text:
Goods and Services Tax Ruling
GSTR 2000/28
Goods and services tax: attributing GST payable or an input tax credit arising from a sale of land under a standard land contract
Please note that the PDF version is the authorised consolidated version of this ruling and amending notices.
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Context of attribution
This document is a ruling for the purposes of section 37 of the Taxation Administration Act 1953 . You can rely on the information presented in this document - which provides advice on the operation of the GST system.
[Note: This is a consolidated version of this document. Refer to the Tax Office Legal Database (http://law.ato.gov.au) to check its currency and to view the details of all changes.]
1. This Ruling is about attribution of Goods and Services Tax ('GST') payable or input tax credits under the A New Tax System (Goods and Services Tax) Act 1999 ('GST Act') arising from a sale of land under a standard land contract. All legislative references in this Ruling are to this Act unless otherwise stated.
2. The Ruling explains when to account for GST payable or input tax credits on the sale of land under a standard land contract. The Ruling also briefly examines the GST consequences of a deposit that is forfeited under a standard land contract.
3. While this Ruling is concerned primarily with the sale of freehold land it is not limited to sales of freehold title. It applies where the parties are dealing with the maximum interest in land that the Crown has alienated and, therefore, includes the sale of land in the form of long term leases and pastoral leases. It also applies to sales of strata units.
4. The Ruling only applies to a sale of land that is made under a standard land contract as defined in paragraph 10 below. It applies equally to standard land contracts that are unconditional or conditional.
5. The Ruling does not address attribution of GST payable or input tax credits in respect of the sale of any separate interest attaching to the land or that may be severed from the land, for example, easements, profits a prendre or leases.
6. This Ruling does not cover a sale of land on terms or by instalment, whether under a standard land contract or otherwise. Generally, under a contract for a sale of land on terms or by instalment the purchaser is entitled to possession of the land or the receipt of rents and profits before becoming entitled to a transfer or conveyance of land. The specific terms of such contracts need to be examined to determine the GST consequences.
7. This Ruling does not address issues about whether there is a taxable supply or creditable acquisition arising from a sale of land under a standard land contract. This Ruling only looks at how to account for GST payable or input tax credits where there is a taxable supply or creditable acquisition arising from such a sale. However, it is noted that in certain circumstances a sale of land under a standard land contract is not a taxable supply or a creditable acquisition. These are briefly outlined at paragraphs 22 and 23.
8. The Commissioner does not propose to make a determination under section 29-25 in relation to supplies and acquisitions made under a standard land contract subject to conditions precedent to performance. This Ruling explains the reasons for this decision.
9. This Ruling applies on and from 8 July 1999 (the date of Royal Assent to the GST legislation).
Note: The Addendum to this Ruling that issued on 5 April 2006 applies on and from 1 July 2000.
10. This Ruling uses the term ' standard land contract' . This term refers to the standard contract for the sale of land as prepared by the various law societies or institutes and real estate institutes in Australia,[1] with the features mentioned in paragraph 13 below.
11. For the purposes of this Ruling, this term also covers contracts for the sale of land similar to those prepared by the law societies or institutes and real estate institutes where the contracts include the features mentioned in paragraph 13.
12. Where the terms of a contract for the sale of land vary one or more of the features in the following paragraph, it will not be treated as a standard land contract for purposes of this Ruling and this Ruling will not apply to that contract.
13. For purposes of this Ruling, a standard land contract is a written contract for the sale of land that provides for:
the payment of a deposit that is either to be forfeited if the purchaser defaults or applied as consideration on settlement; and
the payment of the balance of the purchase price upon settlement.
14. A ' deposit' under land law is an earnest given to bind the bargain; it is a guarantee that the purchaser means business; and on completion, it becomes part payment of the purchase price (see Howe v. Smith (1884) 27 Ch D 89 at 101; Brien v. Dwyer and Another (1978) 141 CLR 378 at 392).
15. 'Settlement' refers to that stage in the completion of a standard land contract where the transfer in the purchaser's favour and certificate of title are exchanged for the purchase price. It is at this stage that the purchaser (or the purchaser's agent) obtains:
unconditional possession of a registrable instrument of transfer; or
an instrument of transfer that would be registrable once stamped.
16. Attribution is the term used in the GST law to describe the way you account for GST payable, input tax credits and adjustments in order to work out your net amount of GST for a tax period. GST payable, input tax credits and adjustments are attributed to tax periods rather than being remitted or refunded, as the case may be, each time a taxable supply, creditable acquisition or adjustment is made.
17. The basic attribution rules that apply to attribute GST payable on taxable supplies and input tax credits for creditable acquisitions are explained in Goods and Services Tax Ruling GSTR 2000/29[2]. However, we summarise below the basic rules for working out when you pay GST on taxable supplies or claim input tax credits for creditable acquisitions.
18. If you do not account for GST on a cash basis, you attribute all the GST payable on a taxable supply to the earlier of the tax periods when:
any of the consideration for the supply is received; or
an invoice is issued for the supply.[3]
19. Provided you have a tax invoice at the required time,[4] you attribute all of an input tax credit for a creditable acquisition to the earlier of the tax periods in which:
you provide any of the consideration; or
an invoice is issued for the acquisition.[5]
20. If you account for GST on a cash basis, you attribute GST payable on a taxable supply to the tax period when the consideration for the supply is received, but only to the extent that the consideration is received in that tax period.[6]
21. Provided you have a tax invoice at the required time,[7] you attribute an input tax credit to the tax period in which you provide consideration for the acquisition, but only to the extent that you provided the consideration in that tax period.[8]
22. In certain circumstances a sale of land under a standard land contract will not be a taxable supply or a creditable acquisition because the supply is GST-free or input taxed. A sale of residential premises that is not new is input taxed under section 40-65. Supplies of the following kind may be GST-free:
a supply of land as part of a going concern - refer section 38-325;
a supply of subdivided farm land - refer section 38-475; and
a supply of farm land for farming - refer section 38-480.
23. Also, it is noted that an acquisition of a freehold interest in land, a stratum unit or a long term lease is not a creditable acquisition under section 75-20 if the supply of the interest, unit or lease was a taxable supply under the margin scheme (refer Goods and Services Tax Ruling GSTR 2000/21).[9]
24. An examination of the provisions referred to in paragraphs 22 and 23 is outside the scope of this Ruling.
25. When you make a taxable supply of land under a completed standard land contract, you attribute the GST payable to the tax period in which settlement occurs. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
26. If you hold a tax invoice, you attribute an input tax credit for a creditable acquisition of land under a completed standard land contract to the tax period in which settlement occurs. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
27. Division 99 applies to a deposit paid under a standard land contract. As a result, the payment of a deposit under a standard land contract will not trigger attribution of GST payable or input tax credits at the time the deposit is paid. This is the case if you account for GST on a cash basis or if you do not account for GST on a cash basis.
28. If, under section 27 of the Sale of Land Act 1962 (Victoria), the stakeholder[10] releases the deposit to the vendor prior to completion of the standard land contract (refer to paragraph 86 below for the conditions under which such a release may occur), Division 99 continues to apply to that deposit. Attribution of GST payable or input tax credits is not triggered by the release of the deposit in these circumstances.
29. A standard land contract is not an invoice for GST purposes. This means that entering into a standard land contract will not trigger attribution of GST payable or input tax credits where you do not account for GST on a cash basis.
30. Where you make a taxable supply upon a deposit being forfeited to you as a vendor under a standard land contract, you attribute the GST payable to the tax period during which the deposit is forfeited. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
31. Where you make a creditable acquisition upon a deposit being forfeited by you as a purchaser under a standard land contract and you hold a tax invoice, you attribute the input tax credit to the tax period during which the deposit is forfeited. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
32. The Commissioner does not propose to make a determination under section 29-25 in relation to the attribution of GST payable and input tax credits for supplies and acquisitions made under a standard land contract subject to conditions precedent to performance.
33. This Ruling deals with taxable supplies and creditable acquisitions of land in its entirety. It is concerned with the absolute interest in land under a standard land contract. While recognising, both at law and in equity, that property consists of bundles of rights, this Ruling is concerned with the supply of full and complete ownership of land, that is, the maximum interest which the Crown has alienated - whether it be freehold or leasehold.
34. Any supply and acquisition of any contractual or equitable interest upon entering into a standard land contract is ancillary to the eventual supply and acquisition of the legal property at settlement and is not a separate supply.
35. In a New Zealand case, Case L67 (1989) 11 NZTC 1391 Barber J rejected an argument based on the idea that a contract for the sale of land can be severed into the acquisition of an equitable interest first and legal interest later for GST purposes. He said:
'I consider it specious to endeavour to sever the sale of land, for GST purposes, into a chose in action and (later) legal title, even though the vendor is not capable of actually supplying title at the auction date.'
36. This Ruling is not concerned with the sale of any separate interest attaching to the land or that may be carved out or severed from the land, for example, easements, profits a prendre, or leases.
37. A sale of land under a standard land contract usually involves the following stages:
the parties enter into a standard land contract either by the exchange of contracts or by both parties signing one contract;
a deposit is paid to the stakeholder by the purchaser at the time of entering into the contract;
the deposit is held by a stakeholder until it is applied to the vendor's benefit at settlement;
the vendor will execute a transfer in favour of the purchaser;
at settlement the transfer in the purchaser's favour and certificate of title are exchanged for the purchase price; and
