text:
Support the Paul Amendment to Repeal FATCA!
This Is an Urgent Campaign to Repeal FATCA ALERT!
This week the Senate version of the tax reform bill will come to the Senate
floor. The Campaign to Repeal FATCA has learned that Senator Rand Paul
(R-Kentucky) plans to offer as a floor amendment his bill S. 869 to repeal
the so-called "Foreign Account Tax Compliance Act (FATCA).
The Campaign to Repeal FATCA is asking everyone immediately to contact your
Senators with this simple message:
You can find the contact information for your state's two Senators
here. Given the partisan divide
in the Senate, it is especially important to contact Republican Senators. If
your state has one from each party, contact the Republican first!
Here is a suggested draft message you can use via the email contact. (NOTE:
If you are contacting a Democratic Senator, please delete the sentence in
red referring to the Platform.):
Dear Senator [Name]:
As your constituent, I strongly urge you to support the floor amendment to
be offered by Senator Rand Paul to repeal the so-called Foreign Account Tax
Compliance Act, or FATCA. Despite the claims of its sponsors when it was
passed in 2010, FATCA is a failure in its supposed aim to recover offshore
tax assets hidden by "fat cats." Instead, it has imposed massive costs on
middle class Americans, violated Americans' privacy without probable cause,
and led to a huge increase in U.S. citizenship renunciations. The 2016 GOP
Platform called for the repeal of this wrongheaded Obama-era law – and the
Republican Party should keep its promises! Please support the Paul Amendment
to repeal FATCA!
[Name, location]
In addition, if you represent an organization, please issue a statement in
support of the Paul Amendment to repeal FATCA and send it to Senate offices
and distribute via social media.
Time is of the essence. Thank you for your help at this critical moment!
Nigel Green and Jim Jatras
Co-Leaders, Campaign to Repeal FATCA
www.RepealFATCA.com
Further information points on why FATCA must be repealed follow:
The GOP called for repeal in its 2016 Platform. "The Foreign Account Tax
Compliance Act (FATCA) and the Foreign Bank and Asset Reporting Requirements
result in government's warrantless seizure of personal financial information
without reasonable suspicion or probable cause. Americans overseas should
enjoy the same rights as Americans residing in the United States, whose
private financial information is not subject to disclosure to the government
except as to interest earned. The requirement for all banks around the world
to provide detailed information to the IRS about American account holders
outside the United States has resulted in banks refusing service to them.
Thus, FATCA not only allows 'unreasonable search and seizures' but also
threatens the ability of overseas Americans to lead normal lives. We call
for its repeal and for a change to residency-based taxation for U.S.
citizens overseas."
FATCA fails in its stated purpose of recovering tax revenues. On enactment
in 2010, FATCA was scored as raising about $800M per year. According to
Texas A&M law professor William Byrnes, actual recoveries are closer to
$100-200M per year and falling. FATCA will soon cost more than it brings in.
FATCA is an indiscriminate violation of privacy. FATCA data reporting
requires no probable cause or even suspicion. Unlike domestic 1099s and W2s,
no taxable event is required. Compliance burdens fall disproportionately
upon people of moderate means, few of whom are engaged in evasion or owe any
tax. Foreign banks' denying services to Americans leads to increased U.S
citizenship renunciations.
FATCA is costly. Estimates of global compliance spending rely on aggregation
of per-institution costs: millions for each small bank, hundreds of millions
for a big one. One projection puts cumulative cost at $58 to $170 billion.
This is an order of magnitude greater than any recoveries from FATCA.
FATCA relies on Obama-era Executive overreach. Because of other countries'
privacy laws, FATCA is unenforceable without so-called "intergovernmental
agreements" (IGAs) invented by Tim Geithner's Treasury Department. The IGAs
are not authorized by statute or submitted to the U.S. Senate as treaties.
FATCA threatens our domestic financial industry. Reciprocal "Model 1" IGAs
promise "reciprocity" from U.S. domestic banks. This threatens massive
FATCA-like costs on U.S. banks and consumers.
Keeping FATCA on the books risks future harm. The OECD, which for years has
sought to extinguish personal financial privacy and create a worldwide
financial data fishbowl, has praised the IGAs as a "catalyst" to that end.
If FATCA remains on the books, the next Democrat Administration and Congress
may press reciprocity on domestic American financial firms to create a
global FATCA – or "GATCA." This is the opposite of what the GOP Platform
promised.
Transparency is when citizens monitor government.
When government monitors citizens, that's tyranny.
Author Patricia MoonPosted on November 29, 2017 Categories FATCATags extra-territorial taxation, FATCA, HARM
It's the Subpart F Rules, Stupid
There is a very good discussion going on over at Brock regarding the "Transition Tax" and the unintended consequences that may be passed on to expats. Fortunately, this cross-posted comment by USCitizenAbroad demonstrates how we have moved from the complicated verbiage of statutes/IRS Code to something understandable. (!!!!!)
@Plaxy
First, there has never been ANY background discussion that suggests that a transition tax would apply to individual shareholders (whether in the US or abroad) of non-U.S. corporations.
Second, ALL of the discussion has been in the context of finding a way to impose taxation on the offshore trillions supposedly owed by the corporate shareholders of foreign corporations,
Third, notice that some of the discussion (for example in the two Morse articles) raises the question of how the tax should be designed (inside the income tax system, outside the tax system, subpart F, etc.).
What I think has happened is that, by making a subpart F inclusion the mechanism for taxing the "offshore trillions", it has theoretically drawn individuals (and by extension Americans abroad) into harm's way.
Because the subpart F rules do apply to the individual shareholders of Canadian Controlled Private Corporations (even though originally intended for corporations), and the mechanism to capture the "offshore trillions" is subpart F, individuals have been drawn in.
Had the mechanism for inclusion been something other than subpart F, I suspect that we would not even be having this discussion. But, what discussion? What is generating the discussion?
Interestingly, the ONLY discussion of the impact of this on individual Americans abroad comes from the tax compliance industry in Canada (because they are the only group considering individual Americans abroad) and probably tax people in other countries.
There is no final legislation and the rules are complex. So, what happens is that one tax person says: "These rules apply to Americans abroad" and the rest follow. They have few (if any) independent thoughts on this. It is very difficult to read and understand this proposed legislation. They read legislation literally. They don't read contextually. They in effect "make up the law". We have seen this happen time after time.
Now, what are individuals to do? It's obvious that this tax was NEVER intended to apply to them. But, (I expect) the tax compliance industry will work hard to force people to pay up. What is clear is the tax compliance community will NOT (if they adopt the "party line") tell people that the tax does not apply to them. They won't be willing (and understandably so) take the risk. But, they don't know any more about this than you or I.
So, what should be done? What should the response be?
At the present time there are still many unknowns. But, I really don't see how people can pay a tax that
was never intended for them
will confiscate their retirement plans
is in effect a retrospective tax – they are (possibly) going back in time and deeming income that was not taxable at the time to be taxable now.
is not based on any "event" whatsoever – this is why it is pure confiscation. Even if it were 1 cent it would be pure confiscation because there is no event triggering a tax.
(5) reaches directly into the tax base of Canada.
Since July the Government of Canada has been discussing this same pool of Canadian capital. This whole discussion is confusing theory, reality and practicality. This cannot and should not be paid.
My suggestion I guess is:
Get your tax preparer to reveal his/her position on this before work on the returns commences. If the preparer will not sign the returns without paying this tax – then find another preparer or do them yourself or don't file at all. Obviously the pressure to renounce has become even more intense.
What you cannot due is let the tax compliance community turn your retirement savings over to the IRS based on a law that was never intended to apply to you.
Furthermore, I think that tax preparers have a moral obligation to make their position on this known in advance.
Author Patricia MoonPosted on November 27, 2017 Categories CBT, US Tax ReformTags CCPCs, CFCs, extra-territorial taxation, HARM1 Comment on It's the Subpart F Rules, Stupid
Seven Simple Points to be Made Re: Transition Tax and CFCs
This comment from the Isaac Brock Society makes basic points to be made with regard to the proposed "Transition Tax" in both the House and Senate Tax Reform Bills.
Every expat who knows there are private individuals who are incorporated in their country should be contacting relevant government representatives giving them the information that U.S. Tax Reform may impose a "transition tax." As it is widely surmised that this is an unintended consequence, now is the time to bring it to the forefront and create awareness/resistance to this. We have appealed to the U.S. government to change the relevant sections (or give some clarification); if this does not occur, we cannot allow the compliance community to decide what the law is. In the past this HAS occurred with regard to the treatment of PFICs, applying the Exit Tax retroactively to people who renounced prior to 2008 and putting "minnows" into OVDP/OVDI. Time to stand up and say "NO!"
The following points would work for any country; just change the numbers in point 1 and "Canadian" to your country (generally) and the ministers' names to yours.
1. There are approximately one million Canadian citizens who are resident in Canada and are also U.S. citizens (mostly Canada/U.S. dual citizens – with the U.S. citizenship conferred on them because of a U.S.
birthplace).
2. It's safe to say that a significant number of these "dual citizens" are "small business owners", who carry on business through Canadian Controlled Private Corporations.
3. It is possible and likely that many of these "small business" owners have (since 1986 or the date of incorporation) accumulated earnings.
These accumulated earnings operate as their "retirement pensions" ( a fact that has been widely discussed with Finance Minister Morneau and Prime Minister Trudeau as part of their discussions on Canadian tax reform).
4. The United States imposes taxation on individuals based ONLY on U.S.citizenship (even if the person lives in Canada). The United States is the only advanced country in the world to impose "citizenship-based taxation". The United States is the ONLY country in the world that BOTH:
1. Confers citizenship based on birth in the country AND 2. imposes "worldwide taxation" based on citizenship.
5. Many of the Canadian Controlled Private Corporations owned by Canadians with dual citizenship are deemed under the Internal Revenue Code of the United States, to be "U.S. shareholders", of what are called "controlled foreign corporations". To repeat, from a U.S. perspective the Canadian shareholders of Canadian Controlled Private Corporations, may be considered to be the "U.S. shareholders" of "Controlled Foreign Corporations".
6. The United States is in the middle of a process of amending the Internal Revenue Code. It appears that both the House and Senate versions of the bill, include a provision that would require the "U.S. shareholder" of a "controlled foreign corporation" to include directly in his/her personal income, a percentage of the total amount of the "retained earnings" of the "controlled foreign corporation" (which could well be a Canadian Controlled Private Corporation"). This percentage would be based on the amount of the retained earnings which have accumulated since 1986. See for example Sec. 14103 of
The Tax Cuts and Jobs Act
(See the section starting on page 375 with Sec. 14103 beginning on page391.)
7. Although it is not completely clear that this provision would apply to the Canadian shareholders of Canadian Controlled Private Corporations, the "literal reading of Sec. 14103 suggests that it may.
Certainly there have been (and this is where the danger lies) some tax professionals who are adamant that this would apply.
It is extremely important that this danger be understood by all "stake holders" in Canada. This would include Finance Minister Morneau and members of the small business community in general.
Some discussion of this problem may be found here.
Author Patricia MoonPosted on November 25, 2017 Categories Compliance Industry, Ethics, Law & Morality, Legal Issues, US Tax ReformTags 877A, CCPCs, CFCs, extra-territorial taxation, HARM, OVDI, OVDP, PFICs1 Comment on Seven Simple Points to be Made Re: Transition Tax and CFCs
