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foreign bond example
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Explore answers and all related questions . International bonds provide investors with an added layer of diversification. Foreign market. Governments, companies, and other entities issue Yankee bonds. You must buy a $5,000 security bond for each non-Malaysian Work Permit holder you employ. The ownership of foreign bonds is an example of a portfolio investment. Through the National Association of Foreign-Trade Zones (NAFTZ), Avalon offers members discounted bond rates on all required surety products. As you might expect, there are other names for similar bond structures. The bond has a par value of $1,000, a coupon rate of 5%, and 10 years to maturity. A sovereign default is the failure or refusal of the government of a sovereign state to pay back its debt in full when due. Most of assets and liabilities have associated periodic cash flows, for example an investment in foreign bonds may have cash inflows in the form of interest receipts denominated in foreign currency. A foreign bond issue is one offered by a foreign borrower to investors in a national capital market and denominated in that nation's currency. Yankee Bonds. Naim 11:19 Multinational Business Chapter 1. They often have colorful names: Yankee Bonds (in the U.S.), samurai bonds (in Japan), Rembrandt bonds (in the Netherlands) and bulldog bonds (U.K.). We provide competitive pricing, an easy application process, flexible underwriting and knowledgeable employees to facilitate the filing of bonds with CBP. Foreign bonds issued on national markets have a long history. The value of a 5-year 5% USD/GBP bond at $1 = £0.80 is the sum of the value of a straight bond and the value of a currency option. Q 73 . Foreign currency convertible bond is a special type of bond issued in the currency other than the home currency. Example 3—foreign exchange loss exceeds overall economic gain: The facts are the same as in Example 1, except that T sells the bond for €1,100 when €1 equals $0.65. Foreign Bonds Examples are: • Yankee Bonds: Foreign Bonds sold in the U.S. • Samurai Bonds: Foreign Bonds sold in Japan • Rembrandt Bonds: Foreign Bonds sold in the Netherlands • Bulldog Bonds: Foreign Bonds sold in the U.K. Yankee Bonds • Yankee bonds must be registered under the Securities Act of 1933, which means the issuer must disclose to U.S. standards. Bonds that are partially backed by the U.S. government are called "Brady bonds" after Nicholas Brady, former treasury secretary under the administration of presidents Reagan and Bush (Brigham & Ehrhardt 2009). For example, the Yankee bond market is the U.S. dollar version of this market. Domestic stocks could be split into large companies and small companies. They are rated below the investment grade that is BBB. Common examples include the purchase of property, shares in Australian companies or government bonds by foreign superannuation or pension funds. In this case, the result is that U.S. citizens' total holdings of foreign assets fall. A Eurobond is a bond that is issued by an international borrower and sold to investors in countries with currencies other than the currency in which the bond is denominated. If the exchange rate was 1$ = Rs 50, the bond buyer will pay $20 (or Rs 1000) to buy the rupee denominated bond. Title: The development of the international bond market Author: Richard Benzie Subject: BIS Economic Papers No 32 Created Date: 20060322160621Z 2. An example of a Eurobond is a dollar-denominated bond issued by a U.S. company and sold to Japanese investors. What Is the Difference Between Eurobonds and Foreign Bonds? Please explain and discuss. The bond is sold for $100 and pays an interest of $5 or £4. And like international bond ETFs, currency ETFs allow you to hedge foreign interest rate risk. What is a BOND A bond is a debt investment in which an investor loans money to an entity (typically corporate or governmental) which borrows the funds for a defined period of time at a variable or fixed interest rate. Foreign Bond Market: This is the market where the issuers from outside the country issue the bonds in the country. How Do Yankee Bonds Work? Junk Bonds Definition, Basics and Example Junk Bonds Definition – "A high yield bonds with ratings less than the investment grade by one or more rating agencies" In simple words, these are the high yielding bonds with low investment rating. Related questions. The bond will return 5% ($50) per year. Foreign bonds sold in the United States and denominated in US dollars are called Yankee bonds. Bonds could be split into government bonds and corporate bonds. For example, imagine two 10-year sovereign bond issues by India: one for $100 in the US, and the other for Rs 7,000 in India. The offered company which is the company, whose equity shares can be purchased by the bondholder to exercise the right to conversion, must receive foreign investments. The bond is in the form of a banker's or insurer's guarantee. Foreign bond is a bond issued by a business entity in the financial market of a country which is other than its parent country. Example: A German MNC issuing dollar-denominated bonds to U.S. investors 4. Say you purchase a bond for $1,000 (present value). See also Eurobond. Provides comprehensive Malaysia's bonds market information and analysis yield curve for Malaysian Goverment Bond, Malaysian Government Securities (MGS), Islamic Bond, Cagamas, Khazanah Bond and Corporate Bond A eurobond is a bond issued and traded in a country other than the one in which its currency is denominated. The highest rating is AAA. Foreign bonds: Issued by foreign borrowers in local currency. This result might occur because the bond has a fixed interest rate and interest rates have decreased, or the issuer's credit has strengthened. Bond Pricing Example. The fact that a company is the market leader in one country is no guarantee that it will be the leader in another country. Adding diversity to an investment portfolio helps to reduce the risk of substantial losses while also limiting an investor's potential return. For example, let's assume Company XYZ is headquartered in Spain. Get updated data about global government bonds. At the maturity date, you will be paid back the $1,000 par value. Pick a foreign bond market (outside the USA) and give an example and briefly discuss the risks of the bond market that you choose. A bond's price equals the present value of its expected future cash flows. Q 72 . For example, an investor who has his entire portfolio invested in one bond may profit if the bond quickly increases in value. Also, they are a nice way to gain exposure to a country's economic climate, since the value of a currency is indicative of its current financial state. • Global Bond: It is a bond issued and traded outside the country where a currency is denominated. Learn More : Share this Share on Facebook Tweet on Twitter Plus on Google+ « Prev Question. A foreign bond allows an investor a measure of international diversification without subjection to the risk of changes in relative currency values. Find information on government bonds yields, bond spreads, and interest rates. Similarly, a floating-rate loan may have cash outflows in the form of interest payments which vary according to some benchmark interest rate, say LIBOR. An American manufacturer issues a 1-year 5% USD/GBP currency option bond at $1 = £0.80. Government regulations have forced many international borrowers to leave foreign bond markets and borrow instead in the Eurobond market. For the sake of simplicity, suppose the exchange rate is Rs 70 to a dollar. For example, if an Indian financial entity issues Rs 1000 rupee denominated bond overseas, the buyer in overseas can buy the bond, paying equivalent amount of dollar/sterling. Investing in Foreign Bonds . Some of the categories in the example could be broken down into further sub-categories. On a final note, it is important to highlight the difference between a so-called eurobonds and foreign bonds. For example, the bonds issued by global companies in Japan denominated in yen are called samurai bonds. For example, a Chinese Government bond in Chinese yuan. As with other foreign ETFs, currency ETFs can track a specific country or a collection of currencies. Foreign Currency Exchangeable Bonds In this type of bond, the interest amount and the principal is payable in foreign currency. Another example is Ford Motor Corporation issuing a yen denominated bond in Japan. The ownership of foreign bonds is an example of a portfolio investment. Foreign Bond. A bond denominated in U.S. dollars that is issued in the United States by the government of Canada is a foreign bond. The foreign bond market includes the bonds that are sold in a country, using that country's currency, but issued by a non-domestic borrower. Practical Example of a Currency Bond Valuation. You cannot ask your worker to pay for the bond. Yankee bond has certain peculiar features associated with the US domestic market. For example, Japanese Government issuing a US-dollar denominated bond in the US foreign bond market. Again, completing that sale requires making a payment to people in the U.S. A security bond is a binding pledge to pay the government if either you or your worker breaks the law or Work Permit conditions. In today's scenario of globalization, FCCBs hold high significance especially for multi-national companies wherein they are constantly dealing with different currencies of the world. • Foreign Bond : A foreign bond is one offered by a foreign borrower to the investors in a national capital market and denominated in the nation's currency. Investing in Eurobonds (Global Bonds) vs. Example 2: U.S. investors who currently own $100 million in French corporate bonds sell those bonds to French investors. This is because they are sold in the U.S. using the dollar, but issued by a syndicate outside of the U.S. For such foreign bonds, the denomination is in the local currency of the country where these bonds are issued and they are regulated by local regulations. Foreign direct investment (FDI) is when an individual or entity from outside Australia establishes a new business or acquires 10 per cent or more of an Australian enterprise, and so has some control over its operations. Yankee Bonds are US dollar denominated issues by foreign borrowers (usually foreign governments or entities, supranationals and highly rated corporate borrowers) in the US bond markets. Foreign stocks could be divided into developed and emerging markets. In other words, companies issue foreign currency convertible bonds to raise money in foreign currency. Yankee bonds are bonds issued in the U.S. bond market by a foreign entity, and they are denominated in U.S. dollars. Answer: TRUE. Example 3: Someone in the U.S. borrows from a Canadian Bank. The ownership of foreign bonds is an example of a portfolio investment. Cessation of due payments (or receivables) may either be accompanied by that government's formal declaration that it will not pay (or only partially pay) its debts (repudiation), or it may be unannounced. For example, a bond denominated in Philippine peso that is issued by the government of the United Sates is a foreign bond. 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If you're planning on moving away from Earth in the near future, as many Americans have decided after the results of the 2016 election, you might want to catch an upcoming National Geographic documentary. It's all about how Martian homes may look in the future once humans have finally spread out into the cosmos proper.