the purchaser (or purchaser's mortgagee) registers the transfer upon the certificate of title.
Attribution of GST payable or input tax credits arising from the sale of land under a standard land contract.
If you do not account for GST on a cash basis
Taxable supplies and creditable acquisitions
38. Under subsection 29-5(1) the GST payable by you on a sale of land under a standard land contract that is a taxable supply is attributable to:
the tax period in which any of the consideration is received for the supply; or
if, before any of the consideration is received, an invoice is issued relating to the supply - the tax period in which the invoice is issued.
39. Under subsection 29-10(1) the input tax credit to which you are entitled for a creditable acquisition under a standard land contract is attributable to:
the tax period in which you provide any of the consideration for the acquisition; or
if, before you provide any of the consideration, an invoice is issued relating to the acquisition - the tax period in which the invoice is issued.
40. However, under subsection 29-10(3) if you do not hold a tax invoice for a creditable acquisition when you lodge your Business Activity Statement ('BAS')[11] for the tax period to which the input tax credit (or any part of the input tax credit) on the acquisition would otherwise be attributable:
the input tax credit (including any part of the input tax credit) is not attributable to that tax period; and
the input tax credit (or part) is attributable to the first tax period for which you have a tax invoice when you lodge your BAS.
41. It follows that for attribution purposes it is necessary to determine first whether or not:
a standard land contract is an invoice for attribution purposes; or
the payment of a deposit under a standard land contract is consideration received for the supply of land or consideration provided for the acquisition of land.
Is a standard land contract an invoice for attribution purposes?
42. An invoice is defined under section 195-1 as 'a document notifying an obligation to make a payment'.
43. We consider that this definition is designed to capture the essence of a commercial invoice. There is support for this proposition in the New Zealand and Canadian GST jurisdictions.
44. The New Zealand definition of invoice for GST purposes is very similar to the definition in the Australian GST Act: 'a document notifying an obligation to make payment'.[12]
45. The leading case in New Zealand on what is an invoice for GST purposes, Shell NZ Holding Company Ltd v. CIR,[13] supports the proposition that the definition of invoice for GST purposes is designed to capture the essence of a commercial invoice.
46. In that case there were two documents competing as invoices for GST purposes: an import entry form and a deferred duty statement. The taxpayer was seeking to deduct credits on imported petroleum goods before GST payments were made to Customs. The taxpayer's argument was based on the import entry form being an invoice for GST purposes. The Commissioner of Inland Revenue argued that the input tax credit was not deductible until Customs had sent the taxpayer a deferred duty statement requiring payment. The Commissioner argued that the deferred duty statement was an invoice for GST purposes, not the earlier import entry form.
47. The New Zealand Court of Appeal held that the import entry form was an invoice for GST purposes. In reaching this decision the court commented as follows:
'Invoices are rendered in commercial transactions where goods are supplied or work is done by one party for another. Invoices record what was done and the charge. It may be a cash or credit transaction and in the latter case it is common for a monthly or other periodic statement to be issued subsequently. Whether payable on delivery or under the credit arrangement the invoice states the price or charge involved. And it is both unnecessary and uncommon in practice for commercial invoices to specify the time for payment.
In our view the GST obligation is in the same position. The statutory definition of "invoice" recognises that it is not a commercial two party transaction. It uses the central feature of an invoice which is "a document notifying an obligation to make payment". The time for payment is not part of the definition. "Notify" has its ordinary dictionary meaning of "to give notice to -, to inform". Certainly when completed by the Customs officer it is the Customs document and a copy is furnished to the importer. It is the signing of the document by the Customs officer which under the statute is the entry of the goods. It is that act which constitutes the duty as a debt due to the Crown. At that point the document is notice to the importer of the obligation to make payment.'[14]
48. Thus the New Zealand Court of Appeal considered that the GST obligation is in the same position as that of the obligation in commercial invoices, capturing the central feature of a commercial invoice which is a notice of an obligation to pay.
49. The Canadians have an inclusive definition of invoice for GST purposes: 'invoice includes a statement of account, a bill and any other similar record, regardless of its form or characteristics, and a cash register slip or receipt'.[15] Revenue Canada explains this definition as follows: 'An invoice is a document which either notifies a recipient of the obligation to pay or records payment'.[16] Obviously the second part ('records payment') has no relevance to our definition of invoice, but it is significant that their explanation of what an invoice does ('notifies a recipient of the obligation to pay') reflects the very words used in our definition.
50. The definition of invoice in the GST Act only refers to an 'obligation'. It does not refer to a contingent or conditional obligation, consistent with the essence of a commercial invoice. In the New Zealand High Court judgement in the Shell case Heron J, when considering the New Zealand definition of invoice, commented that:
'The Act does not speak in terms of future obligation or conditional obligation or contingent obligation. It speaks of obligation. It is an obligation to make payment.' [17]
51. The use of the words 'notifying' in the definition of 'invoice' and 'issued' in the attribution rules under the Australian GST Act more typically reflect the commercial invoice environment.
52. Consistent with commercial practice, the issue of an invoice is likely to be proximate to or after the supplier's completion of all that the supplier is required to do to become entitled to payment.
53. A standard land contract does not capture the essence of a commercial invoice as described above. A standard land contract does not notify an obligation to make a payment in the sense that a commercial invoice does. As Deane J pointed out in Foran v. Wight.[18]
'In the ordinary case of a contract for sale of land, the contractual obligations of the parties to complete the sale are concurrent and conditional in the sense that the vendor is not obliged to convey the land and the purchaser is not obliged to pay the purchase price otherwise than upon concurrent performance by the other party.'
54. Payment of the deposit to the vendor under a standard land contract is conditional upon completion of the contract or if not completed, the breach by the purchaser of an obligation under the contract. Until completion of the contract, the vendor 'has no vestige of right to get that deposit into his hands - he could not control its possession, that is, could not recover it'.[19]
55. We consider, therefore, that a standard land contract is not an invoice for GST attribution purposes as it does not notify an obligation to make a payment.
56. It follows that the entry into a standard land contract does not trigger attribution of GST payable under paragraph 29-5(1)(b) or attribution of input tax credits under paragraph 29-10(1)(b).
57. However, it is to be noted that the above analysis does not mean that a contract is never an invoice for GST attribution purposes. A contract may upon execution notify an obligation to make a payment consistent with a commercial invoice. As discussed a standard land contract is not a contract of that kind.
Is a deposit consideration received or provided for attribution purposes? Does Division 99 apply to a deposit held under a standard land contract?
58. Division 99 applies to deposits held as security for the performance of an obligation and has the effect of deferring attribution for these security deposits. [20] The Division also contains a special rule about attribution for these security deposits.
59. Specifically, under subsection 99-5(1) the deposit is not treated as consideration for a supply unless the deposit is forfeited because of a failure to perform the obligation or is applied as all or part of the consideration for a supply.
60. Under subsection 99-10(1) the GST payable on a taxable supply for which the consideration is a deposit that was held as security for the performance of an obligation, is attributable to the tax period during which the deposit is:
forfeited because of failure to perform the obligation; or
applied as all or part of the consideration for a supply.
This attribution rule overrides section 29-5 which is about attributing GST for taxable supplies.[21]
61. The heading to section 99-10 refers to 'Attributing the GST relating to deposits that are forfeited etc'. Subsection 99-10(1) refers to the GST payable on a 'taxable supply for which the consideration is a deposit ...'. In the Commissioner's view, in a standard land contract, subsection 99-10(1) operates to attribute the GST payable on the security deposit. The GST payable on the balance of the consideration is attributable under section 29-5.
62. There are no special attribution rules in Division 99 for input tax credits. The attribution rules in section 29-10 apply to attribute input tax credits for creditable acquisitions.
63. The standard land contracts provide for the payment of a deposit. This is usually 10 per cent of the purchase price (although other amounts may be agreed), payable by the purchaser at the time of entering into the contract. The deposit is retained until completion of the contract or earlier termination of the contract. Broadly, if a purchaser defaults, under the terms of the contract the vendor is entitled to terminate the contract and the purchaser automatically forfeits the deposit, irrespective of whether any damage has been suffered by the vendor.
64. A deposit paid under a standard land contract serves two purposes. If the contract goes through to completion, the deposit goes against the purchase price. But its initial purpose is as security for the performance of the contract. Fry LJ in Howe v. Smith[22] makes this plain:
'The deposit is not merely a part payment, it is also an earnest to bind the bargain so entered into and creates by fear of its forfeiture a motive in the payer to perform the rest of the contract...That earnest is lost by the party who fails to perform the contract.'
65. The dual purpose of a deposit under a standard land contract is also explained by WD Duncan and Stephen E Jones as follows:
'The deposit is expressly stated in the contract to be in part payment of the purchase price. While the payment bears the character of a part payment under an executory contract, it is also expressly stated to be a deposit and liable to forfeiture where the purchaser is in default. A part payment would not be so forfeited.'[23]
66. A deposit under a standard land contract displays the essential ingredients of a Division 99 deposit. That is, the deposit is liable to forfeiture on failure of the recipient of the supply to perform an obligation under the standard land contract for the supply of land. Division 99, therefore, applies to a deposit under a standard land contract.
67. As Division 99 applies, the deposit held under a standard land contract is not treated as consideration for a supply unless the deposit is either forfeited because of a failure to perform the obligation or applied as part of the consideration for the supply of land.
