OSFC decision. This would suggest that the Supreme Court may be prepared to "fill in the gap" much more than what I would have otherwise thought. I thought Copthorne would be a win for the taxpayer.But what about the triad of "value shift" cases creating an artificial capital loss using existing provisions of the Act or what are called the "75(2) surplus strips"? On a literal reading of the Act, they work. But is it proper for a lawyer to assist clients in transactions of this nature? I have no problem with advising the client that such schemes are "out there" (if he asks) but I do have a problem in being involved in the execution of them. Another more difficult example which does not really fit into either of the above categories is an Antle-like transaction. Should a lawyer be involved in a transaction that utilizes a discretionary trust existing for days when there is no intention whatsoever that the trustee will exercise any discretion under the trust deed? Here we have a panel of the Federal Court of Appeal finding that the transaction is a "sham". That means that the lawyers who structured this transaction were involved in a sham. Does any lawyer want to be anywhere near a transaction where a judge of the Federal Court of Appeal is even discussing why a charge of tax evasion may not apply to the false impression created by the documents in that case? This is what happens when lawyers do not ask themselves the question as to whether or not they should be part of such a transaction. On the other hand, what really is the difference between saying you have put in place a discretionary trust for a few days (or hours) with saying that you have a partnership carrying on business for a profit for three days in the Continental Bank case. Perhaps the lawyers in Antle could be forgiven for thinking this would be acceptable given the decision in Continental Bank. Does this show a changing attitude (morality?) in the courts towards what is acceptable tax planning or just the difference in the "fiscal morality" of one panel of judges? My guess is that a critical difference between these cases is the brazen attempt in Antle to avoid taxation in Canada of a capital gain that had accrued in Canada. These are the kind of things in which I do not think we as professionals should participate. This is a moral question. Without the use of some sort of moral compass, law firms and accounting firms can get into trouble. We only have to remind ourselves as to what happened to one of the most respected international accounting firms as a result of the Enron scandal. The underlying reason why this accounting firm is no longer in existence is that they applied a "literal" interpretation to the relevant accounting rules rather than a "purposive" one. We have to ask ourselves questions of what is right and wrong when conducting our practice. Whether this is cast in language of morality or ethics is somewhat academic because ethical obligations have their underpinning in morality. Returning to ethics, the ethical duty of a lawyer is not just to act with integrity and good faith as suggested by Thomas McDonnell. Surely there is a duty to conduct yourself with integrity and good faith. But the duty of a lawyer extends to the state to maintain its integrity and the law. That is the integrity of the state and its law not the integrity of the lawyer. At least in my particular jurisdiction that duty also includes an obligation not to "aid, counsel or assist any person to act in any way contrary to the law." Schemes put together that clearly frustrate specific provisions (if not the spirit) of the Income Tax Act should be shunned by lawyers. To sum up, it is my personal view that lawyers and accountants should not be able to hide behind a "literal interpretation" of an existing provision or provisions of the Act to justify participation in the execution of the scheme where the professional, based upon his knowledge of the Act, is satisfied that it is outside a textual, contextual and purposive interpretation of the provision or provisions. This is exactly what happened in the Enron scandal. In my mind, it brings the practice of law into disrepute when lawyers are associated with schemes that are clearly outside the intention of the Act.
two tennis players are playing the final match of an important tournament. They are tied at two sets all and are playing a tie-breaker in the fifth and final set. The score is 7-6, for player A, so if A wins the next point, the match is over. Player B hits a shot when A is on the other side of the court. There is no way A can get to the ball. The ball is called in by the linesman. But A calls for an instant replay, and it shows that the ball was out by the smallest fraction of a nanometre. A wins the match. Afterwards, B says to A, you should have given me that point: you were totally out of position, morally I won the point.A's obvious response is, morality, shmorality. The ball was out, the rules say I win, too bad, so sad.That is my feeling about tax law (or Phil's "plate" analogy. If you write a rule, then you have to live by the rule. You can't say, well, yes the rule says this, but REALLY everyone knows we really meant THAT. If you don't like the rule, change the rule. If you REALLY don't like the rule, change it retroactively, with all the political consequences that entails. But don't write a rule and then complain that people are not following it on a moralistic basis. There's no such thing in tax law.