ADCS-ADSC & ADCT Letter to U.S. Congress
— In this press release we ask United States Congress to fix a problem in the present House/Senate tax bills that targets certain Canadian citizen/residents who own an incorporated business — and more broadly — to "stop imposing worldwide taxation on any Canadian resident".
The press release is being sent in part to members of U.S. Congress and also to Canadian politicians who should be in the business of defending Canadian citizens from harm caused by a foreign state.
The focus of the press release is intentionally on "Canadians". The word "American" is not mentioned. Our use in the text of the now-offensive term "U.S. person" (defined by the U.S. Internal Revenue Service) does not imply that U.S. person law applies to any Canadian resident or that any of these so-designated (by the U.S.) Canadians have ever consented to be U.S. persons.
U.S. CONGRESS: DO NOT CONFISCATE OUR SMALL CANADIAN BUSINESSES AS PART OF YOUR TAX REFORM
Dear Congressperson,
On November 16, 2017 Rep George Holding, of the House Ways and Means Committee, in an exchange with Chairman Brady, urged that as part of tax reform that: The United States join the rest of the world by adopting "residence-based taxation". This would END the U.S. current practice of imposing worldwide taxation on certain residents of other countries.
As U.S. law currently stands, many Canadian citizen/residents (who are deemed by the U.S. to be "U.S. Persons") find themselves subject to U.S. taxation (ON THEIR CANADIAN INCOMES and CANADIAN ASSETS), even though they live in Canada and pay taxes to Canada.
The application of U.S. tax law into Canada – a principle enforced by FATCA – has profoundly negative consequences, some of which are intended and some of which are unintended.
This is a request that the wording of the United States "Tax Cuts and Job" bill be revised so as not to harm, even more, small Canadian businesses possibly included, we believe inadvertently, by your proposed tax reform legislation.
As your tax Senate and House tax reform bills are presently worded, Sec. 14103, for example in the Senate bill, might be interpreted to confiscate a significant percentage of the retained earnings of certain small "Canadian Controlled Private Corporations". This is evidently part of broader legislation to implement "territorial taxation", in order to enhance the competitiveness of publicly traded U.S. multinational corporations.
We believe that this section is intended to apply ONLY to the foreign subsidiaries of U.S. domestic corporations. However, a strict reading of the language of the bill suggests that this "transition tax" MIGHT also be paid by those who are deemed by your country to be "U.S. persons" living overseas who happen (as is common in Canada) to own an incorporated small business. The "minnows" swept up by your bill will then include small businesses such as a one-person incorporated medical doctor's clinic, should the owner be designated by U.S. law to be a "U.S. person".
We do not believe that this was your intention and ask that you fix the language of the bills accordingly. Surely you would agree that "territorial taxation" for U.S. multinational corporations does NOT mean that the United States should extend its taxable "territory" to Canadians who happen to own small Canadian Controlled Private Corporations!
As part of U.S. tax reform, we conclude by asking that the United States stop imposing worldwide taxation on any Canadian resident AND clarify that the "Tax Cuts and Jobs" Bill does NOT apply to Canadian residents who are shareholders of Canadian Controlled Private Corporations.
Carol Tapanila
Stephen Kish
On behalf of the
Alliance for the Defence of Canadian Sovereignty (www.adcs-adsc.ca ) Information@adcs-adsc.ca;
Alliance for the Defeat of Citizenship Taxation (citizenshiptaxation.ca)
Contact Mr. John Richardson at johnrichardson@citizenshipsolutions.ca
Author Patricia MoonPosted on November 24, 2017 Categories ADCS-ADSC, ADCT, CBT, Law & Morality, US Tax ReformTags CCPCs, CFCs
Parsing Proposed Legislation -Intended Confiscation or Not?
cross posted from The Isaac Brock Society
Is there a duty to obey a law that was never intended to apply to you,
even if the literal reading of he law suggests that it may/does apply?
USCitizenAbroad says
@Karen notes:
At the bottom of page 62 of the section by section summary:
" For the last taxable year beginning before the dividend exemption takes effect, a U.S. corporation that is a 10-percent shareholder of a foreign corporation must include in income its pro rata share of the undistributed, non-previously-taxed post-1986 foreign earnings of the corporation. The subpart F inclusion is taxed at rates of 10 percent for earnings attributable to liquid assets and 5 percent for other earnings. (emphasis added)"
Clearly, the Senate intends for the deferred foreign income to be taxable only to corporate shareholders. I'm not sure how the actual legislative text accomplishes this.
This is what the Senate summary says. This may even be what the Senate actually intends. I have spent considerable time trying to read through this crap to determine whether the "literal reading" of the proposed statute (regardless of legislative or Senate intent) can be interpreted to apply to the shareholders of Canadian Controlled Private Corporations. Although I do NOT believe that the intent is to apply this "transition tax" to Canadian Controlled Private Corporations, I believe that the literal reading of Sec. 14103 would include Canadian Controlled Private Corporations. So, the Senate Bill is no improvement (with respect to Americans abroad than the House bill).
What follows is my reading/parsing of the proposed legislation. I hope that those who are "wiser than I" can demonstrate why I am wrong.
1. What is the purpose of Sec. 14103?
The purpose is to confiscate a percentage of the retained earnings of certain corporations as a way of funding the move to territorial taxation for corporations.
2. Do the U.S. individual shareholders, including Americans abroad get the benefits of territorial taxation?
3. To what kind of corporations does Sec. 14103 apply?
The section applies to any "deferred income corporation".
4. What is a "deferred income corporation"?
"The term 'deferred foreign income corporation' means, with respect to any United States shareholder, any specified foreign corporation of such United States shareholder which has accumulated post-1986 deferred foreign income (as of the close of the taxable year referred to in subsection (a)) greater than zero."
Note that U.S. citizens are United States shareholders. So the question becomes …
5. What is a "specified foreign corporation"?
"For purposes of this section, the term 'specified foreign corporation' means— (A) any controlled foreign corporation,"
By "this section" they mean Sec. 14103 – noting that Sec. 14103 is the section that prescribes who is pay the "transition tax". It does NOT mean Sec. 14101 which is the section that prescribes who gets the benefit of "territorial taxation".
So, a "specified foreign corporation" appears to include any "controlled foreign corporation" which would include a very large number of Canadian Controlled Private Corporations!
Notice how similar the language in Sec. 14103 "specified foreign corporation" (who is subject to the tax/confiscation) is to the language in Sec. 14101 (who gets the benefit of territorial) "specified 10-percent owned foreign corporations". The definition of "specified 10-percent owned foreign corporations" in Sec. 14101, is restricted to U.S. corporations that are the owners of a foreign corporation. See:
''(1) IN GENERAL.—The term 'specified 10-per-cent owned foreign corporation' means any foreign corporation with respect to which any domestic corporation is a United States shareholder with respect to such corporation."
Conclusion …
The language in both the House and Senate bills seem to allow for the confiscation of the retirement plans of some Shareholders of some Canadian Controlled Private corporations. (In July of 2017, Mr. Morneau – of Trudeau Government Finance Minister fame) began a discussion of how the Government of Canada could attack this same pool of earnings. It appears that the U.S. Government may be interested in that same earnings pool.)
Actually, I remain convinced that this is not the intent. So, I will conclude with the question that I asked in my last comment on this issue:
Is there a duty to obey a law that was never intended to apply to you, even if the literal reading of he law suggests that it may/does apply?
Legislative Text of US Senate Tax Reform Bill
What follows is a very parsed down excerpt from Sec. 14103
1 SEC. 14103. TREATMENT OF DEFERRED FOREIGN INCOME
2 UPON TRANSITION TO PARTICIPATION EX-
3 EMPTION SYSTEM OF TAXATION.
4 (a) IN GENERAL.—Section 965 is amended to read
5 as follows:
6 ''SEC. 965. TREATMENT OF DEFERRED FOREIGN INCOME
9 ''(a) TREATMENT OF DEFERRED FOREIGN INCOME
10 AS SUBPART F INCOME.—In the case of the last taxable
11 year of a deferred income corporation which begins before
12 January 1, 2018, the subpart F income of such foreign
13 corporation (as otherwise determined for such taxable year
14 under section 952) shall be increased by the greater of—
15 ''(1) the accumulated post-1986 deferred for-
16 eign income of such corporation determined as of
17 November 9, 2017, or
20 December 31, 2017.
1 ''(d) DEFERRED FOREIGN INCOME CORPORATION;
2 ACCUMULATED POST-1986 DEFERRED FOREIGN IN-
3 COME.—For purposes of this section—
4 ''(1) DEFERRED FOREIGN INCOME CORPORA-
5 TION.—The term 'deferred foreign income corpora-
6 tion' means, with respect to any United States
7 shareholder, any specified foreign corporation of
8 such United States shareholder which has accumu-
9 lated post-1986 deferred foreign income (as of the
10 close of the taxable year referred to in subsection
11 (a)) greater than zero.
12 ''(2) ACCUMULATED POST-1986 DEFERRED FOR-
13 EIGN INCOME.—The term 'accumulated post-1986
14 deferred foreign income' means the post-1986 earn-
15 ings and profits except to the extent such earnings—
16 ''(A) are attributable to income of the
17 specified foreign corporation which is effectively
18 connected with the conduct of a trade or busi-
19 ness within the United States and subject to
20 tax under this chapter, or
21 ''(B) in the case of a controlled foreign
22 corporation, if distributed, would be excluded
23 from the gross income of a United States share-
24 holder under section 959.
1 ''(e) SPECIFIED FOREIGN CORPORATION.—
1 ''(1) IN GENERAL.—For purposes of this sec-
2 tion, the term 'specified foreign corporation'
3 means—
4 ''(A) any controlled foreign corporation,
6 ''(B) any section 902 corporation (as de-
7 fined in section 909(d)(5) as in effect before the
8 date of the enactment of the Tax Cuts and Jobs
9 Act).
Author Patricia MoonPosted on November 23, 2017 Categories Legal Issues, US Tax ReformTags territorial taxation
U.S. CBT is Enforced ONLY by the Compliance Industry
#FATCA is enforced NOT by the USA directly but by the banks & U.S. #CBTax is enforced ONLY by the compliance industry https://t.co/GWwaGrnmbO
— Homelander NOT (@Homelander_NOT) November 21, 2017
This post is based upon a comment of USCitizenAbroad at Brock. It makes a very important point that all of us should keep in mind generally but especially if the Tax Reform Bill passes with the insidious clause concerning taxing the retained earnings of small CFCs (which really isn't INTENDED but………..)
USCitizenAbroad says:
@Plaxy quoting @Badger writes:
badger: "What is with the reverence for or tacit acceptance of US
law on Canadian sovereign autonomous soil?"
Exactly. Why accept US law, US/Canadian duals residing in Canada?
Stop filing and renounce.
After having watched the proceedings at both the House Ways and Means Committee and the Senate Finance Committees, I can say with absolute confidence that:
– the members of the these committees don't even understand how these provisions affect Homeland Americans
– have no consciousness that the USA has "citizenship-based taxation"
that would apply to people living outside the United States
– do NOT understand the technicalities of how "territorial taxation" for corporations is being implemented
– have no understanding that there is a "transition tax" and/or that it could possibly apply to the owners of Small Business Corporations living outside the United States.
There is no possibility that the "transition tax" could possibly have been intended to apply to the small business corporations owned by Canadian citizens resident in Canada.
BOTH Mr. Reed and Mr. Nightingale state their views that the application of the "transition tax" to CCPCs is NOT intended; but
The plain wording of Sec. 4004 (by making the statute apply to individual U.S. persons as defined in the subpart F rules which reference back to the definitions in Sec. 7701) means that it would apply to any U.S. citizen (regardless of where he has "escaped to") anywhere in the world.
Please remember that the U.S. legislators:
– equate citizenship with residence (didn't you know that a citizen is a resident and a resident may or may not be a citizen)
– don't know there is a world beyond the USA
– are therefore NOT thinking at all about the application of U.S. law outside the USA
Also, again I make the point that the Internal Revenue Code does NOT anywhere explicitly mandate "citizenship-based taxation" – referring only to "individuals" and then allowing the inference that "individuals"