68. This means that at the time that the deposit is paid upon entering into a standard land contract, the deposit is neither consideration received for the supply of land nor consideration provided for the acquisition of the land. The payment of the deposit does not, therefore, trigger attribution of GST payable or input tax credits at the time it is paid.
69. A deposit under a standard land contract is applied as part of the consideration for the supply of land on settlement. As previously pointed out, on settlement the deposit becomes part payment and is applied for the vendor's benefit. Upon settlement, consideration is received for the supply of land and provided for the acquisition of land, triggering attribution of GST payable and input tax credits.
70. Under subsection 99-10(1), the GST payable on the deposit is attributable to the tax period in which settlement occurs.
71. Under paragraph 29-5(1)(a), the GST payable on the balance of the purchase price of the land is attributable to the tax period in which any of the consideration is received, that is, in the tax period in which settlement occurs.
72. This means that you, as a supplier making a taxable supply of land under a completed standard land contract, attribute the GST payable to the tax period in which settlement occurs.
73. Under paragraph 29-10(1)(a), the input tax credit for a creditable acquisition of land under a completed standard land contract is attributable to the tax period in which any of the consideration is provided, that is, in the tax period in which settlement occurs.
74. This means that if you hold a tax invoice, the input tax credit to which you are entitled for a creditable acquisition of land under a standard land contract is attributable to the tax period in which settlement occurs.
If you account for GST on a cash basis
75. Under subsection 29-5(2) if you account for GST on a cash basis, then:
if, in a tax period, all of the consideration is received for a taxable supply - GST on the supply is attributable to that tax period; or
if, in a tax period, part of the consideration is received - GST on the supply is attributable to that tax period, but only to the extent that the consideration is received in that tax period; or
if, in a tax period, none of the consideration is received - none of the GST on the supply is attributable to that tax period.
76. Under subsection 29-10(2) if you account for GST on a cash basis, then:
if, in a tax period, you provide all of the consideration for a creditable acquisition - the input tax credit for the acquisition is attributable to that period; or
if, in the tax period, you provide part of the consideration - the input tax credit for the acquisition is attributable to that tax period, but only to the extent that you provided the consideration in that tax period; or
if, in a tax period, none of the consideration is provided - none of the input tax credit for the acquisition is attributable to that tax period.
77. However, under subsection 29-10(3) if you do not hold a tax invoice for a creditable acquisition when you lodge your BAS[24] for the tax period to which the input tax credit (or any part of the input tax credit) on the acquisition would otherwise be attributable:
78. Again, it is necessary to determine first when any consideration is received or provided. The issue of an invoice is not relevant if you account for GST on a cash basis.
79. As previously discussed, we consider that the effect of Division 99 is that a deposit under a standard land contract is not treated as consideration for the supply of land unless the deposit is forfeited because of a failure to perform the obligation or is applied as part of the consideration for the supply of land (refer paragraphs 58 to 68 above).
80. Until either of these events occur, payment of a deposit under a standard land contract does not trigger attribution of GST payable under subsections 29-5(2) or 99-10(1), or input tax credits under subsection 29-10(2).
81. As previously pointed out, under a completed standard land contract attribution is triggered once the deposit is applied as consideration upon settlement (refer paragraph 69 above).
82. Under subsection 99-10(1), the GST payable on the deposit is attributable to the tax period in which it is applied as consideration, that is, to the tax period in which settlement occurs.
83. Under paragraph 29-5(2)(a), the GST payable on the balance of the purchase price of the land under a completed standard land contract is attributable to the tax period in which all of the consideration is received for the sale of the land, that is, when settlement occurs.
85. For completed contracts, attribution of the input tax credit for a creditable acquisition of land under a standard land contract is triggered under paragraph 29-10(2)(a) at settlement when all of the consideration is provided, that is, when the deposit is credited and the balance of the purchase price is paid. This means that if you hold a tax invoice, the input tax credit to which you are entitled for a creditable acquisition of land under a standard land contract will be attributable to the tax period in which settlement occurs.
Standard land contracts in Victoria - early release of deposit
86. In Victoria, section 27 of the Sale of Land Act 1962 (Vic) permits the earlier release of deposit moneys by the stakeholder for the vendor's benefit where the contract is not subject to any condition enuring for the benefit of the purchaser, and where the purchaser has accepted title or may be deemed to have accepted title.
87. Although the deposit is released by the stakeholder to the vendor, the deposit retains its character as a deposit until it is forfeited or applied as consideration. Division 99 still applies to such a deposit. The early release of that deposit does not trigger GST payable on the supply or input tax credits for the acquisition before settlement unless the deposit is forfeited. This is the case, irrespective of the basis you use to account for GST.
Summary: how the attribution rules apply to sales of land under standard land contracts
88. Payment at settlement triggers attribution for sales under standard land contracts. This means that you attribute GST payable when you make a taxable supply under a standard land contract to the tax period in which settlement occurs. Provided you have a tax invoice, you attribute an input tax credit for a creditable acquisition under a standard land contract to the tax period in which settlement occurs. This applies if you account on a cash basis or if you do not account on a cash basis.
Example of how the attribution rules apply to sales under standard land contracts
89. Peter owns a number of commercial properties. He is registered for GST, does not account for GST on a cash basis and has one month tax periods. He puts one of his properties on the market through his real estate agent, Maria.
90. Maria finds a purchaser, Marilyn. Marilyn owns a newsagency and is looking for a new outlet. Marilyn is registered for GST, accounts for GST on a cash basis and has three month tax periods.
91. On 14 July 2000 Peter and Marilyn enter into a contract for the sale of the freehold interest in Peter's property. The terms of the contract include the following:
the purchase price of the property is $330,000 (GST inclusive);
a deposit of $33,000 is to be paid by Marilyn on entering into the contract;
the deposit is to be held by Maria as stakeholder for Peter and Marilyn;
settlement will occur on 30 November 2000; and
the balance of the purchase price of $297,000 (after adjustments allowed under the contract) will be paid at settlement in exchange for a transfer in Marilyn's name and the certificate of title.
92. Marilyn pays the deposit to Maria on 14 July 2000. Settlement occurs on 30 November 2000: Peter exchanges a transfer in Marilyn's name and certificate of title for Marilyn's payment of the balance of the purchase price (after adjustments allowed under the contract). Peter also gives Marilyn a document that satisfies the requirements for a tax invoice. Maria pays the deposit (after deducting her fees) to Peter. Later Marilyn registers the transfer upon the certificate of title.
93. Peter attributes the $30,000 GST payable (1/11 x $330,000[25]) to the tax period in which settlement occurs. As Peter has one month tax periods, the $30,000 GST payable is attributed to the tax period ending 30 November 2000.
94. Marilyn attributes the $30,000 input tax credit to the tax period in which settlement occurs. As Marilyn has three month tax periods, the $30,000 input tax credit is attributed to the tax period ending 31 December 2000.
Forfeiture of a deposit under a standard land contract
Taxable supplies
95. If a vendor defaults under a standard land contract and the deposit is refunded to the purchaser, there are no GST consequences. There is no taxable supply as neither the purchaser nor the vendor has made a supply for consideration, as required by paragraph 9-5(a). Nor is there a creditable acquisition under section 11-5.
96. There may be GST consequences where the purchaser defaults under a standard land contract and the stakeholder pays the deposit to the vendor. In this case, the vendor has made a supply for consideration and, if the other elements of a taxable supply as defined in section 9-5 are satisfied, there will be a taxable supply by the vendor.
97A. If the vendor exercises a right to forfeit the deposit as a result of a breach of contract by the purchaser, the Commissioner considers that the forfeited deposit has no nexus with the originally arranged or intended underlying supply but is consideration for a different supply.[27] This is because, for the purposes of the GST Act, the deposit is not treated as consideration for a supply until the circumstances in subsection 99-5(1) apply. It has been argued[28] that a forfeited deposit may not be consideration for, or have a nexus with, any supply. The Commissioner's view is that if a deposit is forfeited, it is consideration for a supply.
97B. The term 'supply' is defined broadly in subsection 9-10(1) to mean 'any form of supply whatsoever'.[29] Subsection 9-10(2) without limiting subsection 9-10(1) lists inclusive examples of a supply.
97C. In order to forfeit and retain the security deposit, the supplier must elect to rescind the contract,[30] thereby surrendering some of their rights and/or releasing the other party from some of their obligations, acquired under, or associated with the arrangement.[31] Without limiting subsection 9-10(1), under paragraphs 9-10(2)(b), 9-10(2)(e) and 9-10(2)(g) respectively, a supply includes the supply of services, the surrender of any right and the release from an obligation. When considering subsection 9-10(2), the Commissioner's view is that the forfeited deposit is consideration for the act of rescission, and/or the surrender of rights and/or release from obligations which occur as a result of the rescission, and/or a combination of these supplies under paragraph 9-10(2)(h).
97D. The arrangement between the parties is that the supplier agrees to make an underlying supply, but in the event that this does not proceed in accordance with that arrangement, the parties agree that an amount will be paid (in the form of the forfeited deposit) for a different or substituted supply. By commencing performance of the arrangement, the supplier allocates resources, typically by performing certain services or undertaking tasks. If the original arrangement is completed, this supply forms part of the underlying supply. However, in the event that the underlying supply does not proceed, the forfeited deposit is consideration for the other supply.
97E. Furthermore, the intention of Division 99 is in part; to ensure that forfeited deposits are treated as subject to GST when the forfeiture occurs.[32] This interpretation is supported by the words of paragraph 99-5(1)(a) which states that a deposit is not to be treated as consideration for a supply unless it is forfeited. This means that a deposit must be treated as consideration for a supply upon forfeiture.