Man, that was a long gap between posts!With respect, there is a fundamental difference between rules made by an authority to govern the conduct of two people neither of whom is the authority, and rules made by a group of people to govern the activity of that very group. The government that writes tax laws is not a third party imposing rules on us, it IS us (it is we?).Furthermore, there was no pre-existing view of who should win a tennis match (or any other artificial contest) before the rules of the game were invented; any game is entirely a creation of its arbitrary rules. In contrast, there was a pre-existing view of how the nation's tax bill should be divvied up even before the rules were first written: "fairly". That makes the tennis example irrelevant.


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13: Human Impacts on the Ocean
- Page ID
- 431
- 13.1: Pollution: Sources & Types
- As the world's population growth increase and technology continues to spread worldwide, the navigation of the ocean has become a shipping route and dumping ground for human activities. The continuations of human activities deplete biodiversity and disrupt the natural ecosystem in the ocean. According to the Science Learning, wasting such as chemical, sewage, and industrial run-off have a big problem worldwide. Besides that, a country's without strong government to enforce existence policies, the
- 13.7: Eutrophication
- Eutrophication is a process in which there's an excess nutrient input to water. This process increases the rate of supply of organic matter in an ecosystem and stimulate aquatic plant growth. At normal levels, these nutrients feed growth of organisms called cyanobateria or algae. But with too much nutrients, cyanobacteria grow out of control. Excess algae blocks the sunlight needed by bottom-dwelling plants and leads to decrease in oxygen in the water and consequently leads to negative outcomes.
Thumbnail: Plastic Pollution covering Accra beach. Image used with permission (CC BY-SA 4.0 international; Muntaka Chasant).


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Ahmed, S. M. F. (2006). Making Beautiful: Male Workers in Beauty Parlors. Men and Masculinities, 9(2): 168-185.
Barber, K. (2008). The Well-Coiffed Man: Class, Race, and Heterosexual Masculinity in the Hair Salon. Gender & Society, 22(4): 455-476.
Boroughs, M., G. Cafri, and J. K. Thompson. (2005). Male Body Depilation: Prevalence and Associated Features of Body Hair Removal. Sex Roles, 52(9-10): 637-644.
Boscagli, Maurizia. (1996). Eye on the Flesh: Fashions of Masculinity in the Early Twentieth Century. Westview Press.
Breward, Christopher. (1999). The Hidden Consumer: Masculinities, Fashion and City Life 1860-1914. Manchester University Press.
Breward, Christopher. (2001). Fashioning Masculinity: Men's Footwear and Modernity. pp. 116-134; IN: Shari Benstock and Suzanne Ferriss. (eds.). Foot on Shoes. New Brunswick, N.J.: Rutgers University Press.
Bunkin, Helen, and Randall Williams. (2000). Beards, Beards, Beards! Green Street Press.
Cash, Thomas F. (1990). Losing Hair, Losing Points? The Effects of Male Pattern Baldness on Social Impression Formation. Journal of Applied Social Psychology, 20(2).
Chenoune, Farid. (year?). A History of Men's Fashion.
Cole, S. (2000). "Macho Man": Clones and the Development of a Masculine Stereotype. Fashion Theory: The Journal of Dress, Body & Culture, 4(2), 125-140.
De Buzzaccarini, Vittoria. (1997). Men's Coats. (Twentieth Century-Histories of Fashion Series).
Diamond, A. (2001). Rethinking Culture on the Streets: Agency, Masculinity, and Style in the American City. Journal of Urban History, 27(5): 669-685.