Building homes is already difficult on Earth, let alone a planet that we're not even inhabiting as humans just yet. There are very specific conditions that need to be fulfilled when it comes to putting up houses on the Red Planet, namely because of its thin atmosphere, arid land, and overall harsher environment than that of Earth's. The safety of crews assigned to live on Mars would be the utmost priority, so ensuring steady supplies of oxygen, water, food and other essentials would come before feng shui or beautiful home exteriors.
The National Geographic documentary will explore several different building options and is set place in 2037 in the Valles Marineris region on Mars, right near its equator. The homes, from the trailer, appear to resemble igloos, though others include underground tunnels and even repurposed Martian soil bricks known as regolith.
The homes should still have the important areas, such as your bedroom, kitchen, and other integral areas, but you won't get to see outside since there wouldn't be any windows built into them — protection, you know. Mars is a lot closer to the sun than one would think, so anyone who takes up residence on the planet would need additional protection from the sun as it still offers energy to harness.
It may seem stranger than fiction, but it's not a crazy notion anymore to think we could actually live on Mars. It's a long way off, but it's becoming closer and closer to the truth with each day that passes. You might need to stay on Earth for the remainder of your lifetime, however.


Gather together as a Community in a comfortable setting (around a table, on the couch, the floor of a living room, etc.).
If you're up for it, and your setting is quiet, spend a few minutes in silence. Why silence? Because we live in a busy, noisy world, under the non-stop assault of digital distraction. In the midst of all the chaos, it's hard at times to hear one another, let alone the voice of God. As we gather together as a family, we want to hear what the Father is saying to and through each of us, and respond in turn. A great way to do that is to begin with a moment of quiet.
Have somebody lead a prayer asking the Holy Spirit to lead and guide your time together.
If you are in a Community of seven or more, divide into small groups of 3–4 people each (ideally same gender).
1. Did you listen to the teaching? What was the main take away for you?
2. Is Sabbath already a part of your life, or no? If yes, to what extent?
3. What has been (or do you sense will be) your greatest obstacle in practicing Sabbath?
1. Is the Practice of Sabbath new to you? Was it part of your upbringing? Did you grow up with any kind of negative understanding about it?
2. How does the idea of practicing Sabbath make you feel? Nervous about Sabbath being too legalistic? Skeptical about working this into your schedule? Full of anticipation for rest? Something entirely different?
3. In what ways do you see our culture pushing back against a life of rest?
We live in a cultural moment of restlessness. The unsatisfied desires of our human condition are exacerbated by the barrage of digital marketing from a consumption-oriented, consumer-driven economy. We have multi-billion dollar, multi-national industries hovering over our minds – via our devices – in an attempt to monetize our restlessness. But rest doesn't come from buying a product; it comes from Sabbath. A word that literally means stopping. The Sabbath is an entire day set aside to stop - stop working, stop wanting, stop worrying, etc.—and to simply rest in God's presence.
Most followers of Jesus (at least, in the modern, Western world) no longer practice Sabbath. This means many of us are missing out on one of the most life-giving practices of the way of Jesus, and arguably, one of the most important for our cultural moment.
Since this Practice is brand new for many of us, the goal of week one is to start with the basics: just set aside a 24 hour time period to rest and worship; mark a beginning and end time, each with a ritual of your own design; and spend the day in Sabbath delight. It sounds easy, but, like all good things, it takes practice. So be patient with yourself, with this Practice, and with God. Let yourself settle into the "rest for your soul" that Jesus has on offer.
If at all possible, establish a regular rhythm of Sabbath on the same day each week.
Much of the Sabbath is about rhythms and rituals that set aside the day as "holy." Beginning and ending with a marked moment will help you settle into rest, and help you reenter the week with a restful spirit.
Light two candles (symbolic for the two commands in Exodus and Deuteronomy to "remember" and "observe" the Sabbath). Invite the Spirit of Jesus to come and give your home light, joy, love, peace, and rest.
Pour a glass of wine (or grape juice for the kids or the straight edge). Pray a blessing over the drink and give thanks.
If you have a family, this is where, traditionally, the father speaks a blessing over the children and the mother. If you're with roommates or friends, this can be a wonderful time to bless each other, with prayers like: May you be happy and full of joy. May the Lord lift up his countenance upon you and give you peace. May you find rest for your soul. Etc.
Read a Psalm, sing a song, quote a poem, or pray a liturgy to center on God.
Pray: ask the Holy Spirit bring a spirit of rest over your life and lead and guide you through the next 24 hours.
If you begin at night, share a meal with your family or friends.
If you begin in the morning, go to church and worship.
Take a slow, leisurely prayer walk around your neighborhood, nearby park, or nature reserve.
Share a meal with family and friends.
Spend some time alone or with your family and friends in prayers of gratitude.
Traditionally, the Sabbath ends by sitting on the floor, lighting a special havdalah candle, and sharing 1) the best part of your Sabbath, and 2) what you are looking forward to in the week ahead, passing around sweet smelling spices to savor the day, and ending with prayers of gratitude.
3. Spend an entire day in rest and worship.
Fill your day with activities that are life-giving for your soul. Begin to distinguish between recreation and restoration. Begin to transition from entertainment, TV, social media, shopping, and going "out," to activities that deeply connect you to Jesus and his rest.
This is not a "to do" list: there are no "to do"s on Sabbath! No oughts or shoulds. This is just a list of activities many people find restful and restorative.
Adapt your day to your personality, preference, stage of life, and however it is you connect with God: time in nature, walking your dog to the park, playing frisbee golf with your kids, getting lost in a good novel, etc. Just take the day to pamper your soul in God's presence.
1. Any thoughts, creative ideas, or feedback on this coming week's Practice?
2. What activities do you find most restful? Connect you to God?
3. What do you think has to change in your life for Sabbath to become a part of your practice?


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Professor Russell Engler is a nationally recognized scholar on Access to Justice and the right to civil legal counsel for low-income citizens.
The Center for Law and Social Responsibility may provide students with opportunities to become legal advocates in criminal justice, immigration, education, the environment, and women's and children's issues, obtaining real lawyering experience alongside professors or under the guidance of full-time legal service providers.
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Gifting Business Interests: Will the Parent's Tax Treatment Be Visited Upon the Child?*
The Tax Gene?
King of Swamp Castle: One day, lad, all this will be yours.
Prince Herbert: What, the curtains?
King: No, not the curtains, lad. I'm talking about all of my business and investment interests, along with the related tax reporting positions.[I]
Have you ever wondered how much our parental genes define us? What about the impact of external factors?
It is a scientific fact that an individual's genetic make-up, as passed down to them from their parents, influences their physical characteristics, and even their behavior. Each of us, therefore, "owes" a great deal to our parents for who were are.