include "citizens". My point is only that the application of U.S. tax laws outside the USA is not something that is even on the radar in Washington.
Also, to the extent that U.S. laws impact Americans abroad, they are NOT enforced directly by the USA anyway. The USA has downloaded enforcement to the banks and tax compliance professionals. Think about it this way:
FATCA is enforced NOT by the USA directly but by the banks. Yes, your friendly neighborhood bank is a FATCA enforcement agent.
U.S. CBT is enforced ONLY by the compliance industry. If you stay away from the tax professionals you will not be within their "enforcement area" … The ONLY people with U.S. tax problems are those who have attempted U.S. tax compliance. Leaving aside the complicated legal/moral/ethical issues of "to comply or not to comply" (tax compliance people are amoral) the individuals who have been brutalized are those who have attempted compliance. The people who must renounce are those who have complied. Those Americans abroad who want to retain U.S. citizenship do so by NOT attempting compliance.
So, where are we now?
The early commenters from the compliance industry are saying: Bad luck, although NOT intended, this new and exciting instrument of confiscation applies to you. Okay, they should also add to their "news bulletin"
that: Because they are compliance "professionals" that they will NOT sign the returns of anybody who does NOT pay this tax.
This poses an interesting question:
What is a poor compliant person, dependent on his tax professional, doesn't believe this tax applies to him and needs professional help to do? Completing his return (that form 5471 is not easy for an individual to do). Will you let your friendly neighborhood tax professional force you to turn your retirement fund over to the IRS?
The question it seems to me is this:
Is there a duty to obey a law that clearly was NEVER intended to
apply to you and can be construed to apply to you ONLY because of
the literal wording? That is the question.
This is the question that should have been asked in some other interesting contexts which include:
Were the PFIC rules really intended to apply to the Canadian mutual funds owned by Canadian residents?
Were the S. 877A Exit Rules intended to apply to those who clearly relinquished prior to 2004?
Were OVDP and OVDI appropriate compliance options for Americans abroad who have lived for many years outside the USA?
Were the CFC rules intended to apply to Americans abroad, etc. …
Are you going to allow your assets to be confiscated yet again?
When the "Call Of The Condor" becomes the "Law Of The Land"
Neither the IRS nor Congress really know how these laws apply (or not) outside the USA. What happens is that the compliance industry becomes the single most important vehicle for determining how these laws are to be interpreted. Once enough tax people start behaving in a certain way, the others are sure to follow. Put it another way: In general (and I am not referring to either Mr. Reed or Mr. Nightingale) tax professionals know less about this than you do. So, if you call a tax professional and
"Does the Sec. 4004 "transition tax" apply to Canadian business
corps" they will just ask their associate". Yes, it really is that
bad. So, I would NOT rely on "tax professionals" to give you good
advice on how these laws might or might not apply to Americans
abroad.
But, to get back to my original question:
I expect that different people will have different answers to this question. But, I don't think that the "tax professionals" are worth asking. After all, they can't sign your returns unless you comply with their interpretation of the law.
I have previously explored this issue in the following comments (which I am including here so that I can find them again later):
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-9/#comment-8045126
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-14/#comment-8049389
isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-25/#comment-8053507
And on the compliance choice …
Author Patricia MoonPosted on November 21, 2017 Categories Compliance Industry, US Tax ReformTags extra-territorial taxation
The Ownership and use of the U.S. Person which includes a Citizen as an Instrument of Foreign Policy – Parts V & VI
cross-posted from citizenshipsolutions
originally published July 7, 2016
The Ownership and use of the U.S. Person Which Includes a Citizen as an Instrument of Foreign Policy
by John Richardson
Part V – Why Americans abroad are renouncing U.S. citizenship …
Put it this way:
Ireland recently opened a museum honoring the achievements of Ireland's diaspora.
The United States continues to control the lives of U.S. citizens living outside the United States. "When in Rome, Live As A Homelander".
The United States continues to cause other nations to discriminate against U.S. citizens who leave the United States.
The United States continues to use U.S. citizens as instruments of foreign policy.
The United States continues to threaten it's diaspora (citizens abroad) with penalties and sanctions
It's no surprise that renunciations of U.S. citizenship are growing! They will continue!
Part VI – The injustice of the S. 877A "Exit Tax" as applied to Americans abroad
For many Americans abroad to renounce U.S. citizenship they will be required to pay an Exit Tax. Those who are "covered expatriates" will be required to pay an "Exit Tax" that is based on the value of their non-U.S. assets, their non-U.S. pensions and possibly more. A detailed explanation is NOT the purpose of this post. For information on the S. 877A Exit Tax, I refer you to:
Renouncing US citizenship? How the S. 877A "Exit Tax" may apply to your Canadian assets – 22 P… https://t.co/TyXIrhCmWE via @ExpatriationLaw
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 7, 2016
In closing …
"Let us not look back in anger, nor forward in fear, but around us in awareness"
Posts in this Series:
Part I The U.S. "Giveth" and the U.S. "Taketh" – How the U.S. uses "citizenship" as a weapon against individuals
Part II – U.S. Citizens living abroad – "Life in the penalty box"
Part III – I'm a "Toxic American", but it's not my fault – How U.S. regulation makes "U.S. citizens undesirables in other nations
Part IV – The use of U.S. citizens as instruments of foreign policy
Part V – Why Americans abroad are renouncing U.S.
Author Patricia MoonPosted on November 21, 2017 Categories CBT, Citizenship, U.S. Tax Colonization, US ExceptionalismTags citizenship as a weapon, extra-territorial taxation
The Ownership and use of the U.S. Person which includes a Citizen as an Instrument of Foreign Policy – Part IV
To leave the USA one needs a passport and when it comes to having a U.S. passport …
22 U.S. Code § 212 – Persons entitled to passport https://t.co/sVDeQndIt7 via @LIICornell – allegiance to USA is a necessary condition!
No passport shall be granted or issued to or verified for any other persons than those owing allegiance, whether citizens or not, to the United States.
"U.S. citizen" vs. "U.S. Person" – What is the difference?
All U.S. citizens are U.S. persons, but not all U.S. persons are U.S. citizens
A U.S. citizen is a "U.S. Person". But, not all "U.S. persons are U.S. citizens".
My impression is that:
– the term "U.S. citizen" is a term that is used to describe one as a person who has rights or membership, benefits and some responsibilities to the United States
– the term "U.S. Person" is a a broader term that "U.S. citizen". It is defined differently in different pieces of legislation. The class of "U.S. Persons" is broader than the class of "U.S. citizens". The class of "U.S. Persons" often includes "Green Card holders", perhaps "U.S.
Nationals", etc. For example, S. 7701(a)(30) of the Internal Revenue Code defines "U.S. Persons" as "citizens or residents".
The term "U.S. Person" appears to be used in a context that imposes prohibitions and sanctions directly on the "U.S. Person" and/or is used to imply "U.S. ownership and control" over the person. Often this "ownership or control" is exercised in the context of U.S.
interaction with "foreign nations". When used in the context of interaction with "foreign nations", the "U.S. Person" is often used as an instrument of foreign policy.
When you see the words "U.S. Persons" in a U.S. law or regulation you can assume that a "control", "sanction" or "implementation of foreign policy" will follow. "U.S. person" is a term signifying "sanction" or "control". https://t.co/9u56Srrex6 pic.twitter.com/h58qTEcRRC
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 19, 2017
There is no one definition of "U.S Person" …
Thinking more about the different kinds of "U.S. Persons" … https://t.co/azs8Jrl0Ug
Are you a "U.S. Person"? It's defined differently in different pieces of legislation https://t.co/839GxdG7Wm
Restrictions on U.S. currency going to Cuba …
When it comes to Cuban Democracy, here is how a "US Person" is defined: pic.twitter.com/ru2OKOGbDZ
When it comes to "Corrupt Foreign Practices", "U.S. citizens"
are "domestic concerns" …
Foreign Corrupt Practices Act (FCPA) https://t.co/3EKQIbIYrJ – applies to "US Persons"
It has become clear that United States enforces its extra-territorial law by pressuring other governments, organizations and entities (under threats of sanction) to do "U.S. dirty work for the U.S.".
Some examples include:
– the use of the OECD to enforce the U.S. Corrupt Foreign Practices Act
– the FATCA IGAs to impose U.S. taxation on the citizens and residents of other nations
– as per Juan Zarate in "Treasury's War" the "blacklisting of foreign banks"
The OECD employs "full-time lawyers" whose mission is to enforce the U.S. Corrupt Foreign Practices Act worldwide!
Bobby, you may be a national hero, but don't even consider playing chess in Serbia …
Citizens as property of government – The tragic story of Robert James "Bobby" Fischer https://t.co/bahGaUnp20 via @USCitizenAbroad
Restrictions on "U.S. Persons" under FATCA and the FATCA IGAs …
26 U.S. Code § 1471 – Withholdable payments to foreign financial institutions https://t.co/ajJXn3pZur @LIICornell – "U.S. Person" referenced
When it comes to FATCA, the definition of "U.S. Person" is broad …
Who is a U. S. person ( or has U.S. indicia) according to the IRS | Maple Sandbox https://t.co/N2PeEtFyrf – mostly describing "residents"
Posts in this Series
Prologue – U.S. citizens are "subjects" to U.S. law wherever they may be in the world
Part I – The U.S. "Giveth" and the U.S. "Taketh" – How the U.S. uses "citizenship" as a weapon against individuals
Part II – – U.S. Citizens living abroad – "Life in the penalty box"
The Merry-Go-Round of "Unintended Consequences"
This provision is not designed to catch individuals (I think), and certainly not Americans abroad – they are collateral damage. it's incredibly unfair.
A little more than 10 days ago, an article by a Canadian tax lawyer claimed the proposed House Bill contained two very startling changes that would affect #AmericansAbroad:
BAD NEWS FOR BUSINESS OWNERS
If your cross-border client owns a business, his tax position "may get substantially worse," Reed says, noting two areas of concern:
a one-time 12% tax will be imposed on all income previously deferred from U.S. tax in Canadian (foreign) corporations; and
new complex rules make it difficult for U.S. citizens who own Canadian (foreign) corporations to defer active business income.
The 12% tax is part of the transition to a territorial corporate tax system.
"Although perhaps unintentional, since U.S. citizens will not benefit from a territorial model, the new rules impose a 12% tax on any cash that has been deferred since 1986," says Reed.
He offers the example of a U.S. doctor who moved to Canada in 1987 and has since deferred income from personal tax in her medical corporation, and invested it — resulting in a potentially significant tax bill.
Deferring active business income
New punitive rules that apply to US citizens who own a business. Currently, most US citizens who own a Canadian corporation that is an active business don't pay tax on the company's profits until they take the money out. The House plan changes this. It imposes a new, very complicated, set of rules on US citizens that own the majority of a foreign corporation. The proposal would tax the US citizen owner personally on 50% of the entire income of the Canadian corporation that is above the amount set by an extremely complex formula. At best, this will make the compliance requirements for US citizens that own a business extremely complicated and expensive. At worst, this will cause double tax exposure for US citizens who own a Canadian business on 50% of the profits of that business.
This post was a response to the issues raised.
Today, another Canadian compliance professional made similar observations about the proposed Senate bill.
Still nothing about residency-based taxation. In fact, the international corporate tax proposals are going to make things significantly worse for Americans abroad who have corporations. https://t.co/iwdTtaJxDQ
— Kevyn Nightingale (@ustaxcanada) November 17, 2017
Kevyn Nightengale published an article on LinkedIn; excerpts below:
American? Own shares in a foreign corporation? Get ready for a pain in the wallet
by Kevyn Nightengale
Accumulated deferred foreign income