97F. The supply, for which the forfeited deposit is consideration, constitutes a taxable supply under section 9-5 if it meets the requirements in paragraphs (b) to (d) of that section.
98. Where you make a taxable supply for which the consideration is a deposit that was held as security for the performance of an obligation under a standard land contract, you attribute the GST payable on that supply under paragraph 99-10(1)(a) to the tax period during which the deposit is forfeited because of a failure to perform the obligation. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
Creditable acquisitions
99. A supply under paragraphs 97A to 97F is a taxable supply that is made by the vendor since the forfeiture of the deposit is consideration for that supply (assuming that the other conditions under section 9-5 have been met). Provided that the other requirements of section 11-5 are also met, this supply is a creditable acquisition by the purchaser.
100. Where you make a creditable acquisition upon a deposit being forfeited by you as a purchaser under a standard land contract and you hold a tax invoice, you attribute the input tax credit to the tax period during which the deposit is forfeited. In terms of section 29-10, this will be the tax period in which you provide consideration for the acquisition. This applies if you account for GST on a cash basis or if you do not account for GST on a cash basis.
No determination for particular attribution rules necessary for conditional standard land contracts
101. Under section 29-25 the Commissioner has power to make a determination varying the attribution rules for GST payable on taxable supplies or input tax credits for creditable acquisitions of a specified kind if satisfied that it is necessary to prevent the basic attribution rules under Division 29 and any special rules in Chapter 4 applying in a way that is inappropriate in circumstances described in paragraphs (a) to (g) of subsection 29-25(2).
102. Paragraph 29-25(2)(f) refers to circumstances involving 'a supply or acquisition made under a contract that is subject to preconditions'.
103. 'A contract that is subject to preconditions' would include a standard land contract subject to conditions precedent to performance: non-fulfilment of a condition precedent to performance means that the contract can be avoided by the parties. An example of a condition precedent to performance is a subject to finance term where the performance of the contract is subject to the purchaser obtaining approval of a loan to finance the purchase.
104. 'A contract that is subject to preconditions' would not apply to conditions precedent to formation of a contract[26] as there would not be 'a supply or acquisition under a contract' where the formation of the contract itself is subject to a condition.
105. As pointed out in this Ruling, under completed standard land contracts (including those contracts subject to conditions precedent to performance) there is no attribution prior to the tax period in which settlement takes place. This result is consistent both with when property passes and when income is derived for income tax purposes. The Commissioner, therefore, is satisfied that it is not necessary to make a determination under section 29-25 for supplies or acquisitions of land under a standard land contract.
106. Below is a detailed contents list for this Ruling:
Definitions 10
Context of attribution 16
Ruling 25
Explanation 33
Attribution of GST payable or input tax credits arising from the sale of land under a standard land contract 38
If you do not account for GST on a cash basis 38
Taxable supplies and creditable acquisitions 38
Is a standard land contract an invoice for attribution purposes? 42
Is a deposit consideration received or provided for attribution purposes? Does Division 99 apply to a deposit held under a standard land contract? 58
If you account for GST on a cash basis 75
Standard land contracts in Victoria - early release of deposit 86
Summary: how the attribution rules apply to sales of land under standard land contracts 88
Example of how the attribution rules apply to sales under standard land contracts 89
Forfeiture of a deposit under a standard land contract 95
Taxable supplies 95
Creditable acquisitions 99
No determination for particular attribution rules necessary for conditional standard land contracts 101
1 For example, see:
New South Wales Contract for the sale of land 1992 edition (copyright of the Law Society of New South Wales and the Real Estate Institute of New South Wales);
Victoria Contract of Sale of Real Estate (copyright of Law Institute of Victoria and the Real Estate Institute of Victoria)
Queensland Contract For Lots in a Community Titles Scheme and Contract For Houses and Land (copyright of Real Institute of Queensland);
South Australia REISA Contract (copyright of Real Estate Institute of South Australia);
Western Australia Joint Form of General Conditions for the Sale of Land 1998 revision (copyright of The Law Society of Western Australia and The Real Estate Institute of Western Australia); and
Tasmania Contract for Sale of Real Estate (not for use for sale on terms)
(copyright of the Law Society of Tasmania).
2 Goods and Services Tax Ruling GSTR 2000/29 Goods and Services Tax: attributing GST payable, input tax credits and adjustments.
3 Subsection 29-5(1).
4 You must hold a tax invoice when you lodge your Business Activity Statement ('BAS') for the tax period to which the input tax credit is attributable. Otherwise, you attribute the input tax credit to the first tax period for which you have a tax invoice when you lodge your BAS. There is no requirement to hold a tax invoice if the value of the taxable supply to you was $50 or less: subsections 29-10(3) and 29-80(1). See GSTR 2000/17 as to what is a tax invoice for GST purposes.
5 Subsections 29-10(1) and (3).
6 Subsection 29-5(2). This means that if, in a particular tax period, you receive only part of the consideration for a supply, you attribute only that same part of the total GST payable to that tax period.
7 Refer to footnote 4.
8 Subsections 29-10(2) and (3). This means that if, in a particular tax period, you have paid only part of the total consideration for an acquisition, you are entitled to only that same part of the input tax credit for the acquisition.
9 Goods and Services Tax Ruling GSTR 2000/21 Goods and Services Tax: the margin scheme for supplies of real property held prior to 1 July 2000.
10 A stakeholder is a person who holds a deposit not as agent for the vendor but for both the vendor and purchaser until it is decided who is entitled to the deposit.
11 Your GST return is part of your BAS.
12 Section 2 of the Goods and Services Tax Act 1985 (NZ).
13 (1994) 16 NZTC 11,163.
14 Shell NZ Holding Company Ltd v. CIR (1994) 16 NZTC 11,163 at 11,168.
15 Subsection 123(1) of the Excise Tax Act (Can).
16 Paragraph 6 of Canadian GST Memorandum 300-6-3 in the Time of Liability sub-series.
17 Shell NZ Holding Company Ltd v. CIR (1993) 15 NZTC 10,136 at 10,139. When this case went on appeal to the Court of Appeal the court did not overrule Heron J on this point. The Court of Appeal decided on the facts that the obligation to pay arose upon the issue of an earlier document than that identified by Heron J.
18 (1989) 168 CLR 385 at 433. See also McDonald v. Dennys Lascelles Ltd (1933) 48 CLR 457 at 475-476; Sunbird Plaza Pty Ltd v. Maloney (1988) 166 CLR 245 at 253-254; and Gasparin v. FCT 94 ATC 4280; (1994) 28 ATR 130.
19 Christie v. Robinson (1907) 4 CLR 1338 per Issacs J at 1355.
20 Refer GSTD 2000/1 Goods and Services Tax determination. Goods and Services Tax : is the scope of Division 99 of the A New Tax System (Goods and Services Tax) Act 1999 limited to holding deposits?
21 Subsection 99-10(2).
22 (1884) 27 Ch D 89 at 101-102.
23 Sale of Land in Queensland (4th ed.), at 88-89.
25 Please note that in calculating the GST payable it is assumed that the margin scheme under Division 75 does not apply. See Goods and Services Tax Ruling GSTR 2000/21 for details on the operation of the margin scheme.
26 Conditions precedent to the formation of a contract are rare. An example would be a 'subject to contract' condition in correspondence leading to the informal finalisation of an agreement. In this situation no legal obligations are created until entry into a formal contract: see Masters v Cameron (1954) 91 CLR 353 at 360 361 (this situation would fall into the second of the three classes outlined by the High Court).
27 Note that in the event that the contract is completed and the deposit is applied as consideration, paragraph 99-5(1)(b) operates to connect the deposit with the supply it is applied against.
28 Rowe, S 'Liquidated damages, terminated leases and forfeited deposits - Part II', Australian GST Journal, 2004, vol. 4, issue 9, at p 248-249.
29 Shaw v. Director of Housing & Anor (No. 2) 2001 ATC 4054; (2001) 46 ATR 242 at paragraph 13 and Saga Holidays Ltd v. FC of T [2005] FCA 1892 at paragraph 48.
30 Hoobin, Re; Perpetual Executors and Trustees Association of Australia Ltd v. Hoobin [1957] ALR 932; [1957] VR 341 at 347. The law recognises that the supplier can either elect to terminate the performance of the contract and claim damages or elect to go on with the contract notwithstanding the breach. See Carter, JW 1991, Breach of Contract, 2nd edn, The Law Book Company Limited, Sydney, p. 242.
31 These general principles are referred to in Mayson v. Clouet and Another [1924] AC 980 at 985, Lowe v. Hope [1969] 3 All ER 605 per Pennycuick J at 607-8; 3 WLR 582; McDonald and Another v. Dennys Lascelles Limited (1933) 48 CLR 457 at 470 per Starke J. The rights which are surrendered upon termination include the right to sue for the purchase price and right to receive instalments of the purchase price which are not forfeited. See Rossiter, CJ 2003, Principles of Land Contracts and Options in Australia, Chapter contributed by Harley, DJ, Lexis Nexis Butterworths, Australia at p. 302. However, some terms of the contract (such as a liquidated damages clause) may survive rescission, as rights that are not divested or discharged which have already been unconditionally acquired may survive rescission. See Dixon J in McDonald and Another v. Dennys Lascelles Limited (1933) 48 CLR 457 at 476-7. See also Contract Law in Australia, Carter and Harland 4th edition, at 1993; Cheshire, Fifoot's Law of Contract, Seddon and Ellinghaus, 8th Australian edition at 21.34; and Carter, JW 1991, Breach of Contract 2nd edn, The Law Book Company Limited, Sydney, p.455.
32 The EM in paragraph 6.166 indicates that forfeited deposits should be subject to GST. Also, at paragraph 6.169 the EM notes that the GST payable on the forfeited deposit is attributable to the period in which the deposit is forfeited.
Previously issued in draft form as GSTR 2000/D10
NO 99/18258-0
GSTD 2000/1
business activity statement
conditional contracts
creditable acquisition
GST payable
input tax credits
not on a cash basis
standard land contract
taxable supply
unconditional contracts
ANTS(GST)A99 9-5
ANTS(GST)A99 9-5(a)
ANTS(GST)A99 9-10(2)(e)
ANTS(GST)A99 11-5
ANTS(GST)A99 11-10(2)(e)
ANTS(GST)A99 Div 29
ANTS(GST)A99 29-5(1)
ANTS(GST)A99 29-10(1)(a)
ANTS(GST)A99 29-10(1)(b)
ANTS(GST)A99 29-10(2)
ANTS(GST)A99 29-25
ANTS(GST)A99 29-25(2)(f)
ANTS(GST)A99 38-325
ANTS(GST)A99 195-1
Excise Tax Act (Can) 123(1)
Goods and Services Tax Act 1985 (NZ) 2
Sales of Land Act 1962 (Vic) 27
Brien v. Dwyer and Another
(1978) 141 CLR 378
Case L67
(1989) 11 NZTC 1391
Christie v. Robinson
(1907) 4 CLR 1338
Foran v. Wight
Gasparin v. FC of T
Howe v. Smith
(1884) 27 Ch D 89
McDonald v. Dennys Lascelles Ltd
Master v. Cameron
Shell NZ Holding Company Ltd v. CIR
(1994) 16 NZTC 11,163
Sunbird Plaza Pty Ltd v. Maloney
GSTR 2000/28 history
Date: Version: Change:
30 June 2000 Original ruling
You are here 5 April 2006 Consolidated ruling Addendum
22 August 2007 Consolidated ruling Addendum
24 June 2009 Consolidated ruling Addendum
25 January 2012 Consolidated ruling Addendum
31 October 2012 Consolidated ruling Addendum