It has also been scientifically established that the environment in which one is raised plays a significant role in one's development as an individual. Poverty and poor nutrition, for example, may greatly influence whether one's genetic abilities will ever be fully realized. These factors may also be attributed to who our parents were.[ii]
Until recently, however, I never seriously considered whether a parent's tax reporting position – of all things – may be passed on to their child in such a way that it is determinative of the child's own tax reporting. Surprisingly, that seemed to be the argument that the IRS made in a case decided by the Tax Court last week.[iii]
Dad's Interest Expense
Dad was a real estate entrepreneur who owned[iv] a 50-percent interest in each of several partnerships (the "Partnerships") that owned, operated, and actively managed rental real estate. The remaining interest in each partnership was held by an unrelated person.
The Partnerships borrowed money from Bank and distributed the proceeds to Dad and his partner.[v] The terms of the loans were substantially similar. Each loan had a 5.88% interest rate, and was evidenced by a note that was secured by the partnership's assets. Neither Dad nor his partner was personally liable on the notes.[vi]
Dad invested the funds distributed to him in money market funds and other investment assets, which he held until his death.
Of course, the Partnerships incurred interest expense on the Bank loans. Each partnership issued to Dad for each year a Schedule K-1, Partner's Share of Income, Deductions, Credits, etc., reporting his distributive shares of its rental real estate income and of its interest expense.
On his federal income tax return for each year, Dad reported his distributive shares of the interest expense on the loans as "investment interest."[vii]
A couple of years before his death, Dad transferred to Son, by gift, his ownership interests in the Partnerships.[viii] Son agreed to be bound by each Partnership's operating agreement,[ix] but he did not become personally liable on any of the Bank loans.
However, by "gratuitously" transferring his interests in the Partnerships to Son, Dad was relieved of his shares of the partnership liabilities represented by the loans.
On his federal income tax return for the year of the gift, Dad treated the nonrecourse partnership liabilities of which he was "relieved" as amounts realized on the gift transfers of his partnership interests.[x] Accordingly, Dad reported taxable capital gains to the extent the amount realized exceeded his adjusted basis in his partnership interests.[xi]
Son's Interest Expense
The Partnerships paid interest on these loans, and issued Schedules K-1 to Son reporting his distributive shares of the Partnerships' rental real estate income and of the interest expense attributable to the Bank loans.
Son filed his federal income tax return on IRS Form 1040, to which he attached Schedule E, Supplemental Income and Loss.[xii] He took the position that the interest paid by the Partnerships on the Bank loans was not "investment interest," as it had been in the hands of Dad, because Son had not received any of the loan proceeds, and had not used any partnership distributions to acquire investment assets.
Rather, Son treated the interest as having been paid on indebtedness properly allocable to the Partnerships' real estate assets, and thus treated his distributive shares of the interest expense as fully deductible against his distributive shares of the Partnerships' real estate income. Accordingly, on each Schedule E, Son netted against the rental income for each partnership the corresponding amount of interest expense.
The IRS Disagrees
The IRS examined Son's tax returns and issued a timely notice of deficiency in which it asserted that Son's distributive shares of the interest paid by the Partnerships on the Bank loans should properly have been reported on the Schedules A of his Forms 1040 as investment interest – the way Dad had reported the interest.
Investment interest, the IRS pointed out, is deductible only to the extent of a taxpayer's "net investment income." Because Son had insufficient investment income to utilize the interest expense allocated to Son by the Partnerships, the IRS disallowed the deductions for all of the passed-through interest attributable to the Bank loans.[xiii]
Son then timely[xiv] petitioned the U.S. Tax Court for a redetermination of the deficiencies resulting from the disallowed deduction.[xv]
The Code generally provides that "[t]here shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness,"[xvi] but this rule is subject to a number of limitations.
For example, in the case of taxpayers other than corporations, "personal interest" is generally nondeductible.[xvii]
However, nondeductible personal interest is defined to exclude (among other things) "interest paid or incurred on indebtedness properly allocable to a trade or business," and any interest which is taken into account in computing income or loss from a passive activity."[xviii]
Personal interest also excludes "any investment interest."[xix]
The IRS contended that the interest paid by the Partnerships on the Bank loans, part of which was passed through to Son,[xx] constituted "investment interest."
Investment interest is defined as interest that is "paid or accrued on indebtedness properly allocable to property held for investment."[xxi]
The Code allows a deduction for investment interest, but subject to a limitation. Specifically, it provides that, "[i]n the case of a taxpayer other than a corporation, the amount allowed as a deduction * * * for investment interest for any taxable year shall not exceed the net investment income of the taxpayer for the taxable year."[xxii]
The interest in question was incurred by the Partnerships. These entities owned, operated, and actively managed apartment buildings and other rental real estate. The loans on which the interest was paid were secured by those real estate assets.
The IRS did not contend, however, that the operating assets held by the Partnerships constituted "property held for investment."
How, then, could the IRS treat Son's share of the Partnerships' interest expense as investment interest?
Tracing the Debt Proceeds
The Court explained that tracing rules are utilized for determining when debt is "properly allocable to property held for investment."[xxiii]
In general, according to these rules, "[d]ebt is allocated to expenditures in accordance with the use of the debt proceeds and * * * interest expense accruing on a debt * * * is allocated to expenditures in the same manner as the debt is allocated."[xxiv] In other words, "debt is allocated by tracing disbursements of the debt proceeds to specific expenditures."[xxv]
For example, if a taxpayer uses debt proceeds to make a personal expenditure, the interest is treated as nondeductible personal interest. If a taxpayer uses debt proceeds in connection with a passive activity, the interest is subject to the passive loss limitations.[xxvi] And if a taxpayer uses debt proceeds to make "an investment expenditure," the interest incurred on the debt is allocable to such investment expenditure, and the interest is treated, for purposes of the interest deduction disallowance rule, as investment interest.[xxvii]
Although the tracing rules do not specify how they are to be applied to partnerships and their partners, the IRS has provided that, if a partnership uses debt proceeds to fund a distribution to its partners – i.e., to make debt-financed distributions – each partner's use of the proceeds determines whether the interest passed through to them constitutes investment interest.[xxviii]
Thus, if a partner uses the proceeds of a debt-financed distribution to acquire property that they hold for investment, the corresponding interest expense incurred by the partnership and passed on to the partner will be treated as investment interest.
In short, if a taxpayer uses debt proceeds to acquire an investment, the interest on that debt is investment interest regardless of whether the debt originated in a partnership.
Reduced to its essentials, the question before the Court was whether Son – who had acquired interests in the Partnerships by gift from Dad – was required to treat the interest expense passed through to him in the same manner as Dad.
The IRS argued that Son in effect stepped into Dad's shoes, with the supposed result that the interest, properly reported by Dad as investment interest, remained investment interest as to Son so long as the loans remained on the Partnerships' books.
Dad received debt-financed distributions from the Partnerships. He used the proceeds of those distributions to acquire shares of money market funds and other assets that he held for investment. Consistently with the tracing rule, Dad properly treated the interest expense incurred by the Partnerships and passed through to him as investment interest.
Son, however, did not receive, directly or indirectly, any portion of the debt-financed distributions that the Partnerships made to Dad. Nor did Son use distributions from the Partnerships to make investment expenditures.
The Court determined that the facts which caused the passed-through interest to be investment interest in Dad's hands did not apply to Son.
Acquisition Indebtedness?
The Court then explained how debt should be allocated where (as in Son's case) no loan proceeds were disbursed to a taxpayer:
If a taxpayer incurs or assumes a debt in consideration for the sale or use of property * * * or takes property subject to a debt, and no debt proceeds are disbursed to the taxpayer, the debt is treated * * * as if the taxpayer used an amount of the debt proceeds equal to the balance of the debt outstanding at such time to make an expenditure for such property * * *.
Son acquired his ownership interests in the Partnerships by gift from Dad. He acquired those interests subject to the Bank debts that were then on the Partnerships' books. Thus, Son was treated as using his allocable share of that debt to make an expenditure for the acquisition of his partnership interests.[xxix]
In the case of a debt-financed acquisition (as opposed to a debt-financed distribution), such as the purchase of an interest in a partnership, the Court explained that the debt proceeds and the associated interest expense should be allocated among all the assets of the partnership "using any reasonable method."