One thing they will do is apply an immediate tax (well, sort of immediate – it's to be paid over 8 years) to the retained earnings of those foreign subsidiaries. And there's some logic to this as well. Those earnings have been tax-deferred until now. If they fell into the "exempt" system in future years, US multinationals will have effectively gamed the system by keeping them offshore long enough to completely escape tax.
One problem is that if you're an American individual, and you own shares in a foreign corporation directly, this provision will create an immediate tax in your hands.
You won't get a foreign tax credit for the corporate tax (like a US domestic corporate parent). You won't get a special deduction (like a US domestic corporate parent). You just have to pay tax on the retained earnings.
It's a double whammy if you live abroad
If you live in a country where it's common to run a small business through a corporation (say, Canada), you already have enough double-tax issues to worry about (Subpart F, filing forms 5471, FINCEN 114, etc.). This new provision will probably lead to double taxation. And even if you can pay out dividends to limit that, it probably will create extra tax in your country. The US tax probably isn't creditable in your country (in Canada, it isn't).
Global intangible low-taxed income ("GILTI")
…… The shareholder (yes, including a US citizen living abroad, in the same country as the company) has to include an amount in his income.
The amount is the company's total income less a deemed return (10%) on tangible assets. This means that any type of income is caught. Companies that provide services are especially vulnerable, because they typically have only a small amount of tangible assets. Incorporated professionals are going to be hit hard. They'll be taxed on their companies' incomes, even if the company doesn't distribute it to them. And that tax will apply at full tax rates, not qualified dividend rates.
Can this be avoided?
I find it puzzling that both gentlemen indicate these policies are not intended to include #AmericansAbroad, yet act as if they have no choice but to "enforce" this if it becomes U.S. law. Haven't the "unintended" consequences of #FBAR caused enough grief for #AmericansAbroad? Why does everyone assume there is nothing that can be done to stop this from extending to expats? If the law is not meant to be applied that way, does not specifically indicate they are to be included, how can they claim they must do so because it is "U.S. law?" That is clearly not the correct position to take. And what will the result be if people are mad/scared enough to simply not deal with this U.S. situation any longer?
Merely "collateral damage?" If all agree this is an unintended consequence why would u folks insist on enforcing it? The US doesn't even understand it- won't be coming after u. Bet people will draw a line here……… https://t.co/O6spTzM2xq
— Patricia Moon (@nobledreamer16) November 18, 2017
John Richardson comments:
There are many who interpret the proposed changes, to include a provision that would lead to the confiscation of a significant portion of the retained earnings of small business corporations, owned by Americans abroad. I wrote the above referenced post and used the example of a U.S./Canada dual citizen living in Canada who owns a small business corporation. By the way, it is very common for Canadians to utilize small business corporations to carry on their businesses.
This specific provision is found in Sec. 4004 of the Proposed tax bill.
The way it would operate (after identifying those who own small Canadian Controlled Private Corporations in Canada) would be to:
1. Focus on the retained earnings of the corporation since 1986. Note that these earnings were either NOT subject to U.S. taxation at the time or were already included in the income of the shareholder via the subpart F provisions.
2. Impose a tax of either:
House Bill: 14% (cash) or 7% (non-cash)
Senate Bill: 10% (cash) or 5% (non-cash)
on the retained earnings by including those earnings in Subpart F income.
Understand that for many Canadians these small business corporations contain their retirement savings. So, the bottom line is the the United States proposed to literally confiscate these assets.
Understand also that Sec. 4004 is part of the section that creates the system of territorial taxation for U.S. corporations. The idea is that the "transition tax" is a way to repatriate the earnings which have not returned to the USA (obviously because of confiscatory taxation). After paying this "transition tax" those U.S. corporations will get the benefit of territorial taxation.
Understand also that U.S. individual shareholders of Canadian Controlled Private Corporations do NOT get the benefit of "territorial taxation"
but (if this is interpreted correctly) are still required to pay this.
What the USA, in it's great wisdom is doing, is to:
1. Retroactively go back and deem income that was NOT taxable at the time to be taxable; and
2. Use the mechanism of subpart F inclusion (I am not going to dignify this by calling it a tax) to CONFISCATE the asset.
Understand also that this is one more of a long line of indignities inflicted on Americans abroad that includes:
– the virtual confiscation of Canadian pensions (via the Sec. 877A Exit Tax rules applied to some who renounce U.S. citizenship) that were earned in Canada while the individual was NOT living in the United States; and
– the application of the 3.8% Obamacare surtax to distributions of from Canadian RRSPs (the equivalent of U.S. IRAs) and excluding distributions from IRAs.
I suspect that this will be the "straw that breaks the camel's back".
And "The Band Played On ….""
Author Patricia MoonPosted on November 18, 2017 Categories Ethics, Law & Morality, US Tax ReformTags CCPCs, CFCs, citizenship as a weapon, extra-territorial taxation, HARM, SubpartF Income2 Comments on The Merry-Go-Round of "Unintended Consequences"
The Ownership and use of the U.S. Person which includes a Citizen as an Instrument of Foreign Policy – Part III
Part III – I'm a "Toxic American", but it's not my fault – How U.S. regulation makes "U.S. citizens undesirables in other nations …
U.S. citizenship-taxation, enforced by FATCA, does have an impact on the economies of other nations.
There is evidence that this will negatively affect the job and career prospects of Americans abroad. "Citizenship-taxation" is increasingly affecting the way that nations and the citizens of other nations interact with "U.S. citizens". Because of the "immutable characteristic" of a "U.S place of birth", many U.S. citizens living outside the United States (assuming they are allowed to have a bank account in a FATCA world) have become undesirable as business partners.
See the following two accounts of discrimination against U.S.
citizens abroad
Exactly why does the US Government hate #Americansabroad so much? (Homelanders too) https://t.co/z7TWPxWVmz via @USCitizenAbroad
Good points that highlight, yet again, the absurdity and detachment of the U.S. political system from 9 million of their citizens now living in an ever globalized and ever more competitive world. The U.S. political class and presidential candidates disinterest in this ever-growing and important group of citizens only speaks to the total stupidity, general ignorance, global unawareness, profound provincialism and confirms a totally dysfunctional and archaic system that is today the United States. A country that attacks and harms its diaspora and through its laws has succeeded in turning its own citizens into international pariahs with international banks, in international business partnerships, in marriage and in the general perception outside of the U.S.
I recently met with three start-ups at a fair in Germany, two from the UK and one from Sweden. In my work as a headhunter they were hiring me to find them some talented people for their growing and successful startups. In all three cases, and each in separate meetings with me, the startups told me that they did not want any Americans or Europeans with U.S. Green cards or passports. They were all wisely warned by their banks and financial advisors not to bring any U.S. Persons into their business. Two of them knew the reasons and the risk that any American presence would bring to the business. The other one learned the hard way. They had an American investor who got them into his FATCA mess, reporting his holdings and his American tax consultant demanding the business's bank details and the personal details of the owners. They returned his investment, threw him out and agreed never again to get involved with any U.S. persons in their business. This is now widely known and even if FATCA and all of the other reporting requirements for Americans would be eliminated, the damage is already done. The perception out there is to avoid hiring any Americans and also avoiding their investments. They are too much trouble and their government is an intrusive bully that thinks it can control the entire world. That spirit is so foreign to the young brilliant startup minds out there today. The U.S. has become a has-been and definitely not seen as a cool place anymore.
The world has moved on and the U.S. politicians and presidential candidates still haven't realized that the world has changed since their anachronistic citizenship based tax system dating from the Civil War.
Truly, a nation of idiots.
"get rid of your U.S. citizenship, which was contaminating our German business or must sell your shares and leave." https://t.co/3131iTMxTR
As a former U.S. citizen, who renounced just in order to survive, as my four non-U.S. business partners gave me an ultimatum, either get rid of your U.S. citizenship, which was contaminating our totally German business and subjecting our company's accounts to U.S.
Treasury and IRS scrutiny, or you must sell your shares and leave. This all started upon the advice of our German bank, who said that they wouldn't deal with our accounts if there was any American/'U.S. Person'
involvement? Not to mention the personal impact on my mortgage, on my bank closing all of my investment accounts and everything else that every reader here knows all too well.
What amazes me most, and also amazes all of my personal and professional friends, all of them non U.S. persons, is how obedient and conforming the organizations supposedly representing the interests of U.S. citizens abroad are. With all that has happened, and especially now, subsequent to the Senate Finance Committee's "report" on tax reform, paying nothing but contemptuous lip service to the plight of US citizens abroad, it should be more than obvious that U.S. Citizens abroad are of absolutely no relevance for lawmakers and legislators in Washington. Yet, the attitude of all of the organizations supposedly looking out for and fighting for the rights of US citizens abroad has been to follow a very respectful path of presenting the case for change, as if they were dealing with a fair democratic system, that respects equal representation and justice. They look ridiculous, all of them! When I read that Democrats Abroad have been trying to push the "bandage" fix of 'Same Country Exception' for more than four years, with no result, I say that this is absolutely pathetic. When I see American Citizens Abroad sending endless delegations to Washington, year after year, and even opening an office there, only to see the interests of overseas Americans relegated to a footnote, with no action proposed n the recent Senate Financial Committee report, I would think that they should be embarrassed and ashamed, as they should be. It has taken the group Republicans Overseas over one year to formulate an intended lawsuit, which has been postponed endless times, with a "promise" to file it next week, I say that they too have not approached this in the right way. Too much damage has been done in the interim.
What astonishes all of my "foreign" friends is how passive, obedient and fearful U.S. people are of their government, especially when confronted with such outright injustice, literal extortion and destruction of their financial wellbeing and that of their families and business partners.
Even the ever law abiding Germans wouldn't put up with any of this and they would probably, en masse, as one lawyer friend told me, simply refuse to cooperate with any of this Byzantine filing of forms and endless intrusions into their privacy and that of their families and business partners. They would collectively refuse and file class action suits against the authorities behind these injustices worthy of a fascist totalitarian regime. Perhaps the Germans understand better than the Americans what this sort of thing leads to, when a society becomes so beaten down, so subservient, so fearful of authority that it complies with the most horrific and undemocratic "laws" and is unable to unite and simply say NO, collectively. Until Americans fight to recover some form of democracy and fairness, the ravages of FATCA will be but one in a coming litany of similar such abuses. To continue believing that they are dealing with democratic institutions and that reason and fairness will prevail is nothing but a naive attitude that will lead them nowhere, as we can now see with the recent Senate Finance Committee report.
Author Patricia MoonPosted on November 16, 2017 Categories CBT, Citizenship, U.S. Tax Colonization, US ExceptionalismTags citizenship as a weapon, extra-territorial taxation1 Comment on The Ownership and use of the U.S. Person which includes a Citizen as an Instrument of Foreign Policy – Part III


