text:
\section{Introduction}

Recent works\cite{BBMP,CollinsQiu07}
have seriously re-discussed the ideas of factorization
and universality in hard processes aimed at
the detection of T-odd distributions.
In the last fifteen years the study
of these distributions
has often made it necessary to reconsider the basic properties
of the QCD-improved parton
model, in particular
factorization\cite{CollinsSoperSterman,Bodwin}.

In quark/parton physics the first T-odd
distribution function was probably
the Sivers function\cite{Sivers} in 1990, followed by the
Boer-Mulders-Tangerman
function\cite{MuldersTangerman96,BoerMulders98,Boer99}.
The former was used to explain single spin
asymmetries\cite{ABM95}, the latter to explain
unpolarized Drell-Yan azimuthal
asymmetries\cite{Boer99}.
Recently, it has been demonstrated\cite{JQVY06} that the T-odd
mechanism introduced in\cite{EfremovTeryaev82} and \cite{QiuSterman91}
produces a Sivers asymmetry when its effect is extrapolated into the
small transverse momentum region.
Also, in high energy nuclear physics a T-odd
structure function, the so-called ``fifth structure function'',
was introduced\cite{Donnelly}
and modeled\cite{BB95,BR97} to describe normal asymmetries
in $A(\vec e,\vec e' p)$ quasi-elastic scattering.

For justifying the same existence of leading twist
T-odd functions, the central object is the gauge restoring
operator entering the definition of parton
distribution\cite{CollinsSoperSterman}. In an approach
where factorization is assumed from the very beginning, this gauge
field is assumed to be negligible at leading twist, but in its
absence T-odd distributions
are  forbidden\cite{Collins93} by general
invariance principles.
A chain of arguments and
examples\cite{BrodskyEtAl02,BrodskyHwangSchmidt02,Collins02,JiYuan02,
BoerBrodskyHwang03,BelitskyJiYuan03}
has shown that
proper taking into account the gauge factor permits the existence of
leading
twist T-odd distributions in a QCD framework, associated with
formal factorization breaking by interactions in the
initial or final state. In the same works it has been shown that
in some cases it is possible to recover factorization from a
practical point of view.
Systematic efforts
have been undertaken\cite{JiMaYuan,JQVY06}
for rewriting factorization rules for processes where partonic
distributions depend on moderate values of the transverse momentum and
the gauge factor is assumed to play a role.

Several models and studies
have been published on T-odd
distributions\cite{Yuan03,GambergGoldsteinOganessyan03,
BacchettaSchaeferYang04,LuMa04,Pobylitsa03,DalesioMurgia04,Burkardt04,
Drago05,GoekeMeissnerMetzSchlegel06,BoerVogelsang06,Entropy3},
together with phenomenological
parameterizations of the Sivers
function\cite{Torino05,VogelsangYuan05,CollinsGoeke05,BR06a}
and of the Boer-Mulders-Tangerman function\cite{Boer99,BaroneLuMa05}.
So, we may say that T-odd distributions are an accepted reality,
although we have no data yet about their behavior at asymptotic energies.

This creates the problem of the coexistence of factorization breaking
and factorization, i.e. at which
extent it is possible to reconcile the interpretation of observable effects
in terms of factorization breaking interactions with
the safety of the extremely simple and useful
factorization/universality scheme for classifying phenomenology.
Also, it raises questions\cite{BrodskyEtAl02,Collins02}
on the probabilistic interpretation
of the measured distributions.
Most of the above quoted models assume, more or less
explicitly, that
the factorization breaking effects are there but small
enough not to overthrow the underlying parton model picture.
The analysis of \cite{BBMP}
and the observations by \cite{CollinsQiu07}
suggest that this point is still to be clarified,
especially in hadron-hadron single spin asymmetries.

Without considering a model in detail, we show here that
it is possible to restore an approximate factorization scheme
involving
the presence of nonzero T-odd distribution functions,
if factorization breaking interactions satisfy certain
restrictive conditions.

The central object of any distribution function calculation
is the imaginary part of an amplitude $G(2,1)$ that
describes the formation of a quark/hole pair at a spacetime
point 1, and the propagation of the hole up to the point
2 where the hole is filled by the quark again.
A value of the longitudinal fraction $x$ is associated with
this quark hole. By definition $x(1)$ $=$ $x(2)$.
In absence of factorization breaking interactions,
this is true also in local sense: the quark hole conserves
its initial longitudinal fraction along all the path from 1 to 2.

Factorization breaking interactions spoil this property.
In any precise model treatment of rescattering,
one includes explicitly degrees of freedom that
exchange $O(Q)$ amounts of momentum/energy with the quark
hole (see e.g. the calculations in ref.\cite{JQVY06}), and
consequently the wavefunction describing the quark hole
contains plane wave components associated to values $x'$
$\neq$ $x$. A way to quantify the effectiveness of rescattering
is to look at the size of the difference $x-x'$.

Our starting point is the idea that a rescattering mechanism
produces a finite but $small$ violation of $x-$conservation.
To formalize this, in section IV we introduce
the $x-$frequency spectrum
$f_\epsilon(x-x')$ of the rescattering operator
and require a set of properties for it. Qualitatively, we may
write since now that we require $f_\epsilon(x-x')$ to
consist of a regular and narrow peak at $x$ $=$ $x'$,
with finite width $\epsilon$ $<<$ 1.
In addition, we require $f_\epsilon(x-x')$ to respect
causality (see section IV for details).