In short, whereas Dad received a debt-financed distribution, Son was treated as having made a debt-financed acquisition of the Partnership interests he acquired from Dad. For purposes of the investment interest limitation, therefore, the debt proceeds were allocated among all of the Partnerships' real estate assets, and the interest paid on the debt was allocated to those assets in the same way.[xxx]
Because the Partnerships' real estate assets were actively managed operating assets, they did not constitute "property held for investment." Therefore, the interest paid on the Bank loans was not investment interest.
The IRS's Alternative Argument
The IRS disputed the relevance of the tracing rules, urging that Son, when acquiring the Partnership interests from Dad, did not "assume[] a debt" or "take[] property subject to a debt." The IRS emphasized that Son had no personal liability on the Bank loans, which were nonrecourse, and that the liens held by Bank ran against the Partnerships' real estate assets, not against Son's partnership interests.
The Court rejected the IRS's position. In fact, it pointed out that the IRS itself had previously reasoned that, where partnership interests are transferred, each transferring partner's share of partnership nonrecourse liabilities would be considered as a liability to which the partnership interest was subject.
Thus, Son acquired his interests in the Partnerships subject to the Bank debts, even though Son did not personally assume those debts, which remained nonrecourse with respect to the partners individually.
In the converse situation, the Court continued, where a partner sells a partnership interest, the regulations provide that the partner's "amount realized" includes his share of the partnership liabilities of which he is relieved, even if the liabilities are nonrecourse.[xxxi]
Thus, the fact that a partner is not personally liable for a partnership's debt does not mean that their partnership interest is not "subject to a debt" for purposes of the partnership tax rules.
For the foregoing reasons, the Court concluded that the interest expense passed through to Son from the Partnerships was not investment interest.
The Court noted that, even if the tracing rules were somehow inapplicable, the IRS failed to articulate any principle or rule that would affirmatively require the interest expense in question to be characterized as investment interest. According to the Court, the principle that required such interest to be characterized as investment interest in Dad's hands clearly did not apply because Son (unlike Dad) did not receive any debt-financed distributions from the Partnerships.
The IRS's position thus was reduced, the Court stated, to the contention that, because Son acquired the partnership interests from Dad, he stood in Dad's shoes and had to treat the passed-through interest the same way Dad did. But, the Court continued, neither the investment interest limitation rule nor its implementing regulations include any family attribution rule or similar principle that would require this result.
When Dad gratuitously transferred interests in the Partnerships to Son, he was required to include the partnership debt from which he was relieved[xxxii] as an "amount realized," and he reported capital gains accordingly. To the extent Dad was relieved of the debt, liability was necessarily shifted to the other partners, including Son. Son thus took his Partnership interests "subject to the debt," even though the liabilities were nonrecourse.
It seemed obvious, the Court explained, that Son would have no "investment interest" if he had acquired his ownership interests in the Partnerships from a third party for cash. The IRS did not explain why the result should be different because Son acquired those interests from Dad by a partial gift. The Court determined that the IRS failed to articulate a principle that would justify characterizing the interest expense passed through to Son as "properly allocable to property held for investment" by Son.
Once Investment Interest . . . ?
The IRS then urged the Court to adopt a "once investment interest, always investment interest" rule on the theory that any other approach would "place a myriad of additional administrative burdens on both taxpayers and the government."
Again, the Court turned the IRS away, pointing out that both the tracing rules and the partnership tax rules clearly dictated different outcomes depending on whether a partner received a debt-financed distribution or made a debt-financed acquisition.
Recognition that partnership interests may change hands, the Court observed, was thus an inherent part of the regulatory structure.
In sum, the Court held that the interest expense passed through to Son from the Bank loans was not investment interest. When Son acquired the partnership interests from Dad, he was in the same position as any other person who acquired partnership interests encumbered by debt. He did not receive the proceeds of those debts, and he did not use the proceeds of those debts to acquire property that he subsequently held for investment. Thus, there was no justification for treating the interest expense passed through to him as investment interest. Rather, Son correctly reported it on Schedule E as allocable to the real estate assets held by the Partnerships.
Are There Tax Genes?
So, was the IRS crazy to argue that Dad's tax treatment of the interest expense should have determined Son's treatment as well?
Probably, but not entirely.[xxxiii]
When one individual transfers a partnership interest to another by gift, the recipient generally takes the interest with an adjusted basis equal to the donor's adjusted basis in the interest.[xxxiv] In this way, the unrealized gain in the donor's hands is preserved when the property is transferred to the recipient.
In addition, the recipient of the gifted partnership interest will take the donor's holding period for the interest gifted, thereby preserving the long-term/short-term character of any capital gain inherent in the property.[xxxv]
The donor's amount at risk with respect to the gifted partnership interest will be added to the recipient's amount at risk for such interest.[xxxvi]
When a donor gifts a partnership interest in a passive activity, the adjusted basis for the interest is increased by the amount of the donor's suspended passive losses allocable to such interest, in effect allowing the recipient to utilize such losses in determining their gain on a subsequent taxable disposition; the gift is not treated as a disposition that would allow the donor to utilize such losses.[xxxvii]
In the case of a gift of a partnership interest in which the donor has a Section 754 basis adjustment, the donor is treated as transferring, and the recipient as receiving, that portion of the basis adjustment attributable to the gifted partnership interest.[xxxviii]
Likewise, when an individual makes a gift of a partnership interest that they received in exchange for a contribution of built-in gain property[xxxix] to the partnership, the built-in gain will be allocated to the recipient as it would have been allocated to the donor.[xl]
Unfortunately for the Service, there are just as many instances in which the recipient of a gift of property does not step into the shoes of the donor. In general, these instances involve the application of rules where the relationship of the gift recipient to the property interest at issue rightly supplants that of the donor.
For example, the recipient of a gift of real property that had been used by the donor in a trade or business cannot rely upon the donor's use for purposes of themselves engaging in a like kind exchange with such property; rather, the recipient must establish their own qualifying use of the property.[xli]
Most importantly insofar as Dad and Son are concerned, the otherwise gratuitous transfer of property that is encumbered by indebtedness – or, in the case of a partnership interest, to which debt has been allocated under the partnership tax rules[xlii] – is treated as a sale and purchase of such interest to the extent of such indebtedness.
As in the case of any sale between unrelated persons, the buyer takes a cost basis in the property acquired, and begins a new holding period for such property. The buyer determines their own at-risk-amount, and ascertains whether the property constitutes an interest in an activity in which the buyer materially participates, without regard to the seller's history. And the buyer determines their own relationship to the property for purposes of the limitations on the deduction of interest.
So, to the question of whether a parent's personal tax traits can be genetically passed down to their children, the answer is no.[xliii]
*Of course, the reference is from the Old Testament, appearing first in Exodus, Chapter 20 (the presentation of the Ten Commandments): "For I the LORD your God am a jealous God, visiting the iniquity of the fathers upon the sons to the third and fourth generation of those that hate me, and showing mercy to thousands of those that love Me and keep My commandments."
[i] With sincerest apologies to Monty Python. What follows is the complete dialogue from this scene in Monty Python and the Holy Grail:
King: No, not the curtains, lad.
King: I built this kingdom up from nothing. When I started, all I had was swamp! Other kings said I was daft to build a castle on a swamp, but I built it all the same, just to show 'em! It sank into the swamp, so I built a second one. That sank into the swamp. I built a third one. It burned down, fell over, and then it sank into the swamp. But the fourth one stayed up! And that's what you're going to get, lad–the strongest castle on these islands!
King: Listen, lad, in twenty minutes you're going to be married to a girl whose father owns the biggest tracts of open land in Britain.
Prince Herbert: But I don't want land.
King: Listen, Alice–
Prince Herbert: Herbert.
King: Herbert. We built this castle on a bloody swamp, we need all the land we can get!
Prince Herbert: But I don't like her.
King: Don't like her? What's wrong with her?! She's beautiful, she's rich, she's got huge . . . tracts of land.
[ii] Fate? Karma? The alignment of the stars and planets? Just dumb luck? According to the character in the movie, A Knight's Tale, "from peasant to knight, one man can change his stars."
[iii] Lipnick v. Commissioner, Docket No. 1262-18; filed August 28, 2019.