Gediminas has been computing since before computing was even possible for amiture programmers. His first memory of computers was loading games onto a system using audio tapes, and his first programming language was Pascal. He learned to code in a rather unusual way- his school didn't have any computers so his class would write algorhythems on paper and turn them in to the teacher. But this humble start fostered a love of complex code, sophisticated calculations, and high volume data, and if not working in IT, you would likely find him working as some sort of engineer.


Goldfish Films is a full service production company for international filmmakers and photographers who wish to shoot in the Netherlands – based in Amsterdam – facilitating TVC's, feature films, TV-series, industry films and stills photography.
Goldfish Films was established in 2005 by Boudewijn Visser. Boudewijn's experience in film and photo production is extensive. Over the last 20 years, he has worked as production manager, producer and agency producer with some of the busiest and most prestigious directors, cinematographers and photographers from all over the world. His comprehensive knowledge of the Dutch production scene ensures that Goldfish Films' clients will always be offered solutions that are reliable, cost effective and efficiently produced.
Goldfish Films is in the top 3 of 'dedicated' production service companies in Holland and provides the highest level of production support for all aspects of film, video, television, digital media and still photography.


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2015 Assembly
Observing the Arctic Council
Organized by the West Nordic Council 27. September 2017
The breakout session will focus on the following questions: What is the role of observers in the Arctic Council? How can they contribute to and influence the work of the Council? What should an inter-parliamentary organization like the West Nordic Council focus on in its efforts to contribute to and impact the work of the Arctic Council?
Friday, October 13, 17:55 - 19:25
Location: Ríma B, Ground Level
Last May the West Nordic Council was granted observer status to the Arctic Council. The West Nordic Council is currently developing the strategic framework for its observership for 2018-2020. The main overall objective is to decrease the democratic deficit in the Arctic by making sure that the voice of the inhabitants of the region is heard and their rights protected.
The session gives an insight into the work, role and influence of observers to the Arctic Council, with contributions from four different observers. A Senior Arctic Official in the Arctic Council will furthermore shed a light on how those governing the Arctic Council view the role of observers and the value of their contribution. The West Nordic Council hopes for a lively discussion that can provide valuable input into the work on the aforementioned strategic framework.
Bryndís Haraldsdóttir, Vice-President of the West Nordic Council, and MP, Iceland: Introduction.
Eirik Sivertsen, Chair of the Standing Committee of Arctic Parliamentarians (SCPAR), and MP, Norway: Arctic Parliamentarians and the Arctic Council
Nauja Bianco, Senior Advisor at the Nordic Council of Ministers: A Pragmatic Reciprocal Approach to Being an Observer in the Arctic Council – a Nordic Case.
Allen Pope, Executive Secretary of the International Arctic Science Committee: Contributing Scientific Expertise to the Arctic Council.
Árni Þór Sigurðsson, Ambassador for Arctic Affairs, Senior Arctic Official, Iceland: How can the observers influence the work of the Arctic Council?
ARCTIC TODAY