A boxing referee doesn't get paid extra for a longer fight.
Still, there's that lawyer thing. And the jokes come with a warning: What's the difference between a lawyer and a boxing referee?
The boxing referee doesn't get paid more for a longer fight.


text:
Бірлі́цький сільський округ (, ) — адміністративна одиниця у складі Жарминського району Абайської області Казахстану. Адміністративний центр та єдиний населений пункт — аул Бірлік.

Населення — 823 особи (2009; 1309 в 1999, 1666 у 1989).

Станом на 1989 рік існувала Разінська сільська рада (села Александра Невського, Амангельди, Батурінка, Вознесеновка). Село Амангельди, аул Каракожа були ліквідовані 2013 року.

Склад
До складу округу входять такі населені пункти:

Примітки

Сільські округи Жарминського району

redpajama_set_name: RedPajamaWikipedia


"Somewhere your there a social media consultant must be blogging about how important it is to have a Facebook page for your law firm, because 'Follow my firm's Facebook page!' updates seem to pop up in my feed every day or two.
That consultant is a moron."
Perhaps Sam was talking about me, because I think that having a Facebook page is an excellent idea for practically any small business who focuses on a local market.
I also think law firms should have Facebook pages, despite the concern that many attorneys have over the risk of stepping outside ethical guidelines when engaging communities through social media.
Sam goes on to describe his own experience with creating a Facebook page. He had a couple dozen likes from friends and a few strangers, and he really didn't do much with it. He said that he tried to keep it active for a while, but nobody cared, so he deleted it. Poor Sam. He doesn't get Facebook.
Most law firms do not get Facebook, and it's a rather curious puzzle to me why these super-smart and savvy expert people-readers would completely miss the mark on social marketing. I suspect it is because they are listening to the wrong advice.
LexisNexis Martindale-Hubbell offers social media advice to law firms using examples that are reminiscent of what most other businesses were doing five years ago, using the platform as a soapbox instead of an opportunity for creating one-to-one conversations. But their advice is still more progressive than what most firms are doing.
By surveying more than 1,300 law firm Facebook pages, I determined that more than 80% were unsuccessful in their social media effort. Most of the unsuccessful pages have an automated feed from their blog to their Facebook page, which doesn't even register on the "fun and social" scale.
Really, who, besides other lawyers, subscribes to law site blogs? The only reason most law sites have blogs is to improve their search rankings. This is not exactly cocktail conversation.
Sam, I want you to repeat after me. "It's all about connecting with my community".
Did you get that? If you want to be successful on Facebook, you have to stop thinking about your own page and start thinking about how you can connect with people, promote events, promote your community, and create opportunities for engaging conversations. You have to be social.
It really works. Kershaw, Cutter & Ratinoff has over 2,000 fans on their Facebook page. They promote a variety of local causes like Junior Achievement and local food banks. They rally their fans to drum up more support, and gain more fans in the process. This is just one example of dozens I came across in my research.
Facebook provides a great opportunity for law firms to connect with their community and create valuable top-of-mind awareness. Done right, it's highly effective. But it takes effort to make social media work for you.


text:
Bearded Wonders
Let's face it, facial fuzz is growing on men for a variety of reasons.
I've been thinking a lot about beards lately because I've been seeing so many of them, and I don't mean those itty-bitty goatee thingies. Those have been popular for years, especially among guys (like me) who are perhaps attempting to compensate for some "thinning" on top.
I'm talking serious fur: full-blown, lower-face-concealing beards, the kind that used to be associated principally with sea captains, lumberjacks and college professors—as well as, it must be said, Karl Marx and Charles Manson.
Image-conscious actors and other celebs have traditionally shunned beards like those—except on their days off or when they've played certain kinds of roles, like bad guys in Westerns. Professional men once avoided them even more fervently.
Cheney Mason, the prominent local attorney whose clients include Casey Anthony, has worn a full, neatly trimmed beard continuously since 1975, when beards were rare among his peers.
"I don't remember very many of my colleagues, younger or older, at the time that had beards," says the 67-year-old lawyer, whose folksy manner brings to mind a shaggier Matlock. "I do remember one [judge] who had an ultra-right-wing conservative personality, who would make derogatory comments about [my beard] from time to time."
Over time, beards gained wider acceptance.
"Some years later, that very same judge grew a beard," Mason says with a chuckle. "Beards are commonplace now in every walk of life."
Except in politics, that is. There the clean-cut image has reigned since image consultants began warning politicians that facial hair would cost them votes. Even a modern-day Honest Abe would find voters skeptical of a politician with a beard.
Our celebrity culture has a role in the rise of the beard. My candidate for leader of the new hirsute pack is Zach Galifianakis, whose films include The Hangover, Dinner for Schmucks and Due Date, and who stars on HBO's Bored to Death.
I think of Galifianakis as the king of the bearded celebs not just because his projects (especially The Hangover) have been so prominent, but also because his beard is prominent. At first glance, it can make him seem rather menacing, so that when his essential goofiness emerges (as it always must), you may be surprised. And since the actor tends to specialize in playing misfits who are clueless about how foolish they are, his beard can seem like an emblem of his invincible idiocy.
Conan O'Brien's beard is another matter. Breaking what I had assumed to be an unbreakable tenet for talk-show hosts, O'Brien has worn a beard since the start of Conan, his current late-night show on TBS.
Like Mason, O'Brien sports a beard that's neatly trimmed and not as thick as Galifianakis', but it's certainly a full beard. A beard like that can work against a comedian because it hinders his range of expression. But so far, that doesn't seem to have been a problem for O'Brien who, with his lanky frame, huge eyes and ginger cowlick, is like a cartoon character come to life.
In O'Brien's case, the beard is a sort of statement, a way of distinguishing his new show from the work he did for NBC, whose treatment of him he is clearly quite bitter about.
The hair on his face, you might say, is a big "in your face" to his former employer.
Then there's the intriguing case of Brian Wilson, a star pitcher for the San Francisco Giants who has taken to wearing a full, dark and perhaps dyed beard. Not only is Wilson's beard visually distinctive, it's pretty much the opposite of the clean-cut image that professional sports—especially baseball—has promoted since the days of Ruth and Mantle. (The Cincinnati Reds, in fact, had a longstanding policy banning players from sporting facial hair.)
There may be no crying in baseball, but now that there are beards, who can say what comes next? In any case, Galifianakis, O'Brien and Wilson are leading the charge for beards—at least until one of them decides to shave his off.
For a man, a beard can be as much of a personal statement as a pair of shoes, a hairstyle or a lipstick shade is for a woman. (It may even be more of a statement, since it can't be changed as much or as often.) And yet, when full beards start popping up on so many men, there may also be broader cultural forces at work.
Could it be that the miserable economy—with its attendant joblessness and even homelessness—has made the nation as a whole somewhat shaggier by inspiring at least some of these beards?
As every guy knows, when you don't have a job, you're less likely to shave every day. O'Brien has even said that he started growing his beard when he was out of work and didn't have to shave.
Possibly some of America's newly shaggy regular Joes are finding it easier to identify with someone like O'Brien, Galifianakis or Wilson than with clean-cut types like, say, Tom Cruise or Peyton Manning.
It's something to think about, anyway—next time you feel like stroking your beard.
Cheney Mason Brian Wilson Zach Galifianakis
This article appears in the March 2011 issue of Orlando Magazine.
Categories: Health & Beauty

redpajama_set_name: RedPajamaCommonCrawl


Approaching their centenary, the Motor Trade Association (MTA) were looking to refresh their web presence, bringing their digital platforms into the 21st century. With large parts of their existing technology unsupported, they wanted to create digital channels and user-journeys that both their members and the general public would find valuable and engaging when accessing MTA.org.nz.
Working in conjunction with our partner VML, Solnet redeveloped MTA.org.nz into a modern and mobile responsive website. Built around a central search function, the new website makes it easy for people to find MTA members near them, an e-commerce solution to buy and manage gift cards, and access to MTA's Toolbox (an online member services and training system).
We wanted to upgrade our digital presence and develop a more modern look and feel, and at the same time help people find our members throughout New Zealand.
Solnet and VML managed the redesign of the user experience and interface for MTA. Previously people would have to make multiple clicks to find the information they needed. Replacing this with a large and prominent search box on the home page makes it easier for people to simply tell the website what they are looking for.
Once displayed, search results can be filtered by business type, zip code or from location-based services. A large, interactive map is also displayed to the left of the text results for easy browsing by users.
Using API's, Solnet's developers were able to make contact information from the organisation's CRM database available to people looking to find an MTA member. This means that the information can be maintained in one centralised database, and there is no need to duplicate data between the two systems.
The result is an easy to access database for the public, providing them with quick and easy access to contact information for businesses, along with access to their websites to make purchases.
We knew there were two main use cases for the public – finding a reputable business carrying the MTA member brand and to manage their gift cards. We wanted to make it easy for them and not over-complicate things.
One significant use case identified before the development of the new website was the need for the public to be able to both purchase, and check the status of, MTA gift cards.
To achieve this, Solnet deployed an e-commerce system which allowed people to not only purchase standardised or custom amounts of MTA credit, but also to check the balance and status of existing cards or vouchers.
MTA's new website is built on the SilverStripe CMS platform. SilverStripe is an open source CMS which is used by organisations of all sizes, from small businesses through to government agencies and large corporates globally.
The result for MTA is a website which is built with a number of reusable modules and a simple content management interface. This allows content managers to quickly and easily add additional content to existing pages and modules, or create new ones, without the need to engage outside contractors or technical support staff.