Folledore, Giuliano. (1997). Men's Hats. (Twentieth Century Histories of Fashion Series).
Frith, Hannah, and Kate Gleeson. (2004). Clothing and Embodiment: Men Managing Body Image and Appearance. Psychology of Men & Masculinity. 5(1):40-48, January.
Galilee, John. (2002). Class Consumption: Understanding Middle-Class Young Men and their Fashion Choices. Men and Masculinities, 5(1), July.
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Honeyman, Katrina. (2002). Following Suit: Men, Masculinity and Gendered Practices in the Clothing Trade in Leeds, England, 1890-1940. Gender & History, Volume 14 Issue 3, pp. 426-446, Nov.
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Peacock, John. (1996). Men's Fashion: The Complete Sourcebook.
Shannon, B. (2004). ReFashioning Men: Fashion, Masculinity, and the Cultivation of the Male Consumer in Britain, 1860-1914. Victorian Studies, 46(4): 597.
Weltzien, Friedrich. (2005). Masque-ulinities: Changing Dress as a Display of Masculinity in the Superhero Genre. Fashion Theory: The Journal of Dress, Body & Culture, Volume 9, Number 2, June, pp. 229-250.


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Claims file
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The Office of the Independent Assessor (OIA) has been established to assess compensation under the Merlo Davidson class action Settlement Agreement approved by the Federal Court on May 30, 2017. The full text of the Settlement Agreement and its Schedules is available at: https://merlodavidson.ca/documents-officiels/ or you may request the agreement from the OIA.
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The OIA has created a secure system through which claimants may submit application forms. All information submitted to the OIA's servers will be kept confidential. The online application form is designed to allow each claimant to fill out information over time before submitting. Information inputted into the online claim form before the form is submitted will also be stored on the OIA's servers.
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I stand all amazed / Jesu, joy of man's desiring (J. Ashley Hall)
Music files
|Web Page
|File details
- Editor: J. Ashley Hall (submitted 2010-01-24). Score information: Letter, 10 pages, 232 kB Copyright: Personal
- Edition notes: Copyright © 2007 by John Ashley Hall — Non-commercial use is permitted — www.ashleyhallmusic.com
General Information
Title: I stand all amazed / Jesu joy of man's desiring
Composers: Charles H. Gabriel and Johann Sebastian Bach
Arranger: J. Ashley Hall
Number of voices: 4vv Voicing: SATB
Genre: Sacred, Hymn
Language: English
Instruments: Piano
First published: 2007
Description: J. Ashley Hall arrangement of Charles H. Gabriel's hymn, intertwined with J.S. Bach's "Jesu Joy of Man's Desiring"
External websites:
Original text and translations
English text
I stand all amazed at the love Jesus offers me,
Confused at the grace that so fully he profers me.
I tremble to know that for me he was crucified,
That for me, a sinner, he suffered, he bled and died.
Oh, it is wonderful that he should care for me
Enough to die for me!
Oh, it is wonderful, wonderful to me!
Jesu, joy of man's desiring
Holy wisdom, love most bright
I think of his hands pierced and bleeding to pay the debt!
Such mercy, such love, and devotion can I forget?
No, no, I will praise and adore at the mercy seat,
Until at the glorified throne I kneel at His feet.
Oh, it is wonderful that He should care for me
Enough to die for me!
Oh, it is wonderful, wonderful to me!


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Where to wear
This outfit is so versatile and can be worn for shopping, meeting friends and work. To smarten it up, simply switch the jumper for a blouse and add some jewels.
Recreate the look
The famous pink Zara coat; I was lucky to get my hands on this. I had been hunting for it in the run up to Christmas as my parents said they would treat me to one, but couldn't find it in my size anywhere. I searched for alternatives, but nothing compared – they were all a brighter pink. I found it once I stopped looking; it was hiding on the sale rail on Boxing Day
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1 Comment on Pink coat outfit
Wow a Celine bag for £14.99 bargain!!!
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