redpajama_set_name: RedPajamaCommonCrawl


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Home Guardian Clifton Towers tenants want 24/7 security
Clifton Towers tenants want 24/7 security
Tenants at the Housing Development Corporation's Clifton Towers in Port-of-Spain are calling for permanent security in and around the compound, saying they are now living in constant fear of bullying and reprisal attacks by gang members after the HDC evicted illegal tenants from the site.
The issue was addressed on Friday in the Parliament by Housing Minister Randall Mitchell, who told the House police and Defence Force members had evicted illegal tenants twice from the four-tower development, following complaints of unlawful activity and illegal apartment occupation.
Police and soldiers arrested and evicted 15 people and the compound is now being closely monitored, Mitchell said. (See page A8)
But speaking under strict anonymity yesterday, tenants told the T&T Guardian they fear for their lives as some of them are being labelled as "informants" and now their lives are being threatened by the criminal element.
One tenant, who spoke on condition of anonymity, said they are the highest paying tenants in all of PoS, at $800 a month. He said initially there was security for the project but that was stopped years ago.
"With that money we ought to be getting security personnel here, but they moved out the security years ago and it's years now we are trying to get HDC to put back security here for our safety," the tenant said.
"It is really the HDC fault now that the situation reach where it reach with gang people moving in and bullying us, threatening us, beating us and influencing our children. They selling drugs…all kinds of racket going on here and like the people in Government afraid to stand up against them."
The residents had also complained to former housing minister Dr Roodal Moonilal and former HDC managing director Jearlean John about their issues during the People's Partnership rule and noted it would only get worse. The tenants back then also called for the establishment of several programmes, including homework supervision, a daycare, gym, an adult training facility and meeting rooms.
But John advised the tenants then to form a residents' association to oversee the maintenance, security, operations and community relations of the entire development. The tenants were also advised to set up neighbourhood watch systems and to develop a good working relationship with the police station within the district.
Speaking about the response back then, a tenant yesterday said: "It is like they throw us to the wolves out there years ago when we are paying a rent here and HDC is the one who are supposed to be maintaining here and providing security for us. How could they ask us to do that for ourselves when we paying them for a service and to live here?"
Tenants also claimed that there are adverse plumbing issues, leaks and infrastructural damage and called on the current HDC management to deal with their issues.
"We want HDC to move in and see about upgrades and repairs and put back security for us because it is their fault that we are in this ugly situation," on tenant added.
Questions sent to the current HDC managing director Brent Lyons on the ongoing issue have gone unanswered.
Source: Guardian http://www.guardian.co.tt/news/2017-12-04/clifton-towers-tenants-want-24/7-security
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Gustav Kneip (3 April 1905 - 24 October 1992) was a German composer and conductor. He is best known for composing music to several radio dramas in Germany from 1927-1951. He also wrote some popular songs as well and composed the music to four films: Das Hermännchen. Nee, nee, was es nich' alles gibt (1936), Insel ohne Moral (1950), I'm Waiting for You (1952), and Der Glücksbringer (1957).

Born in Beningen, Kneip was trained at the Staatliche Hochschule für Musik Köln where he was a pupil of Hermann Unger. In 1924 he became a conductor at Theater Bonn where he remained for many years. In 1927 he began working as a sound engineer and radio composer for Westdeutscher Rundfunk. He continued to work as sound engineer and composer at the WR and for Saarländischer Rundfunk as well up into the early 1950s.

In 1951 Kneip relocated to Hamburg where he remained for the rest of his life. He continued to work as a freelance composer in his later years. He died in Hamburg in 1992 at the age of 87.

External links

1905 births
1992 deaths
German male conductors (music)
20th-century German conductors (music)
20th-century German composers
20th-century German male musicians

redpajama_set_name: RedPajamaWikipedia


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Archive - Friday, 11 May 2007
Pupils perform for Deep Purple legend
FOUNDER member of Deep Purple, Jon Lord, talks to the Hereford Times about his new work From Darkness to Light, being performed by more than 300 Herefordshire schoolchildren this weekend. To see a video of the interview click on the link at the top
Vandals strike at May Fair
VANDALS and thieves struck as the May Fair visited Hereford city centre. Graffiti was sprayed over a number of rides and damage was caused to a stall after items were stolen overnight. Police received reports of grafitti being sprayed on a number of
Cooker fires
HEREFORDSHIRE firefighters attended two cooker fires yesterday. Two crews from Leominster and Kingsland attended a fire at a heavily smoked-logged property in Millers Close in Leominster at 11.44am. An ambulance was called to attend to a male casualty
Ledbury's new service
HEREFORDSHIRE Council has opened a new customer service centre in Ledbury this week. 16th century listed building, St Katherine's, location in High Street Ledbury has been refurbished to provide a lighter, brighter more customer friendly place from
Motorcyclist hurt
A MOTORCYCLE and a car were in collision on a Ledbury road. The incident involved a BMW motorcycle and a BMW 130 car and police were called at 7.41am last Friday. The motorcyclist was taken to hospital after suffering a cut to the arm in the accident
HELP US CHOOSE THE HEREFORD TIMES BABY OF THE YEAR!
This is your chance to vote for the baby/toddler who you think deserves to be the Baby of the Year 2007! The special photographic supplement, with pictures of all the entrants, was published in the Hereford Times on 3rd May. Copies are available at the…
WIN TICKETS TO WONDERWOOL WALES!
Win a VIP Day at Wonderwool Wales! The festival takes place this year at the Royal Welsh Showground on May 19th and 20th May Be a winner with Wonderwool Wales - a highlight of the Smallholders and Garden Festival Wonderwool Wales is offering…
WIN TICKETS TO SEE THE HARLEM GLOBETROTTERS
WIN TICKETS TO SEE THE FABULOUS HARLEM GLOBETROTTERS IN ACTION AT THE NIA The Harlem Globetrotters' Nothing Like It 2007 world tour is set to bounce into The NIA on Friday 18 May 2007 and you could be there catching all the action for free!! The…


It was the night before his second tour of Afghanistan when Callum Darbyshire got involved in a fight that would see his life take a catastrophic turn.
Recruited by 2nd Battalion The Rifles in Northern Ireland when he was just a teenager, life as a soldier was all Callum had known.
His first tour of Helmand province had left him a 'completely changed man', suffering with an adjustment disorder, presenting similar symptoms to PTSD.
But things got yet harder in 2013, as he was gearing up for his second tour.
The night before the battalion's departure was fuelled by alcohol, excitement and anticipation of what was to come - a recipe which ultimately ended in disaster.
"The bins are being set on fire every weekend. The problem is, they are not frightened of the police."
He ended up in a drunken brawl, which meant by the age of 23 his army career was over for good and he was beginning a two-year stretch behind bars for causing grievous bodily harm.
It was the first time he had been in trouble with the police, or anyone at all.
"We had all been preparing to go out on our second tour at the army barracks and there was drinking involved which ended with aggression and violence," Callum recalls.
"The army completely changed me like it did many others and gave me a very different outlook on life.
"I was diagnosed with an adjustment disorder in 2012 and in 2013, I had become a serving prisoner at HMP Cheltenham."
Near the end of his stretch inside, Callum was moved to an open prison where the anxieties about getting a job once on the outside began to play on his mind.
Having left school at 16 and gone straight into the army, Callum had few qualifications to offer and now, a criminal record.
But those details didn't matter to the Timpson recruiter who came to visit the prison with the view to hiring offenders due for release.
He offered Callum a lifeline - the chance to work for the retailer before he had even been released.
Callum is now one of more than 1,200 ex-offenders who work for the family run group of cobblers and key-cutters, which opened its first store on Oldham Road in Manchester in 1884.
The company now own a total of 2,100 branches nationwide and its headquarters are based in Wythenshawe .
"Police did me a favour by shooting me"
Callum has worked for the company for three years, in which time he has been promoted three times, now working as a 'mobile manager' overseeing a number of branches across Greater Manchester .
"I was still in prison when I met a man called Darren Burns from Timpson who came to give a careers talk," Callum said.
"It was the first talk that had really appealed to me and due to my own worries about coming out of prison without a job, I showed interest straight away.
"For me, it wasn't just about coming out of prison and getting a job, it was being reintroduced to civilian life.
"Because of my time in the army I had no real experience of what it was like to be settled, until now."
The Timpson Foundation, which employs prisoners on day release as well as ex-offenders, was set up by CEO James Timpson after he befriended a young inmate at an open prison 15 years-ago.
His own background, which saw him grow up alongside young people who were fostered by his parents because their own parents were in prison, goes some way to explaining why he believes in second chances.
He has since gone on to chair the Employers Forum for Reducing Reoffending, a group of employers who offer a second chance to people with a criminal conviction.
The company regularly visit local category D prisons and recruit people like Callum, offering them specialist training to work in branches across the UK.
"After meeting Darren, I went down for an interview with about a dozen others but there was only one position so I didn't expect much," says Callum.
"It was the next day that one of the community advisors came over to me and told me I had been accepted for the job, I was esctatic.
"It meant I had one less thing to worry about - I would go on to start my job at Timpson before I was even released from prison."
The retailer has spent more than £692,000 on recruiting, training and mentoring for ex-offenders who now make up more than 10% of the company's work force.
"It just works," said training coordinator Peter Harris.
"We have area managers running their own branches who are ex-offenders and they are all doing an amazing job.
"There is this continuing culture of the revolving door and if a prisoner has a good job to go to they have a better chance of staying out of prison."
Callum works in Manchester but now lives in Widnes with his fiancée and five-year-old son. His stint in prison feels like a distant memory and he plans to carry on climbing the Timpson ladder.
"I started training at Timpson in Derby and once I was released I moved back to Widnes and continued my training," says Callum.
"That was until I went on to bigger and better things with Timpson. I went round and started covering managers days off and got a feel for what it would be like to manage a branch.
"It wasn't very long after that the area manager proposed a shop for me to manage in Warrington and I went on to manage that for about 15 months."
In October he was promoted for a third time to a role which involves travelling to branches around Greater Manchester and Cheshire, offering extra support and training.
"I am so grateful to the Timpson Foundation," says Callum.
"It works absolutely because they don't label you - they look at you as a person and they get to know you, not just the tag you were wearing before.
"Now it never even gets mentioned. They know it's there and that's it, they move on from it."
And the method seems to work.
In the week that saw department store Debenhams enter into administration, concern continues to mount over the future of the high-street.
Whilst many retailers announce branch closures, Timpson say they expect to open another 70 outlets this year alone.
And in March, the company received planning permission to build a 'Timpson university' near its head office in Wythenshawe.
The new training facility is expected to hold a 120-seat auditorium, two training rooms and a break-out facility, says Peter Harris.
"We have been running courses here for a number students but have realised as the brand continues to grow, we needed a bigger facility," he said.
The new training facility is expected to promote the businesses' unique 'upside management' structure which allows employees to run individual branches, trusting them to use their own personality and initiative, says Peter.
Timpson credit their flexible approach to management as one of the main reasons for their continuing success and growth.
The same philosophy applies to the perks afforded to employees, like the extra paid week off Callum has been given for his wedding in October.
"I never regret anything that's happened in my life," he says.
"I always wanted to be a soldier but I knew it wasn't going to be forever as I've always wanted a family.
"Now I get to go to work in the morning and do a job I enjoy, knowing I get to come home each night to see my family."