Logan Hardware Records is Logan Square's classic record store and vintage arcade museum. With our backgrounds in music and a love for classic pinball and video games, it felt natural to combine the two. We had the perfect space for it. Opened in January 2010, our original location at 2410 W. Fullerton was the site of the original Logan Hardware that served our corner of Logan Square for over 50 years. With Chicago's deep history in both the music industry and coin-operated gaming we started realizing how LPs, 45s and even our Pinbot pinball machine were the hardware of our generation. Our space in the old hardware store with the cool old sign was a perfect fit for over three years but we were running out of space for our expanding stock in the store and also noticed a need for a full-scale vintage arcade in Logan Square.
In July 2013, we moved Logan Hardware Records two blocks west of the original location to 2532 W. Fullerton, nearly doubling our stock in the store and expanding our vintage Arcade Museum. Now, you can dig through thousands of 45s on one side of the store without bumping into somebody flipping through endless rows of LPs on the other. Check out our increased selection of ever-changing vintage and new stock stereos, turntables, electronics, toys, movies, cards and other collectables. Looking for a working Fun Chicken? We have one. Looking for that Polish language LP from 1971 about the goat and the ostrich? We've got it. Any in-store purchase gains you access to our Arcade Museum with over 30 video games and 4 pinball machines all set to free play.


An area of specific requirements from clients is often the creation of a report and accounts. In this instance RACE proposed that the directors of the property company were photographed in a raw environment ready for regeneration, rather than on the sites of completed property projects.
The production of a report and accounts is very intensive; as a legal and statutory document complex information has to be included with very detailed financial pages. To compound this, information is often received form auditors at a very late stage and so exacting attention to detail is demanded before production takes place.


Availability with a wholesaler like Ingram (which you have with the Diamond, Pearl, Ruby, and Sapphire packages).
A 50-55% trade discount, which means more money for the retail store. The highest trade discount you can set through Outskirts Press is 55%, industry standard.
A retail returns policy. Outskirts Press is one of the few on-demand publishers offering an optional retail returns program.
Customer demand. Bookstores also require consumer demand for your book. Creating demand, or "buzz," is up to your promotional efforts. Outskirts Press provides a host of optional marketing services and products to help you in this regard, including the Personal Marketing Assistant for authors who require help that is much more personal and specific. Our Personal Marketing Assistant will work with you (and for you) to promote your book in accordance with your marketing plan and goals (which can include pitching your book to bookstores).


My present age is 40 and another 20 years job at hand.
I have 12 lc in my PF account now and want to make it 1 Cr while my retirement.
Can you suggest now onwards, what is the amount should I deduct from my salary.
My present salary is 55K in hand, apart from some other Incentive ,LTA etc.
I agree with Ashal. Voluntary PF is the way to go for if you need higher PF balances. You can go upto 100% of Basic + DA into PF.
Along with PF, you then get entitled to a Pension (which is not great), but still is a monthly cash flow.
Dear TheZionView, Apart from regular 12% of Basic + DA, one may invest more in PF out of his/her own choice. This is called VPF (Voluntarily Provident Fund) Contribution.
A lot of person (mainly those who are about to retire in next 3-5 years) in my organization are using the VPF route to increase their retirement kitty.
Dear Koushil Roy, what's the current PF deduction from your salary & how much is the addition done by your employer?
With Jago Investor calculator i arrived at 16000 per month as EPF with assumption of 8.5% interest rate.This was without considering inflation.
I believe we can only ave 100% of basic as EPF not more than that and we cant include allowance into PF.


Monaliza short full wig –"Wendy", measures approximately 8", made from premium quality synthetic fiber.
Color shown is #613A, also available in 8 colors, you can select a color in the drop-down menu above. Please keep in mind that colors display slightly differently on each computer monitor. If you have any question, please don't hesitate to ask, I'll reply as soon as possible.


When I first saw Lily's curly hair and grey eyes, I was in love. Isn't she such a adorable little thing?
We started in my studio and then headed out back behind it by our horses and snagged a few spectacular images there. Oh I'm in love.
Here's a few of this adorable little princess.


text:
Flux monitoring at 327 MHz during SL9-Jupiter collision
Rakesh K. Malik Pradeep Gothoskar P. K. Manohran G. Swarup K. Subramanian V. Balasubramanian
Volume 16 Issue 3-4 December 1995 pp 393-398
https://www.ias.ac.in/article/fulltext/joaa/016/03-04/0393-0398
SL9-Jupiter collision; radio flux monitoring; Jupiter radio emission
Jupiter flux at 327 MHz was monitored using the Ooty radio telescope from July 12th to July 29th during the collision of comet Shoemaker-Levi 9 with Jupiter. Flux was found to increase steadily from July 17th to July 26th by ∼ 2–5 Jy, after which it declined to its pre-event value. The comparison of 327 MHz observations with those at 840 MHz and 2240 MHz indicates that the enhancement was mainly due to the increased synchrotron emission and the contribution of thermal emission was very small at metric-decimetric frequencies. The enhancement in radio emission was found to be more at 840 MHz than at 327 or 2240 MHz. The steepening of the spectrum between 327 and 840 MHz as well as between 2240 and 840 MHz was also noted.
Rakesh K. Malik1 Pradeep Gothoskar1 P. K. Manohran2 G. Swarup1 K. Subramanian1 V. Balasubramanian2
National Centre for Radio Astrophysics, TIFR, Post Box 3, Pune - 411 007
Radio Astronomy Centre, TIFR, Ooty - 643001


text:
package dynaml

import (
	"encoding/base64"
	"strconv"
	"strings"
)

func func_base64(arguments []interface{}, binding Binding) (interface{}, EvaluationInfo, bool) {
	var err error

	info := DefaultInfo()

	if len(arguments) < 1 || len(arguments) > 2 {
		return info.Error("base64 takes one or two argumenta")
	}

	str, ok := arguments[0].(string)
	if !ok {
		return info.Error("first argument for base64 must be a string")
	}

	max := -1
	if len(arguments) > 1 {
		l, ok := arguments[1].(int64)
		if !ok {
			s, ok := arguments[1].(string)
			if !ok {
				return info.Error("second argument for base64 must be an integer or interger string")
			}
			l, err = strconv.ParseInt(s, 10, 64)
			if err != nil {
				return info.Error("second argument for base64 must be an integer or interger string: %s", err)
			}
		}
		max = int(l)
	}
	result := Base64Encode([]byte(str), max)
	return result, info, true
}

func func_base64_decode(arguments []interface{}, binding Binding) (interface{}, EvaluationInfo, bool) {
	info := DefaultInfo()

	if len(arguments) != 1 {
		return info.Error("base64_decode takes exactly one argument")
	}

	str, ok := arguments[0].(string)
	if !ok {
		return info.Error("first argument for base64_decode must be a string")
	}

	result, err := base64.StdEncoding.DecodeString(str)
	if err != nil {
		return info.Error("cannot decode string")
	}
	return string(result), info, true
}

func Base64Encode(data []byte, max int) string {
	str := base64.StdEncoding.EncodeToString(data)
	if max > 0 {
		result := ""
		for len(str) > max {
			result = result + str[:max] + "\n"
			str = str[max:]
		}
		if len(str) > 0 {
			result = result + str
		}
		if strings.HasSuffix(result, "\n") {
			result = result[:len(result)-1]
		}
		return result
	} else {
		return str
	}
}