[iv] Directly and through a grantor trust. IRC Sec. 671.
[v] Dad received over $22 million. One of the most attractive characteristics of a real estate partnership is its ability to borrow against the equity in the property, to thereby increase its partners' adjusted bases for their partnership interests, and to distribute the loan proceeds to its partners without causing an immediate taxable event. IRC Sec. 752(a), Sec. 722, and Sec. 731(a).
[vi] The debt was nonrecourse as to them; Bank could only look to the partnership properties securing the debt for satisfaction of the debt.
[vii] On Schedule A of his IRS Form 1040.
[viii] I assume that Dad filed a federal gift tax return on IRS Form 709.
[ix] At this point, presumably, Son was admitted as a partner, and ceased to be a mere transferee with only an economic interest in the Partnerships.
[x] IRC Sec. 752(d); Reg. Sec. 1.752-1(h), and Sec. 1.1001-2(a)(4)(v).
[xi] In other words, Dad's transfer to Son was part-gift/part-sale; he was treated as having sold (and as having received consideration for) an interest with a fair market value equal to the amount of debt relieved; the equity portion of the interest constituted a gift.
[xii] Part II is used to report income/loss from partnerships, among other things.
[xiii] The disallowed amount is carried forward.
[xiv] In general, 90 days from the date of the notice of deficiency.
[xv] The parties submitted the case for decision without trial.
[xvi] IRC Sec. 163(a).
[xvii] IRC Sec. 163(h).
[xviii] IRC Sec. 163(h)(2)(A), (C).
[xix] IRC Sec. 163(h)(2)(B); IRC Sec. 163(d).
[xx] IRC Sec. 702.
[xxi] IRC Sec. 163(d)(3)(A).
[xxii] IRC Sec. 163(d)(1).
Son had little net investment income for the tax years in issue (meaning, interest, dividends, annuities, royalties, and net capital gain – see IRC 163(d)(5) and Sec. 469(e)). Accordingly, he agreed that, if the interest in question constituted "investment interest" under Sec. 163(d), it would be nondeductible. And the IRS agreed that, if the interest was not investment interest, it was properly reportable and deductible on Son's Schedule E.
[xxiii] Sec. 163(d)(3)(A); see Sec. 1.163-8T, Temporary Income Tax Regs., 52 Fed. Reg. 24999 (July 2, 1987).
[xxiv] Sec. 1.163-8T(c)(1).
[xxv] Reg. Sec. 1.163-8T(a)(3).
[xxvi] Sec. 469; Reg. Sec. 1.163-8T(a)(4)(ii), Example (1).
[xxvii] Reg. Sec. 1.163-8T(a)(4)(i)(C).
[xxviii] Notice 89-35.
[xxix] The flip-side of the part-gift/part-sale is the part-gift/part-purchase.
[xxx] Reg. Sec. 1.163-8T(c)(1).
[xxxi] Reg. Sec. 1.752-1, 1.1001-2(a)(4)(v), stating that a taxpayer's "amount realized" on transfer of a partnership interest includes the nonrecourse liabilities of which he is relieved, where the transferee "takes the partnership interest subject to the * * * liabilities."
For purposes of the partnership tax rules, generally, any increase or decrease in a partner's share of partnership liabilities is treated as a deemed contribution or distribution, regardless of whether the debt is recourse or nonrecourse. Sec. 752; Sec. 1.752-1.
[xxxii] More accurately, which was allocated away from him and to Son in accordance with the regulations under Section 752 of the Code.
[xxxiii] "There's a big difference between mostly dead and all dead." – Miracle Max, from The Princess Bride.
[xxxiv] IRC Sec. 1015.
[xxxv] IRC Sec. 1223.
[xxxvi] Prop. Reg. Sec. 1.465-68.
[xxxvii] IRC Sec. 469(h). That being said, an activity that may have been passive as to the donor may not be treated as passive as to the recipient.
[xxxviii] Reg. Sec. 1.743-1(f).
[xxxix] IRC Sec. 704(c).
[xl] Reg. Sec. 1.704-3(a)(7).
[xli] See, e.g., Rev. Rul. 75-292.
[xlii] IRC Sec. 752 and the regulations issued thereunder.
[xliii] As distinguished from an aversion to paying tax, which is probably a product of both nature and nurture.


Being the opposition faction's major stronghold in Southern Syria, all eyes are fixed on Daraa governorate today, after it entered a new level of the conflict with the arrival of the reinforcements summoned by Assad's forces and allied militias in the past a few days, which have taken position on the western confrontation lines of the As-Suwayda governorate and the surrounding of the northern countryside on the death triangle's vicinity.
The United States of America has given up on the "Free Army" factions in Daraa in Sync with the Russian air force's participation alongside Assad's forces in their attack against the area.
The letter is considered America's withdrawal from Southern Syria's file and of supporting the military factions.
Ra'ed al-Radi, the official spokesperson of the Southern Central Operation Room, confirmed the letter's content and told Enab Baladi that military confrontations are on at the all the fronts in the eastern countryside of Daraa.
Helicopters and military aircraft covered Assad's forces attempt at progress towards the al-Lajat and practiced pressure on Busra al-Harir, eastern el-Karak, al-Musayfirah, al-Mlaihat in the eastern countryside of Daraa.
Negotiations and talks are conducted concerning Southern Syria by active and in control international parties, which have not yet reached a census and to the failure of which the military operation is an indicator, especially the talks that joined America and Russia.
The potential future of the area is so far swinging between tow resolutions, either to undertake actually wage the war, to be thus the biggest battle of its kind in Syria, or to reach an international census that has the ability to stop the war, turning to gratification, similar to what happened in other Syrian areas and governorates.
For the past seven years, the battles between the opposition and the Syrian regime on the ground were accompanied by political meetings and talks, relied upon to arrive at a solution to stop the field combat in return for reconciliations or agreements that resolve under the control of which of the conflicting parties an area, the subject of the confrontations, would settle.
The role of the talks which accompany grand battles is made necessary, taking into consideration the political talks that parallel the confrontations in Eastern Ghouta, the northern countryside of Homs and the city of Aleppo, which marked the beginning of action under the "Astana" Talks, run by three states, Turkey, Iran and Russia, referred to as the Syrian file's guarantor states.
Southern Syria's file is not different from the former ones and is today waiting for the outcome of the meeting that brings together the "six states" in Geneva. Despite the fact that the meeting's point of focus is the discussion of the formation of the constitutional committee, the Sates would spare a space to address Southern Syria and Assad's forces violations of the "de-escalation" agreement, which included the south last July 2018.
Bashar al- Zuabi, the head of the political office of the "althawra army" faction, active in Daraa, told Enab Baladi that the meeting will issue a decisive and clear decision about Assad's forces attacks, and the United States is supposed to have a serious attitude, since it refused the violations and started the escalation with a number of statements, the last of which was Nikki Haley's, the United States Ambassador to the United nations, who said that Assad's forces are "unambiguously violet[ing]" the "de-escalation" arrangement and that more than 11 thousand people are displaced due to these violations.
"Russia will ultimately bear responsibility for any further escalations in Syria," Haley said.
The opposition is so far contacting the guarantor states of the "de-escalation" agreement in Southern Syria, al-Zuabi added telling Enab Baladi that incase a political solution is agreed upon, it will be sought; however, if the solution was a military one, the factions will choose resistance and will combat any military action.
The American position of Assad's forces movement has not yet been clarified and sources, informed of the developments in Southern Syria, told Enab Baladi that the dispute is about the area's future between the Russians and Americans, while Israel has already given the green light to the first as to go deeper in the area, providing that Iranian and Shiite militias shall withdraw from the area completely.
The Geneva meeting corresponds to another, for the "Negotiations Higher Committee" will hold its annual meeting in the Saudi capital Riyadh, and Southern Syria's file is supposed to top the meeting's talks, but sources have informed Enab Baladi that the Committee is unable to make a decisive and an effective decision about the area.
The six states, Britain, America, Saudi Arabia, France, Jordan and Germany has the same attitude of the Syrian file and according to the meeting's agenda, they will meet the "de-escalation" agreement's guarantor states (Russia, Iran and Turkey).