Not every job opportunity is guaranteed to have you sitting on the edge of your seat in the hopes that you'll land an interview. However, you should get that feeling at least every once in a while. If it's gone entirely, even for positions you think you should be excited for, it may be time to take a break.
Anxiety and desperation can build as your job search lengthens, and potential employers are sure to notice your discomfort. If you're starting to panic, take some time to calm down. You'll be more functional when you come back, and other people will likely see you in a more positive light.
Not reading the description thoroughly is one of the fastest ways to kill your chances of landing a job. In order to succeed, you need to understand the work being offered and customize your application to highlight the reasons you would be good at it. If you've become so jaded about job hunting that you scarcely take the time to read job descriptions any more, it's time for a break.
Sending in sloppy job applications can hurt you just as much as skimming job descriptions. It's always worth the extra time to proofread your e-mails and cover letters, double check that you attached the correct version of your resume, and make sure you got everyone's name right. If you find yourself cutting corners on your applications, take a breather until you can give the work the attention it deserves.


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Home Sports Messi will break the record for most men's World Cup appearances
Messi will break the record for most men's World Cup appearances
whether he lifts the trophy or not, Argentina captain Lionel Messi scheduled to end 2022 world cup With a record that has gone unbroken for nearly a quarter of a century.
With 24 matches played in the men's World Cup final going into this year's semi-finals, Messi needs to make just two more appearances in Qatar to become the most-capped player in the tournament's history.
As and when Messi takes to the pitch for Tuesday's semi-final CroatiaWill equal the career record of the 34-year-old forward Germany The great Lothar Matthäus, who played 25 World Cup matches for his country. Win or lose against Croatia, Messi will then almost certainly break Matthaus' record in Qatar when he reaches either Saturday's third-place playoff at the Khalifa International Stadium or Sunday's final at the Lucal Iconic Stadium.
world cup semi final
Matthäus' World Cup record stood for 24 years, as he made his 25th and final appearance for Germany in France '98 where, coincidentally, die manshaft They were defeated by Croatia at the quarter-final stage. A mainstay of midfield and defence, first for West Germany and then for the reunified nation of Germany, Matthäus' 25 appearances came in five World Cup finals between 1982 and 1998.
it was when he used to play inter Milanon either side of his two mantras Bayern Munich, that Matthäus won the World Cup for West Germany in Italia '90 as their captain. Later that year, he won the Ballon d'Or, and the following year he became the first player to be named FIFA World Player of the Year. Although Messi's combined number of Ballon d'Or and FIFA awards is nine and counting, that shouldn't detract from the fact that Matthaus was one of the greatest players of his generation and the worthy holder of the appearance record for so long.
– World Cup 2022: News and Features , Schedule , brackets
Lothar Matthäus captained West Germany in the 1990 World Cup Jean-Yves Ruzniewski / Tempsport / Corbis / VCG via Getty Images
Men's World Cup all-time appearance list
Ahead of the Qatar 2022 semi-finals, Messi can already claim to have played in more men's World Cup finals (24) than any other active player. Cristiano Ronaldo (22 games) Next among his contemporaries on the overall list.
Players with 20+ Men's World Cup matches
1 lothar matthaus West Germany / Germany 25 5 (1982–1998)
2 = Miroslav Klose Germany 24 4 (2002–2014)
2 = Lionel Messi Argentina 24 5 (2006–2022)
4 paolo maldini Italy 23 4 (1990–2002)
5 Cristiano Ronaldo portugal 22 5 (2006–2022)
6= diego maradona Argentina 21 4 (1982–1994)
6= uwe sealer west germany 21 4 (1958–1970)
6= vladislav zmuda poland 21 4 (1974–1986)
9 = kafu Brazil 20 4 (1994–2006)
9 = philip lam Germany 20 3 (2006–2014)
9 = grzegorz lato poland 20 3 (1974–1982)
9 = Javier Mascherano Argentina 20 4 (2006-2018)
9 = Bastian Schweinsteiger Germany 20 3 (2006–2014)
Messi is joint second with Miroslav Klose as the tournament's all-time top goal scorer, having scored 16 goals in 24 appearances across four World Cups, including a complete victory in 2014.
Messi and Klose are both a game above Italian legend Paolo Maldini, who has played 23 times Italy In the finals however never actually managed to win the trophy – finished as runners-up Azuri Earlier in 1994 after securing a bronze medal in 1990. Maldini retired from international football after the 2002 tournament, but was still playing for the team. AC Milan When Italy became world champion in 2006.
Messi became the holder of the Argentina national team's record for most World Cup appearances during the 2022 tournament, surpassing his idol Diego Maradona. Maradona, who made his country proud in 1986, represented Albiceleste on 21 occasions in the World Cup – a tally surpassed by Messi when he played against poland in their final group stage game.
Women's World Cup appearance record
No one has made more appearances at the Soccer World Cup than Kristine Lilly of the United States Guang Niu/Getty Images
Messi still has some way to go if he wants to surpass the all-time record in FIFA World Cups.
really, Paris Saint Germain The star will have to play till 2030 if he wants to even equal the record Brazil Midfielder Formiga, who represented his country in seven finals (1995, 1999, 2003, 2007, 2011, 2015, 2019).
Messi will need to appear in at least one more World Cup if he wants to equal the all-time Women's World Cup appearance-record holder with Kristine Lille. United States of america Played 30 games in five finals appearances between 1991 and 2007.
Lilly also won the World Cup twice with the USWNT, in 1991 and 1999, and earned bronze medals in 1995, 2003 and 2007 – more podium finishes than any other player in history.
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Genetic evidence for a causal role for triglycerides in CV disease
Literature - Budoff M. AM J Cardiol. 2016
Triglycerides and Triglyceride-rich Lipoproteins in the Causal Pathway of Cardiovascular Disease
Matthew Budoff
The American Journal of Cardiology (2016) doi: 10.1016/j.amjcard.2016.04.004
Epidemiological and clinical data have pointed at elevated triglyceride (TG) levels as a biomarker of CV risk. Evidence is now accumulating that TGs and TG-rich lipoproteins (TRLs) are causally involved in the pathogenesis of atherosclerotic CV disease (ASCVD). This article gives an overview of TRL metabolism, and summarises the evidence supporting a causal role of TGs and TRLs in ASCVD, and how this data can affect management of patients with dyslipidaemia.
Overview of TRL metabolism
LDL stimulates hydrolysis of the core TGs in the TRLs VLDL and chylomicrons. This produces VLDL remnants and chylomicron remnants, which are enriched in cholesterol relative to TGs. Some particles are not cleared but remain in the circulation, and are further modified to form cholesterol-enriched LDL particles.
Remnant cholesterol content can be calculated by subtracting LDL-c from non-HDL-c level. VLDL remnants and chylomicron remnants can be taken up by macrophages in the arterial wall. They may contribute to vascular inflammation and atherosclerotic plaque development and progression, without the need for oxidative modification as is required for LDL particles.
Full activation of LPL needs cofactor ApoC-II, and ApoA-V seems to enhance LPL activity. On the other hand, ApoC-III inhibits LPL and may be involved in hepatic VLDL assembly and secretion.
TRL metabolism and TG levels are further influenced by ANGPTL3 and 4, both by the secreted protein products and by genetic alterations in these factors.
Genetic evidence for TGs and TRLs in the causal pathway of ASCVD
Genetic data can help elucidate causal relationships between lipid biomarkers and disease.
Mutational analyses/exome sequencing
Several mutation in the LPL gene have been identified that reduce LPL activity. Carriers of a specific LPL mutation that reduces LPL activity, had higher TG levels (+78%) and almost five-fold higher CHD risk. Other substitution mutations were associated with smaller changes in LPL activity and CHD risk.
Also loss-of-function mutations in co-factor ApoC-II as well as ApoA-V have been described to be associated with elevated TGs. The opposite is seen when APOC3 is mutated. For instance, a cohort of Amish subjects who are carrier of a mutation in APOC3, had 46% lower TG than non-carriers and 65% lower risk of coronary artery calcification. Recently, ANGPTL4 mutations have also been found to associate with lower TG levels and CAD risk.
Genome-wide association studies
Genome-wide association study (GWAS) search have identified common genetic variants that represent CHD susceptibility loci in gene regions encoding ApoC-III, ApoA-V, ANGPTL3 and ANGPTL4. Multivariate analysis on identified SNPs that affect TG levels showed a strong association of TGs with CHD, after adjusting for both LDL-c and HDL-c effect size.
An epigenome-wide association study revealed that methylation at 4 sites of carnitine palmitoyltransferase 1A was strongly associated with TG and VLDL-c levels.
Mendelian randomisation studies
Mendelian randomisation studies have pointed at a relationship between three common APOA5 variants and non-fasting TG levels and calculated remnant cholesterol levels and risk of myocardial infarction. Other Mendelian randomisation studies found that remnant cholesterol levels correlated strongly with non-fasting TG levels and with observed CHD risk. Genetic variants in LPL were causally related to lower TG levels.
A Mendelian randomisation meta-analysis showed that an unrestricted allele score based on 67 SNPs known to be associated with TG levels, was associated with CHD as well. The same was true for a restricted allele score of SNPs that were only associated with TGs (not with HDL-c and LDL-c).
Thus, genetic data confirm the epidemiologic and clinical data and point at a causative role for TGs and TLRs in ASCVD.
Clinical implications
Since the effects of statins on TG levels are often insufficient, a TG-lowering agent may need to be added to this first line of treatment of lipid abnormalities. Prescription omega-3 fatty acids can be given as an adjunct to diet in adults with severe hypertriglyceridaemia (>500 mg/dL). Clinical trials demonstrated that prescription omega-3 fatty acids significantly reduced TGs in hypertriglyceridaemic subjects, with or without background statin therapy. Different types (containing eicosapentaenoic acid [EPA] and/or docosahexaenoic acid [DHA]) may have diverse effects on other atherogenic lipid parameters, including both beneficial and LDL-increasing effects.
These products are generally well-tolerated. TG-reducing niacin and fibrates, however, have tolerability issues and adverse side effects that may compromise treatment.
Omega-3 fatty acids may be beneficial in other ways than TG lowering, and effects on vascular and cardiac haemodynamics, arrhythmia, inflammation, endothelial function, thrombosis and production of anti-inflammatory mediators have been postulated.
Add-on therapy to statin therapy may therefore lower residual risk and provide CV benefit. The REDUCE-IT and STRENGTH outcomes trials are currently testing whether high dose prescription omega-3 fatty acid products reduce ASCVD in high-risk statin-treated patients.
Find this article online at Am J of Cardiol