redpajama_set_name: RedPajamaGithub


Tough week in the NFL to find games to pick. A lot of big lines and it's hard to trust a lot of the teams that have nothing to play for. The one game I like is an early one on Sunday afternoon.
The Eagles were written off after allowing five touchdowns each in games against Jameis Winston and Matthew Stafford. Philadelphia showed life last week with a shocking defeat of the Patriots. The win puts the Eagles back in the NFC East race. However, they needed three return touchdowns to beat an injury-riddled Patriots squad. The Eagles could even lose this upcoming game and still be right in the division race.
The Bills travel to the Eagles in a game Buffalo needs to win to stay in the AFC playoff hunt. I think this game means more to the Bills and I won't get fooled by the Eagles win over the Patriots last week.
There are a lot games to stay away from this week but I found three underdogs that I predict will cover and possibly win straight up.
Texans (+6) over Falcons: The line for this game was Falcons -3.5 before Week 3 action. The Falcons improved to 3-0 with a win over Brandon Weeden and the Cowboys. The Texans picked up their first win of the season at home against the Buccaneers. I don't see why there was a 2.5-point line move in favor of Atlanta. A lot of people are impressed with the Falcons but they have won all there games as small underdogs. Now they have a different role as a big favorite and I think they struggle trying to cover this number. The Texans have a solid defense and will keep this game close.
Giants (+5) over Bills: The Bills are another team that the public is in love with after a 2-1 start. I was on the Bills last week and they dominated against the Dolphins. Now injuries have caught up with Buffalo as running back LeSean McCoy and wide receiver Sammy Watkins are out for this game. The Giants have an extra three days to prepare for this one and are a few plays away from being 3-0. This is a pretty big number for quarterback Tyrod Taylor and the Bills to cover. I think Buffalo has a letdown after three grueling games against the Colts, Patriots and Dolphins.
Rams (+7) over Cardinals: The Rams burned me last week but they I'm going back to them this week. The lookahead line going into Week 3 was Cardinals -4 for this game. The Rams falling to the Steelers 12-6, and the Cardinals routing the 49ers by 40 points is the reason the line has reached a full touchdown. The Cardinals played a great game against the 49ers but that was set up by two interception returns for touchdowns in the first six minutes. The 49ers were only a 6-point underdog in that game and the Rams are a better team than the 49ers this season. Along with the line value, Jeff Fisher teams do great in an underdog role against division teams. Last year the Rams led the Cardinals going into the fourth quarter in Arizona. The Cardinals scored 21 fourth quarter points, including two defensive touchdowns to get the 17-point win. But the Rams played the Cardinals close and the score was misleading. Arizona is 3-0 but they beat the Saints, Bears and 49ers who are a combined 1-8 this season. My strongest pick of the week is to take the Rams against the spread.
Rams (+1) over Steelers: I think the wrong team is the favorite in this game. The Steelers are coming off a blowout victory against the 49ers but the result is misleading. The 49ers were coming off a Monday night game and had to make the long trip to Pittsburgh on a short week. The Rams had a letdown against the Redskins after beating the Seahawks in Week 1. I think the Rams bounce back and we are getting some value after their poor performance against the Redskins. The Steelers play the Ravens on Thursday night in Week 4 so this is a lookahead game for them.
Eagles (+1.5) over Jets: Another game where we can take advantage of overreaction. The Eagles are 0-2 and their offense is struggling. The Jets are coming off a big Monday win at the Colts. Coming back on a short week is a tough spot for New York. The Eagles would the favorite in this game if they won one of their first two games and I think now is the perfect time to buy low on Chip Kelly's team.
Ravens (-2.5) over Bengals: This game is the season for the Ravens. They started 0-2 after falling to two AFC West opponents. Despite the two road defeats I think Baltimore still has a great chance of making the playoffs but they have to win this game. The Bengals might be a little better than the Ravens but considering home field and the situation, I think the Ravens cover.
Bills (+3) over Dolphins: The Bills were getting too much respect last week and closed as a favorite against the Patriots. They got in a shootout with the Patriots, and this Bills team won't win games playing high-scoring games. They need to run the ball and play well on defense, which is what they did against the Colts in Week 1. There was a lot of preseason hype surrounding the Dolphins this preseason but they have not been impressive in games over the Redskins and Jaguars. I see this being a low-scoring game and the Bills winning straight up.
Lions (+3) over Broncos: Another situation where I will back a 0-2 team that needs to win. The Lions are a much better team at home and the building will be rocking on a Sunday night. Despite winning and covering in the first two games, I have not been impressed with Peyton Manning and the Broncos offense. If Denver loses to Kansas City then this line is probably closer to a pick 'em. I'll take my chances with the Lions.
Chargers (+1.5) over 49ers: The 49ers have nothing to play for and Jim Harbaugh has one foot out the door in San Francisco. The 49ers also played the Seahawks last week and teams struggle the week after playing Seattle. The Chargers need this game to stay in the playoff race.
Vikings (+7) over Dolphins: The Dolphins aren't mathematically eliminated from the playoffs but they are pretty much done. Their coach also might be fired and the Vikings have been a covering machine.
Raiders (+7) over Bills: The Bills had a huge home win against Green Bay, and have held Peyton Manning and Aaron Rodgers without a touchdown pass the last two games. However, the offense has been terrible and their touchdown last week was a special teams score. The Raiders have shown up the last two times at home and won. I think they will cover this number and possibly spoil the Bills' postseason chances.
Bengals (+3.5) over Broncos: The Broncos are winning games but something is wrong with Peyton Manning. It looks like Denver is locked into the No. 2 seed so I don't think they will give a maximum effort on the road. The Bengals are in a must-win situation and I think they will be able to run with rookie running back Jeremy Hill. A successful running game will keep the ball out of Andy Dalton's hands, which would be ideal for Cincinnati in primetime.


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The Levels Academy Trust
Raising Aspirations, Realising Potential TOGETHER
Levels Academy Trust Structure
Details & CVs
Trustee Minutes
Trustee Documents
The Levels Academy Scholarship
Year 7 Taunton Preparatory School
To recognise the special relationship that Taunton School has with the four schools of the Levels Academy, we offer one scholarship each year that is only open to applicants from the Academy.
The award is made to a pupil that can demonstrate real promise in at least one of the following areas:
The scholarship awards are highly desirable, offering scholars a special programme and discounts on school fees of up to 40%, depending on attainment.
Applicants will be asked to attend the Year 7 scholarship day at Taunton Preparatory School to undertake a number of assessments and interviews. Whilst there is only one Academy Scholarship each year, talented applicants will also be entered in the open scholarships and further awards may be offered.
The scholarship days occur in early January each year. If you would like to find out more, please see our information pack. Alternatively please speak to our Prep School Admissions Registrar on 01823 703303.
INTERIM HEADTEACHERJeremy St. John
HEADTEACHERTiffany Doughty Davis
HEADTEACHERLindsay Hayward
Dear Parents and Carers,
In line with the latest government guidance all schools within the Levels Academy Trust are now closed for the foreseeable future from Tuesday 5th January. They will however remain open to all pupils of critical workers and our most vulnerable children.
All school staff will be providing online learning for all pupils, and will maintain regular contact. We will do everything within our power to educate your children in the best possible way over the forthcoming weeks.
Please stay safe and look after yourselves, and do not hesitate to contact us if you have any questions or concerns, or if you need any help.
Judith Barrett
CEO. The Levels Academy Trust
Year 7 Scholarship
We are four schools working together to provide an outstanding education in our academies
At The Levels Academy Trust we are passionate about making a difference to the lives of all our children. They are at the heart of everything we do and we strive to inspire learners and change their lives, as a result of our vibrant and personalised educational provision. We want all our schools to be the best they can be and for each child to discover the skills, abilities, talents and interests that lie within them.
We are privileged to have Huish Episcopi Primary School, Hambridge Primary School and Middlezoy and Othery Primary Schools presently within The Levels Academy Trust. We are building a family of schools who are prepared to truly collaborate. The schools have a desire to question, change and innovate to ensure that what they provide enables our children to become successful learners, confident individuals and responsible citizens.
We believe in the power of partnership, enabling us to ensure more children receive an exceptional education. Our member schools know the transformational impact it can have from experience. We all share the ultimate goal of driving high educational standards through the provision of outstanding teaching, leadership and learning for all.
At the same time, we recognise the importance for schools to retain and promote their individual identity and we endorse earned autonomy across the Trust. Every school has its own context and challenges. This is why we encourage our member schools to lead and manage in a way that preserves their individual identity and responds to the specific needs of their children and community.
Our leaders focus on offering the children a broad and balanced curriculum, on pupil progress and attainment and regularly share knowledge, insight and experience. We ensure that there is plenty of opportunity for all the staff to work in partnership, share best practice, share resources and attend shared INSET and Continuing Professional Development.
The combination of autonomy and collaboration across key areas of leadership and management, underpinned by shared vision, values and best practice is what makes The Levels Academy Trust unique.
If you would like to find out further information about The Levels Academy Trust please visit our website.
We recognise our moral and statutory responsibility to safeguard and promote the welfare of all pupils. We endeavour to provide a safe and welcoming environment where children and young people are respected and valued. We are alert to the signs of abuse and neglect and follow our procedures to ensure children and young people receive effective support, protection and justice.
Trustee Area
c/o Huish Episcopi Primary
Langport
TA10 9RW


Add detail to your models with this tools and equipment kit.
Includes all the parts to build a workbench, vice, tool chest, tool trays, spanners, step ladders, shelves, clocks, boxes and numerous tools.
The painted images are photos of the assembled D6 kit in use on the excellent 'Earl's Court' exhibition layout, by Terry Tew.


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motion pictures greatest year
Follies of 1938, Part 1: Hollywood's Greatest Year (YMRT #8) / July 2, 2014 by Karina Longworth
This micro-episode sets up a topic we'll be exploring throughout the summer: the films, stars and scandals of 1938. By midway through that year, Hollywood was in such a desperate downswing — and so concerned that Americans were losing interest not just in specific movies but in moviegoing as a habit — that the studios banded together to launch a massive PR campaign to convince the public that 1938 was Motion Pictures' Greatest Year. It wasn't.
This episode is shorter than usual, and not as polished as I would like it to be, particularly in terms of the recording quality, and these things are related. Mr. You Must Remember This has a new job, for which we are in the process of temporary relocating to San Francisco. I was short on time this week, and by the time I got around to recording, I was in Los Angeles and parts of my usual recording set-up were en route to our new home. All should be back to normal by next week. I hope.
The primary research source for this episode was Catherine Jurca's fascinating book Hollywood 1938: Motion Pictures' Greatest Year. I basically piggybacked on her extensive, awe-inspiring research, and tried to synthesize it into something more anecdotal. This book gave me the idea to do a series of episodes stemming from the events of 1938, and so, while most of those future episodes won't necessarily have much to do with the MPGY campaign, I thought telling that story would be the best possible way to begin a series called Follies of 1938.
Next week, we're going to return to our other ongoing series, The Many Loves of Howard Hughes. The tentative plan for the next few weeks is to alternate between series, but I reserve the right to mix it up, too.
Music!
"Preludes for Piano #1" by George Gershwin
"Concerto in F Major for Piano and Orchestra I - Allegro" by George Gershwin, performed by Oscar Lavant with New York Philharmonic
"Lady Be Good," performed by Count Basie and his Orchestra
"Concerto in F Major for Piano and Orchestra II - Andante Co Moto" by George Gershwin, performed by Oscar Lavant with New York Philharmonic
"You Go To My Head," performed by Marlene Dietrich
New Episodes marlene dietrich, 1938, classic hollywood, old hollywood, motion pictures greatest year December 19, 2017