On the ground, Russia waged the wand of the official operations and issued threats to Saturday evening. The point that could be considered an "unofficial" participation is related to "Tiger Forces," led by the Brigadier General Suheil al-Hassan, who are viewed as the spear head of the expected battle, for massive numbers of the forces have arrived at the confrontation lines with the opposition in the eastern countryside of Daraa accompanied by the Russian police and a continuous coverage by Russian media.
Russia, nonetheless, has officially entered the battle and initiated an incessant shelling against Daraa, on Saturday evening, according to the Civil Defense Directorate in the governorate.
Today the battles are active at three axes towards the eastern countryside of Daraa, on a 40 kilometers long line, and Assad's forces are trying to exclude the area of al-Lajat completely through controlling the two towns of Busra al-Harir and Masikah which form the link between the al-Lajat and the rest of the areas in the eastern countryside.
Incase the area of al-Lajat is excluded, Assad's forces will avoid entering it militarily and will impose pressure on it as to surrender without fighting. The area is known for its ragged rocky geography and tribal atmosphere which makes it a fort for the opposition factions to indulge in battles that might last for many months.
The tension was not limited to the eastern fronts alone for it also reached the northern fronts in Daraa and those adjacent to rural Quneitra in the area of the death triangle which witnessed massive reinforcements that were not covered by the media, similar to what happened in the direction of As-Suwayda.
Sources have told Enab Baladi that Assad's forces might entice the death tringle in the a few coming days, in a step to control the city of al-Harra and its strategic hill that reveals a wide area in the northwestern countryside of Daraa.
Tell al-Harra is one of the highest hills in the northern countryside of Daraa, overlooking a huge space of the rural parts of Daraa and Quneitra that helped the opposition factions control them rapidly after they captured the hill in October 2014.
Al-Zaubi explains that Assad's forces' action is so far an introduction, for the shelling is random and is not concentrate, which means that the current movements cannot be classified as a real battle to the day.
He expects that Southern Syria will be heading towards the phase of military escalation, pointing out that the factions are ready and capable of combating any of Assad's forces attacks.
Monitoring the last day's escalation, Assad's forces shelling corresponded to the statements issued by America, which al- Zuabi views as an attempt at mocking the international community's statements.
What Are the Factions Holding on to?
With the approaching military confrontations, a light must be shed on the points of strength and the shortcomings of the opposition factions, which will be a card to show their power and ability or weakness in the expected battle.
In Southern Syria, a number of factions are in action and the majority are under the "Free Army". On top of these factions are "al-thawra Army," "Shabab al-Sunah," "Army of Free Tribes," "Yarmouk Army," "Omari Brigades," "Falojat Horan Brigade," "Jaysh al-Islam," the "Artillery and Rocket Regiment," in addition to "Hay'at Tahrir al-Sham" which spreads in most of the military fronts.
As a preemptive step, the factions announced the formation of a central operations room in Daraa to repel any advance by Assad's forces, followed by a step similar to the Quneitra factions that consolidated their military operations in the "Al-Fath Al-Mubin" operation room.
At the beginning of June, the factions put a show of power through a military parade that coincided with the arrival of the first of Assad's forces' military convoys and was translated as an attempt to "highlight their position" before the regime and its Russian alley.
Last week, talks on social media referred to some of the factions' reception of a new support from the United States, which had completely halted its funds early in 2017.
Informed sources told Enab Baladi that a limited portion of second generation "TOWII" were offered to the "Artillery and Rocket Regiment" being a specialist in these missiles and trained on using them.
The sources added that the Daraa factions possess a large quantity of "TOW" guided missiles, but they lack heavy vehicles, especially tanks, few of which are deployed on specific fronts only.
Daraa is directly linked to Jordan, the borders of which are the faction's main gateway to receiving arms from supportive countries, headed by America. But in the past few days, the Kingdom has taken measures on its borders as a preemptive step for any attacks, including the deployment of heavy weaponry.
The Jordanian position is also not clear while Al-Zoubi did not deny the Jordanian moves on the borders, considering them a precautionary measure and routine procedures for fear of any attack on the Jordanian army, stressing that the factions are located less than six kilometers from the borders, and in some areas not more than 600 meters.
Jordan hosted most of Southern Syria-related international meetings on its territory. The most recent was the reception of the Israeli Prime Minister Benjamin Netanyahu, and it is considered the most prominent party in defining the future of the region in the coming days, being the neighboring country with a border of 375 kilometers.
On another track to determine the future of the south, Egypt has entered its own negotiating circle, a step similar to what it has done previously in the Eastern Ghouta and northern Homs.
The entry came suddenly under an initiative presented by the " Syria's Tomorrow Movement" to a Russian delegation that met with it on the Syrian territory. It included reaching a solution in the south in the same scenario witnessed by the cities and towns of the northern countryside of Homs countryside.
A source from "Tomorrow Movement," wishes to stay anonymous, told Enab Baladi that the Russians welcomed the initiative and considered the northern countryside of Homs model the most successful in Syria, because it did not lead to a massive displacement of the people and went away from the military option, protecting residential neighborhoods from destruction.
The source added that the meeting was held on Friday, 22 June, and the Russians indicated their intention to proceed with the model of Homs countryside in Daraa, but after the transfer of the initiative to Jordan, which is a key party and without which any agreement in the region cannot be implemented.
The Egyptian intervention included steps to form the constitutional committee, especially after talks about Turkey's intention to acquire the list of Syrian opposition candidates. According to the source, A delegation from the "Higher Negotiations Committee" met with the Egyptian Foreign Minister Sameh Shukri and discussed the mechanism for developing the political solution in Syria and the steps necessary to identify the candidates in a balanced manner.
As-Suwayda is a fundamental point that cannot be separated from the future of the South. It has abandoned the political and military discourse over the last seven years, until it topped the political landscape again with the military reinforcements that reached its northern and western countryside and the Russian delegation that visited it to determine its future.
On June 21, a Russian delegation visited As-Suwayda, where a closed meeting joined it with Akl Sheikhdom of the Druze denomination to discuss the future of the governorate.
According to "Suwayda24," which covers the governorate's news, the meeting was held at the building of As-Suwayda Provincial Department, attended by Russian officials, major security leaders, the rectorate of Akl Sheikhdom and the area's prominent figures.
The sources said that the meeting was to discuss the internal situation in As-Suwayda and touched upon the local armed factions, in addition the conditions of the western countryside and the protection of civilians.
And said that the Russians talked about the existence of "terrorist" organizations in the governorate, including the movement of "Rejal al-Karama" and about possible security solutions or reconciliations in the region.
Sources from As-Suwayda told Enab Baladi that meeting discussed the the future of the governorate and the hierarchy of the military administration in the next stage.
They added that the Russians' visit aims to find out the details of the management of the whole governorate, being a prominent point in Southern Syria and has a strong connection with Daraa governorate.
The meeting was attended by Bishop Saba Esper, members of the region's Russian Reconciliation Center, Issam al-Hussein, head of the provincial council, Hassan al-Atrash member of the central committee of the Baath Party, Sheikh Najdo al-Ali, director of Islamic endowments in As-Suwayda and Sheikh Saud al-Nimr, as a representative of the area's tribes.
The Movement has also prohibited any violations against or on the part of As-Suwayda and threatened against abusing the status of Jabal al-Arab or its people and refused to hold some of As-Suwayda governorate's people as accountable for what is happening in Daraa governorate, stressing that As-Suwayda is not the only front from which the military operations are triggered.
Since the beginning of the Syrian revolution in 2011, the Syrian regime has tried to win the loyalty of Syrian minorities, as a card, to support its political and military narrative and has attempted since the arrival of its reinforcements to Southern Syria to "create sedition" through missiles that landed in several residential neighborhoods, which led to the death of a number of civilians.


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Time: Whose side is it on?
Sometimes I look at the younger riders and wish I was a 20 Something or a 30 Something. Not just to have a younger body but to have more time. Time! More years still ahead; to ride, to learn, to experience with my horse. I'm a 67 year old Senior and I plan on riding till I'm dead. Yes! But realistically I don't know how many more years I can ride, train and compete at the level I am now. That is why I look at the youngsters and wish I could turn the clock back.