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"Black-ish" Star Marcus Scribner to Help Create the Most Financially Literate Generation Ever in New Campaign
April 1, 2020 By MovieDebuts
Marcus Scribner plays a game of "Would You Rather?"
At least 72% of students say personal finance stresses them out, and COVID-19 could put an added financial burden on many young people, from disrupted financial aid to layoffs to a challenging post-graduation job market. Now more than ever, students need education and resources to help them understand how to make it through these difficult financial times.
That's why DoSomething.org, the largest organization for young people and social change, and HSBC, one of the world's largest banking and financial organizations, have partnered to launch "Would You Rather?", an engaging and impactful financial literacy campaign in time for Financial Literacy Month, designed to educate young people on making and saving money. The campaign is fully digital, so young people can learn to budget and save while safely social distancing.
Through "Would You Rather?", tens of thousands of young people will answer 5 amusing financial questions such as: To save money, would you rather… a) Share a cellphone with your grandma? or b) Share a closet with your ex? After each question, they'll receive a personal finance tip and, ultimately a comprehensive digital personal finance guide they can use and share with friends to take control of their financial lives.
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Students around the country will also be able to use the campaign's resources to facilitate in-person financial literacy workshops at their schools and communities. The finance guide and the workshops were created in partnership with HSBC expertise from the bank's "Your Money Counts" program and their partners at Greenpath Financial Wellness.
"Considering the student debt crisis, the cost of education, and the cost of just life in general, it's no surprise that money is a huge point of stress for students," says Carrie Bloxson, Chief Marketing Officer of DoSomething.org. "That's why we're so proud and excited to team up with HSBC for "Would You Rather?". Sure, the questions are amusing, but the impact is real — through the campaign, thousands of young people will educate their friends on financial literacy and empower them to take control of their financial lives."
Would You Rather with Marcus Scribner
In the campaign's PSA launch video, the magnetic and hilarious Marcus Scribner – best known for his role on Black-ish – hosts (and competes in!) a "Would You Rather?" style game show of questions and answers designed to engage and educate young people on the topic of financial literacy, and encourage them to sign up for the campaign.
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"For lots of people my age, dealing with money can feel intimidating, overwhelming, and honestly just stressful. That's why I'm so pumped about "Would You Rather?", because young people can learn really important stuff about making and saving money just by taking the kind of quiz they would take online anyway," says Scribner, 20.
Influencers who are passionate about financial literacy for young people are also lending their platforms and voice to support this campaign, including self-proclaimed "financial hype woman" Berna Anat, who paid off $50,000 in debt in 2017 and now creates helpful and informative financial content for Gen-Z and Millennials, Katherine Berry, whose popular YouTube channel is dedicated to life and work advice for young people, and Gen Z entrepreneur and creative strategist Jade Darmawangsa, whose podcast, "The Raisn Brand", helps other entrepreneurs use social media to grow their business.
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At HSBC, we want people to be able to achieve their dreams, for themselves and their families." said Kelly W. Fisher, head of corporate sustainability for HSBC Bank USA. "As a global bank, we know that cannot be achieved without people knowing how to manage their finances. We knew that DoSomething is the ideal partner to reach young people and help them build these skills for life."
The "Would You Rather?" campaign runs through April 30, 2020, and young people can sign up by visiting DoSomething.org/MONEY or texting MONEY to 38383. Those who complete the campaign by April 30 will be automatically entered for a chance to win a $2,500 scholarship from DoSomething.org!
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The Consumer Financial Protection Bureau's proposal, and promulgation, of its anti-arbitration rule led many companies to defer considering whether and how to update existing arbitration agreements—and, for those that did not utilize arbitration, whether to implement an arbitration system.
With the invalidation of the CFPB rule earlier this month—as a result of Congress's passage of a joint resolution of disapproval under the Congressional Review Act and the President's signature on that joint resolution—these issues are ripe to be addressed. In addition, new arguments being advanced in court to try to defeat arbitration may necessitate revision of existing agreements.
The regulatory and legal landscape following invalidation of the CFPB rule.
Pros and cons of implementing an arbitration system.
Drafting an arbitration agreement to withstand legal attack—including the new arguments being raised by arbitration opponents.
Revising existing arbitration agreements to ensure enforceability.
For additional information, please contact Liz Whitley at lwhitley@mayerbrown.com or +1 202 263 3092 .


Now as we have seen last week, Lot's wife did not listen. She looked back and turned into a salt pillar. She couldn't let go of all that she left behind.
Now notice something else in his instructions. The angel told them to escape to the mountains. Now what did Lot do? Did he listen? He didn't want to. Despite the fact that they just saved his life, he didn't want to go into the mountains. He was sure that he would die there. So he dared to negotiate with the angel in these dire circumstances and asked him to please rather allow them to go to a small village, Zoar, nearby. He was sure that his life would be saved there. Lot must have been so used to living among civilisation; he was scared to travel into the unknown into an unfamiliar territory. Now the angel was kind to him and granted him his request. And in the process the lives of those in this village, Zoar, was also saved. The moment Lot and his family reached Zoar, the angels rained down God's judgment on Sodom and Gomorrah and the surrounding areas. What a sight that must have been! Abraham also saw the devastation the next morning and must have been shocked that not even ten righteous souls were found. But I am sure that he was relieved that Lot was saved.
Now what is very interesting to me is that the very next verse tells us that Lot didn't stay at Zoar.
Isn't that ironic? God told Lot to go and live in the mountains, but he didn't want to. Instead he said he will die in the mountains, he rather wanted to live in Zoar. But now it seems that he will die in Zoar, so now he went to live in the mountains where he should have gone in the first place. It is clear to see that God knew best from the start. He knew that the people in Zoar were evil; in fact He wanted to destroy them along with Sodom and Gomorrah. He knew that Lot won't be able to live there, but He granted Lot's request, because he had to see for himself.
God knows best for us too. Sometimes we are scared of the 'mountains' where He is sending us to. Sometimes we do not want to go there. We are scared of the unknown, we are afraid of what might happen to us once we arrive there. We would much rather follow our own little plans and go and settle in 'Zoar' where it is seemingly more comfortable for us. We would rather negotiate with God, thinking that we know best. But as we've seen with Lot now, God really does know best. If He wants you to go to the 'mountains' then that is the best route to take. Do not doubt His goodness and Fatherly love. He knows what will be best for you. Trust Him with your life. A heavenly, eternal perspective is much better than an earthly one. Let go and let God. You might just save yourself a lot of heartache and pain if you listen to Him.
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