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Osama Alomar
Acclaimed Syrian Author
An Evening with Osama Alomar
Isabella Hammad
Dunya Mikhail
Mai Der Vang
Javier Zamora
Arab Studies
Exile and Refugees
Short Story Writers
"With their strange wisdom, wild personification, and fatalism, these miniature parables, or prose-poems, helped give words to the absurdly frustrating and sometimes terrifying experience of life in the Assad police state in the decade leading up to the Syrian Revolution. Alomar writes from a deep-seated belief in the act of writing as capable of transcending place and time." —Lydia Davis
"Alomar's sly moral fables and sharp political allegories are shrewd and full of intelligence." —Chicago Review of Books
"Transcending their less-than-lofty origins, Alomar's enigmatic flash fictions blur the lines between aphorism, parable, and fairy tale, often personifying household objects and animals to comment on modern politics and the human condition." –Vice Magazine
"If you laugh, it means you have immunity against hate. This is my responsibility as a writer, to keep writing about love, human rights, human dignity." –Osama Alomar
In his hometown of Damascus, Osama Alomar is one of the most highly regarded, prize-winning writers in Syria, author of four books and many journal publications. He is a prominent practitioner of, and heir to, the Arabic literary form al-qisa al-qasira jiddan ("very short story")—a form that dates back more than a millennium in the Arab world and contains elements of poetry, philosophy, folk tale, and allegory. In 2008, Alomar came to the United States to join his mother and older brother, who had emigrated in the 1990s; he has since lived in Chicago, working as a cab driver at the Horizon Taxi Cab Company. In a New York Times article, Alomar is quoted as saying, "Driving a cab is hard work and very hard psychologically, because it takes me away from writing. It is a kind of spiritual exile to go with my physical exile."
After years of literary obscurity, in 2014 Alomar's literary flame was rekindled by the excitement surrounding the publication of Fullblood Arabian, a collection of stories issued by New Directions as part of their renowned poetry series; then in 2017, New Directions released The Teeth of the Comb, Alomar's first full-length collection of stories, about which Kirkus Review wrote, "all are masterpieces of compression, presented with the generally unironic matter-of-factness of a fable that, no matter how improbable the circumstances, behaves perfectly well according to its own logic: that knife could be literal just as easily as metaphorical, considering the violence and mayhem of the world." Alomar's poetic fictions are strange, often humorously satirical allegories, where good and evil battle with indifference, avarice, and compassion alongside striking imagery and effervescent language. Lydia Davis describes them as "wasting no words…they go quickly from one moment to the next and on to the end. So they have density, but also are sort of explosive, with an aftershock, because they seem to tell one story at the same time they are telling another." Artsfuse Boston noted, "Alomar makes ample use of Middle Eastern traditions in his work. But, given its focus on hunger around the world, his stories are very much addressed to an international readership."
In English, Alomar has been published by Noon, Conjunctions.com, The Coffin Factory, The Outlet (the blog of Electric Literature), Ploughshares, Southern Review, Vice Online, Gigantic, Dissent, and The Literary Review. In Arabic, he has also published three collections of short stories: Ayuha al-insaan (O Man), Rabtat Lisaan (Tongue Tie), and Jami' al-huquq ghayr mahfuza (All Rights Not Reserved); and one volume of poetry, qaala insaan al' asir al hadith (Man Said the Modern World). He is a regular contributor to various newspapers and journals in Syria and the Arab world, among them Tishrin, an-Nur, Spot Light, al-Halil, Adab wa Naqd, and al-Ghad.
Christian Collins, Alomar's translator, writes: "Osama and I made these translations together in difficult circumstances: most were done in the front seat of his taxi in a Chicago suburb heavy with the ache of immigration and the unimaginable pain of watching one's country implode from afar. With books and dictionaries piled on the dashboard, hoping the taxi line wouldn't advance too quickly and force us to break our concentration with another 'load,' we were able to make some part of that lost world in Damascus live again, however briefly. May the act of bringing forth this significant Syrian voice in English serve to continue this spirit of understanding and tolerance, bringing depth and nuance to a situation and a part of the world too often reduced in American eyes to a violent caricature of the truth."
Born in Damascus, Syria in 1968 and now living in Chicago, Osama Alomar is one of the most well-respected Arabic poets writing today, and a prominent practitioner of the Arabic al-qisa al-qasira jiddan, the "very short story." He is the author of Fullblood Arabian in English, and three collections of short stories and a volume of poetry in Arabic. Alomar's first full-length collection of stories, The Teeth of the Comb, will be published by New Directions in April 2017. His short stories have been published by Newyorker.com, Noon, Conjunctions.com, The Coffin Factory, Electric Literature, and The Literary Review. He also performs as a musician. Osama Alomar travels with his translator, Christian Collins.
The Teeth of the Comb
Personified animals (snakes, wolves, sheep), natural things (a swamp, a lake, a rainbow, trees), mankind's creations (trucks, swords, zeroes) are all characters in The Teeth of the Comb. They aspire, they plot, they hope, they destroy, they fail, they love. These wonderful small stories animate new realities and make us see our reality anew. Reading Alomar's sly moral fables and sharp political allegories, the reader always sits up a little straighter, and a little wiser.
Full Blood Arabian
"The range of forms within this collection is matched by the versatility with which Alomar shifts tone, subject matter, and even structure from one story to the next. While some of the tales are explicitly angry or bitter, others are ironically detached, and still others make their point with a piece of sly wit." —Lydia Davis
A prominent practitioner of the Arabic "very short story" (al-qisa al-qasira jiddan), Osama Alomar's poetic fictions embody the wisdom of Kahlil Gibran filtered through the violent gray absurdity of Assad's police state. Fullblood Arabian is the first publication of Alomar's strange, often humorously satirical allegories, where good and evil battle with indifference, avarice, and compassion using striking imagery and effervescent language. Lydia Davis, in the preface to Fullblood Arabian, writes that Alomar "belongs at once to several different important literary traditions: that of the writer driven into exile from his own country and culture; and that of the writer of very short stories…. There was an explosion of this [short] form of writing in Syria in the 1990s; it became popular in magazines and newspaper as an expression of frustration at Syria's bureaucracy and corruption and lack of freedom of expression. In an economically depressed time, too, there was a demand for the densest, briefest, most compressed of stories—a longer literary work was in fact a luxury—and these were shared and circulated freely and spontaneously, like personal anecdotes."
• Osama Alomar's Very Short Tales – The New Yorker
• Artists from across the world find refuge in Pittsburgh's City of Asylum – FOX News
• Review of Osama Alomar's The Teeth of the Comb & Other Stories – The Brooklyn Rail
• Syrian author's tales confront human 'contradiction, complexity, madness' – Syria Direct
• How a Syrian Writer Takes on War – New Republic
• Osama Alomar: The Whole World Is Fighting – Guernica Magazine
• No Longer Driving a Cab, A Syrian Writer in America Focuses on His Fiction –The New Yorker
• Syria: Stories from the Barrel of a Cannon – The New York Review of Books
• Book Review: The Teeth of the Comb – NYT
• Writing in the Blood and Soul: Interview – Sampsonia Way
• Taking Fares, and Writing in Between: Alomar Pursues His Literary Ambitions in Exile — NYT
• Lydia Davis's Introduction to Fullblood Arabian — The New Yorker
• Creativity and Craft in Asylum — PEN American Center
• Excerpts of The Teeth of the Comb from The Paris Review
Title Story from The Teeth of the Comb
Some of the teeth of the comb were envious of the class differences that exist between humans. They strived desperately to increase their height, and, when they succeeded, began to look with disdain on their colleagues below.
After a little while the comb's owner felt a desire to comb his hair. But when he found the comb in this state he threw it in the garbage.
The following are all entire stories fromFullblood Arabian.
FULLBLOOD ARABIAN
The First, wistfully: "If only I were a fullblood Arabian horse!"
The Second, disdainfully: "Would you wish to be an animal when God in his mercy has created you as a human who belongs to a great and ancient nation proud of its glorious history?"
The First: "Man, don't you know that the value of a fullblood Arabian horse in this world is far greater than the value of a fullblood Arabian human?"
Before leaving for work I tied my tongue into a great tie. My colleagues congratulated me on my elegance. They praised me to our boss, who expressed admiration and ordered all employees to follow my example.
A star that had just been born said to her mother in a worried voice, "I'm afraid I will get lost in this vast universe, Mommy. I want to stick close to you."
"Stay in your place, sweetie," her mother said to her with confidence, "there's no need to be afraid of anything."
"But Mommy, how can that be? Don't you see the terrifying void around us that respects no limits?"
"This universe, darling, is subject to a surpassingly precise and strict system without which it would cease to exist."
"If that's true, then why do so many humans get lost so easily when the size of the tiny multicolored seed on which they live is negligible compared to the size of the universe?"
Hearing this, the mother star signed and said nothing.
Freedom was imprisoned inside the walls of time. And time itself exploded.


text:
Emma Carolyn Eastwood-Paticchio
emma.eastwood-paticchio@lw.com
Emma Eastwood-Paticchio is an associate in the San Francisco office of Latham & Watkins and a member of the firm's Litigation & Trial Department.
Ms. Eastwood-Paticchio represents public and private companies in a variety of litigation and investigatory matters. She also maintains an active pro bono practice.
Ms. Eastwood-Paticchio served as a law clerk to Judge John A. Woodcock, Jr., of the US District Court for the District of Maine. She received her JD from Stanford Law School. While there, she served as a senior editor of the Stanford Law Review and managing editor of the Stanford Technology Law Review, worked as a teaching assistant and a research assistant, and earned Highest Pro Bono Distinction.
Prior to law school, Ms. Eastwood-Paticchio worked as a research analyst for the New York State Office of the Attorney General.
JD, Stanford Law School, 2019
BA, Middlebury College, 2015


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