What is it like to be a 20 Something and a rider and have a full time job and maybe family as well? I decided to talk to a 20 Something, 27 to be exact, and find out. Her name is Zoe Cameron.
Zoe do you find it hard to balance the riding and the other parts of your life?
Zoe: Hell yes! My job for a start. I mean, I love it. I love it because I make enough money to be able to have a good horse and ride, train, compete. That's why I love it. The job is pretty much fun and my boss is ok with me taking some days off for competition in the summer. So…it's all good.
Does he understand your love of riding and horses?
Duckworth, that's my boss, he's a polo player. So he's cool with it. I get on pretty well with him. His first name is Clarence but I always call him Duckworth. He's a Brit and he says it reminds him of being in school.(She chuckles) He went to some fancy private school and they all called each other by their last names so he thinks it's amusing that I do that, says it takes him back.
Zoe: You mean Fred? My Significant Other. (Zoe rolls her eyes as she says this) He's started talking about "taking our relationship to the next level". (She says this with a tone of mimicry in her voice). Well……I don't know what universe he's living in but I don't have time for any "next level". I'm cool with where we are now. Marriage? Kids? I'm just not into that right now and I just do NOT have the time for it. I've got a full and I mean FULL time job. I've got four people working under me now and if I miss a beat, and I mean miss a SINGLE beat, those 20 Nothings will be on me like dogs to dinner and cut me off at the knees. For cereals!
So there is a lot of competition in your workplace?
Zoe: You got it! I am seriously good at my job and I am moving up in the firm but like I said……they'd be like…..cutting me off at the knees!
How does your riding fit in?
Zoe: Keeps me sane. Absolutely keeps me sane. My horse, Deutschmark….. fabulously talented horse. Got the body and the brains. My coach, Phyllis, says we can make it to Grand Prix. Seriously! And I believe her. We did amazing this summer at the St.George and Inter 1. Next year…. on to the Inter 2. You know what?
Cynthia wants me to go to Florida for the winter season. She thinks it would be a great experience for Deutschie and me. Wouldn't that be awesome? (Then her smile fades.) But there's no way.
Zoe: Well….Duckworth might be cool with me taking a few extra days in the summer for shows but a couple of months in the winter? No. No way.
Have you told Cynthia this?
Zoe: Yeah but she says that I have the horse for it and I should ride the Grand Prix before I turn 30 and (Zoe's voice trails off and she looks out the window. Then she looks back at me.)I just can't do it. Can't afford to do it.
Zoe: Ah, no. If it was a business venture my Dad would go for it but a horse thing? No. My Mom would totally go for it if it was for a big wedding to some gazillionaire but otherwise? No.
Could you save up, do it and then look for another job when you get back?
Zoe: Maybe but I'd like to add some more job titles to my resume with this firm before I go out there into the craziness of job market again. So…maybe…..later. But Deutschie is already 13 so I can't leave it forever. I don't know. I just don't have the time to do everything I want to do. Just don't have the time.
So Zoe has the years ahead of her but she doesn't have the time to do things now.
Well, Dear Readers, I'm sure you have guessed that Zoe is in fact, a composite of several young women I know, some riders and some not and a few bits of myself at age 27.All of them are women caught in the squeeze between time for life and time for a career.
Time. I may not have a lot of it ahead but I have it now. Present time is on my side. Yes it is.
Next Post Ancient? Or just Old?
My daughters are close to this point with them graduating from university next spring. And, with a ranch project coming along, they have no idea what they want to do particularly after having one of their best riding seasons over the summer. I told them to enjoy the present, that they will know when the other part of life beckons. It helps that their instructors also have said to prepare themselves when they step back from riding.
That is a big transition. I remember my daughter going through that as well.


ERC Celebrates our 30th Anniversary!
As our founder, Dr. Susan Wu, has said, it's hard to believe that ERC is now 30 years old! Each ERC contract location had its own unique celebration, but each one started with that sweet video of Susan and Jimmy talking about the Red Envelopes. If you missed the video, you can still view it on ERCNet. In the near future, we'll have the recording from the 30th Anniversary celebration in Huntsville with Susan and Jimmy talking to our folks about the early days of ERC…it was a treat!
The 30th Anniversary cake for the JETS employees at Johnson Space Center.
The RPS ERC family proudly showing their red envelopes!
The ERC family at JETS at Johnson Space Center.
Sue Muehlhauser, Susan's secretary at UTSI, spoke at the Huntsville Celebration.
Tom Giel (ESSCA), former UTSI employee working with Susan, and now ERC employee.
Kenny Frame, Jimmy and Susan Wu, and Ernie Wu at the Huntsville Celebration.
Jimmy Wu sharing a story from the early days of ERC. He's a very animated speaker!
A sea of cookies await the folks at TOSC for their celebration!
Great shot of Kenny, Susan, Jimmy and Ernie watching the Red Envelope video.
Dr. Roscoe Lee: 50 years of service!
September 2017 marked an important milestone for Roscoe, as that date marked his 50th anniversary working for NASA – quite an accomplishment! With this milestone, Roscoe became the first ERC employee to reach that level of service, so a big congratulations and thanks to Roscoe for his years of service to the space program!
Roscoe has been featured in the ERC blog before. Several years ago, this youtube video was created to tell the "Roscoe Lee Story – Nearly 50 years with NASA." You'll hear Roscoe talk about the incredible journey of important work that he has performed. His career with NASA began in 1967 working on the Apollo missions, the Apollo Soyuz project with the Russians, the Space Shuttle missions, and the International Space Station.
As Roscoe says in the video, "…teamwork is required for success." Roscoe, it is an honor to have you as a member of the ERC Family team!


Mindful Moments will soon be expanding it's program offerings to include a full day preschool program.
We are looking for experienced, curious and passionate child care educators to join our team (aiming to be open January 2019).
Candidates must be self motivated & looking to work with a team of mindful educators.
Harmony, happiness & job satisfaction at work is guaranteed, if you have the right mindset and understand that children require our full attention.
Could you be that person ?
Please forward your cover letter and resume to be considered for this exciting opportunity!


The interactive pieces of the workshop focused on honing climate change messaging, learning about efforts underway in various departments to prepare for climate change, exploring approaches from other cities, and brainstorming cross-departmental emissions reduction and climate adaptation approaches in Boulder. One outcome of the workshop is a common benchmark to plan against – over 95% of workshop attendees felt comfortable using a 2-6 degree Farenheit average temperature change by 2050 as their planning guide and where able to understand how that average change, and the implications for variability in any given year, translated into specific local impacts. Future workshops will drill down into adaptation and mitigation strategies that departments can use to help meet the city's climate and resilience goals.
Boulder's climate change action plan has three complementary goals: prepare for changes that are already coming, prevent climate change from getting more severe, and ensure that all residents, especially those residents with the fewest resources, are protected the negative impacts of climate change. To be successful, climate adaption, equity, and mitigation have to be part of the mission of all city departments– not just the usual suspects like sustainability and environmental affairs.
Boulder leaders are designing and implementing a series of workshops that build a shared commitment to climate change preparation and resilience. The interactive workshops bring together people from every city department to interact with scientists and climate professionals. Together they consider the local impacts of climate change, develop a shared understanding of the range and impacts of future changes, and explore how each individual department can prepare for those impacts. The workshops also promise to develop new collaborative approaches where multiple city departments work together on sector specific issues that they all impact (e.g. climate impacts on forestry). However, it could also branch out to coordinating with city residents to develop joint approaches with multiple benefits. For example, in other cities, Health and Human Services and the Parks Department have launched evening events that bring people out of their homes and into cooler parks on hot evenings. Not only does it help residents cope with heat, it builds social connectedness.
TEX staff are part of the team that planned these workshops, and TEX and Boulder plan to work together to share the workshop template with other communities. Boulder is contributing to TEX for this work, and TEX will use that funding to support work with communities who have less financial resources.
The City of Boulder created a poster to share the goals and outcomes of their TEX collaboration at the 2016 AGU Fall Meeting. Click here to download the poster!
The City of Boulder in Colorado has undertaken many progressive climate-related initiatives, from signing the Kyoto protocol to passing a Climate Action Tax. But as the city prepared to launch its Climate Commitment document and lead a community process, it realized that one critical group that had not been fully engaged in the process was its own staff. It became clear that for organizational change to occur and for the city to meet its goals, city staff needed to develop a deeper understanding of the importance of the climate goals while also learning better how to use these goals to guide their long-term planning.
In early 2016, the city launched a year-long "Climate Leaders" initiative which comprised of a series of workshops that brought together over 70 staff members with climate scientists and experts in climate adaptation planning. The first two workshops, billed as Climate 101 and 201, reviewed the best available scientific information about climate threats and potential impacts, and worked with participants to understand how climate changes could affect diverse city functions. These interactive workshops also explored ways to help city staff feel comfortable preparing for a significantly different climate and discussed ways to communicate this information to the public.
From there the group split into two tracks. A "mitigation" track focused on the ways in which Boulder could meet its aggressive emissions reduction targets. The "adaptation" track developed integrated scenarios for citywide planning to highlight Boulder's vulnerability to climate change and guide adaptation planning.
Bringing these two conversations together is helping city staff to explore critical linkages between mitigation and adaptation, develop common messages to build community support for climate action, and inform comprehensive climate resiliency planning.
We will describe how Boulder successfully partnered with scientists and planning experts to program a year of interactive workshops to bring diverse city staff into the climate action process. We will share outcomes from the development of the integrated climate scenarios vulnerability assessment and adaptation planning. Lastly we will share key lessons learned that will be valuable to other cities and jurisdictions engaging in similar climate action.
MaryAnn Nason is the City of Boulder Water Conservation and Outreach Coordinator. MaryAnn manages programs including water conservation, flood safety, stormwater pollution prevention and other water related outreach programs (wastewater, water treatment, etc.). She holds a B.A. from the University of Colorado in Environmental Studies.
Russ Sands is the City of Boulder Watershed Sustainability & Outreach Supervisor. Russ currently manages a team of 6 Public Works/Utilities staff and is charge of the Water Conservation, Stormwater Quality and Utility Outreach Programs for Public Works/Utilities. The latter has not only includes flood and drought outreach efforts but increasingly focuses on building interdepartmental connections that seek to leverage and support larger city and community goals around climate, resilience and sustainability. He holds a B.S in Environmental Science from Metropolitan State University of Denver.
Greg Guibert is Boulder's first Chief Resilience Officer. Prior to his appointment, Greg worked at the National Center for Atmospheric Research (NCAR) as a risk and development project specialist to develop and manage innovative projects that address complex social and environmental challenges at the intersection of science, policy, and practice. Greg holds a Master's of Urban and Environmental Planning from the University of Virginia and a Bachelor's degree in Geography from Vassar College in New York.
Brett KenCairn is the City of Boulder's Senior Environment and Climate Planner. He has worked throughout the western US in community-based natural resource management and sustainable development. As Senior Environment and Climate Planner for the City of Boulder, Brett is responsible for coordinating the development of the community climate action plan and the city organization climate change preparation strategy and participates as a team member on the city's clean energy development team.
Dr. Rajul (Raj) Pandya is the director of AGU's Thriving Earth Exchange. Prior to working with AGU, Raj worked as the Director of Education and Outreach at the National Center for Atmospheric Research. Raj has been lucky enough to lead internships and mentor students, teach in college and high school, do research with communities internationally and in the US, and work on digital libraries. He has published in areas including thunderstorms, student learning, workforce development, diversity in science, citizen-science, and public health.


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New York Giants Near Alabama
New York Giants ALL LOCATIONS
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New York Giants Information
The New York Giants are a professional American football team. The franchise is based in the New York metropolitan area. It was established 94 years ago on August 1, 1925, and played its first season in the same year. The Giants compete in the NFL as an East Division member of the National Football Conference. The home games of the club are played in MetLife Stadium East Rutherford, New Jersey, whereas the team is headquartered in the Quest Diagnostics Training Center East Rutherford. Some of the former home fields of the Giants include Polo Grounds (1925–1955), Yankee Stadium (1956–1973), Yale Bowl (1973–1974), Shea Stadium (1975), and Giants Stadium (1976–2009).
The Giants are under the ownership of John Mara and Steve Tisch (he is also the chairman of the team). The president of the club is John Mara, whereas the general manager is Dave Gettleman. A few of the nicknames given to the Giants are Big Blue, G-Men, Jints, Now York Football Giants, and a few more. The team has won eight league championships, including four NFL championships and four Super Bowl Championships. They also won eleven Conference championships (NFL Eastern: 1956, 1958, 1959, 1961, 1962, 1963 and NFC: 1986, 1990, 2000, 2007, 2011) as well as sixteen Division championships. The team appeared thirty-two times in the playoffs.
The Giants have three colors in their official uniform, including dark blue, red, and white. The team inducted many players to the Pro Football Hall of Famers such as Red Badgro, Rosey Brown, Harry Carson, Frank Gifford, Joe Guyon, Mel Hein, and many more.
Head Coach: Joe Judge
2019 Season Record: 4-12
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(WXIA) -- You'll see less construction than usual on Atlanta's interstates and highways this weekend -- and you have the Braves to thank for it.
Due to Friday's home opener at Turner Field, as well as spring break, the Georgia Department of Transportation has suspended its typical weekend roadwork.
No lane closures will take place on the surface streets around Turner Field. However, emergency-related closures are always a possibility.
Hall County's unemployment rate was 5.1 percent last month.
(WXIA) -- Metro Atlanta's unemployment rate climbed to 6.2 percent in January.
That's up from December's 6.0 percent, but considerably lower than the 7.1 percent in January 2014.
Hall County's unemployment rate was 5.2 percent this January.
Georgia Labor Commissioner Mark Butler said the rate increased because of the loss of about 35,100 jobs, mostly seasonal positions.
But the Atlanta area had the largest January-to-January job growth ever recorded, adding 104,400 jobs over the course of the year.
The metropolitan Atlanta area consists of 29 counties, including the recently added Morgan County.
Metro Gainesville had January's lowest jobless rate, at 5.2 percent. The Heart of Georgia-Altamaha region had the highest, at 8.3 percent.


WMG, formerly Warwick Manufacturing Group at the University of Warwick, is using Dymola modelling technology to help develop the next generation of low carbon vehicles.
The programme, part of the £29 million West Midlands-based Low Carbon Vehicle Technology Project (LCVTP), is an advanced research project which will ensure Britain's leading role in shaping the future of passenger transport.
WMG and partners Jaguar Land Rover, Tata Motors European Technical Centre, Zytek, Ricardo, MIRA and Coventry University, have created 15 separate workstreams covering everything from battery cells to aerodynamics. WMG is leading the development of the overall plant models, concentrating on powertrain technologies, the group of components that generates power and delivers it to the road surface.
Dymola is a world leading multi-domain modelling and simulation tool. It enables engineers to visualise a joined up, seamless understanding of vehicle architecture and dynamics, and allows them to simulate everything from control system design to driveability. This enables the teams to investigate and optimise every component before physically building a vehicle, drastically reducing time to market.
Dymola is being used alongside WARPSTAR (WARwick Powertrain Simulation Tool for ARchitectures), a flexible tool developed by WMG and its partners using the MATLAB/Simulink® modelling environment.
A low carbon future requires a fundamental reassessment of how companies approach vehicle engineering – from advanced battery and motor technology for efficient propulsion, light weight materials and aerodynamics to minimize lost energy, through to intelligent control systems for efficient operation in urban environments.
The low carbon agenda has for the first time in decades changed the rules of engagement in the auto industry. The need for completely new components, sourced from new partners and assembled into new modules, is forging new alliances.
The LCVTP is set to place the West Midlands as the primary source of low carbon technology for the global marketplace. The initiative has been made possible through a £19 million investment (£9.5million funding from regional development agency Advantage West Midlands and £9.5 million from the European Regional Development Fund Programme (ERDF)); and a further £10 million contribution from the industry partners involved.
The project should be a significant job creator in the UK by 2020, with the majority in the West Midlands. It will also safeguard jobs in the supply chain as businesses switch to low carbon opportunities. The LCVTP brings Advantage West Midlands' investment in low carbon vehicle initiatives to £41.2million. The agency has already invested more than £22million in a range of low carbon vehicle projects.