The $\epsilon$ parameter is supposed to depend slowly
on $x$ and on $|k_T|$
($\vec k_T$ is the quark transverse momentum), and it expresses
the magnitude of $x-$nonconservation in
rescattering: $|x-x'|$ $\sim$ $\epsilon$.
In the limit where $\epsilon$ $\rightarrow$ 0, rescattering
does not affect the quark longitudinal fraction, and factorization
is fully respected.

That the frequency spectrum is large for $x'$ $\approx$ $x$, and small
when $x$ and $x'$ are very different, is suggested
by the fact that at a certain extent factorization
works empirically.
The assumption that the peak of $f_\epsilon(x-x')$ at $x'$ $=$ $x$
is regular is possibly not justified for
individual perturbative diagrams, but becomes more reasonable when
we consider resummed sets of diagrams,
or approximations where
some degrees of freedom have been integrated over,
or diagrams that are regularized
via cutoffs, form factors, and so on.
Clearly, the chosen values for model parameters may critically
influence the size of the relevant region of the frequency
spectrum. As above written, here we suppose that this
size $\epsilon$ is small.

If the rescattering operator frequency spectrum satisfies the
requested properties,
on the ground of simple arguments
we show that
it is possible to write a transverse momentum dependent
quark distribution in the form
$q_0$ $+$ $\epsilon q_1$ $+$ $O(\epsilon^2)$, where $q_0$ may be
calculated
in complete absence of factorization breaking terms, and $q_1$
is a T-odd correction.

This restores approximate universality for the T-even term: for
values of $\epsilon$ up to 0.3 it may be rather difficult to
detect deviations from the $q_0$ behavior. This also agrees
with the
known complete absence of screening effects in hadron-nucleus
Drell-Yan (see \cite{Kenyon82} for a review of the related experiments).

On the
contrary, the T-odd correction term is potentially
process-dependent unless one is able to demonstrate that
$\epsilon$ has universal features. An effort in this
direction has been undertaken
elsewhere\cite{Entropy3} by the author of the present work,
but the arguments presented here are
independent from the analysis in \cite{Entropy3} and so we do not put
constraints on $\epsilon$ in the following.

As a last remark, the enlarged-delta approximation\cite{BR97}
used in the following was developed to quickly approximate interactions
between a pointlike particle and a composite system coexisting at
the same time.
Although it is probably possible to
re-examine it, and to extend its validity to the case where the interacting
particles exist at different times (the case of lepton-hadron SIDIS,
and interactions between initial and final hadronic systems in
hadron-hadron SIDIS), the present analysis is
limited to the case of Drell-Yan and hadron-hadron initial state
interactions.

\section{Some general definitions and notations}

We work, as far as possible, in the traditional
picture of a distribution
function, where a quark/hole pair is formed in a proton state
$\vert P>$ at a spacetime point ``1'' $\equiv$ $(0,0,0,0)$,
and the hole propagates up to a point ``2'' $\equiv$
$(0,z_-,\vec b)$, where
the quark is restored with the same momentum $k_\mu$
it had in the origin.
The imaginary part of this amplitude gives, by suitable Dirac
projections,
all the distribution functions we need.

The quark/hole longitudinal fraction $x$ is defined by $P_+$ $=$ $x k_+$,
where $P_+$ and $k_+$ are the large light-cone momentum components
of the parent proton and of the quark.
The infinite momentum limit $P_+$ $\rightarrow$ $\infty$ selects
leading twist contributions.
Not to work with
singularities, we introduce the scaled longitudinal variable $\xi$:

\noindent
\begin{equation}
\xi\ \equiv\ P_+ z_-, \label{eq:def_xi}
\end{equation}

and a distribution function may be written as

\noindent
\begin{equation}
q(x,\vec k_T)\ \equiv\ P_+ \int e^{-i xP_+z_-} e^{ik_T b}
g(z_-,\vec k_T) dz_- d \vec k_T\ \equiv\
\int e^{-i x\xi} e^{ik_T b}
G(\xi,\vec b) d\xi d \vec k_T. \label{eq:def_qx}
\end{equation}

The range of useful values of $\xi$ remains
finite $\sim$ $1/x$ when $P_+$ $\rightarrow$ $\infty$.
So in this limit
the function $G(\xi,\vec b)$ does
not need to be singular in the origin to produce a nonzero $q(x)$.

The coordinate $z_+$ plays no role in the following and
is not explicitly reported anymore.

\section{Enlarged $\delta$ function}

We adapt here a technique from refs. \cite{BR97} and \cite{BR_JPG}
to roughly but quickly approximate the resummed effect of rescattering.
Rescattering obliges us
to include nonlocality with respect to $x$, involving
integrals of the kind $\int dx' f(x,x') h(x')$ where
the kernel $f(x,x')$ becomes $\delta(x-x')$ in the limit of
respected factorization. In this work we consider kernels that
allow for a $small$ $x-$nonlocality: $\vert x-x'\vert$ $\sim$
$\epsilon$ $<<$ 1.

Given a small nonzero parameter $\epsilon$ $<<$ 1,
we define an ``$\epsilon$-enlarged $\delta-$function''
$\delta_\epsilon(x-x')$ such as to satisfy:

(i) $x'$ $\approx$ $x$ within uncertainty
$\vert \epsilon \vert$,

(ii) $\int_{-\infty}^\infty dx' \delta_\epsilon(x-x')$ $=$ $1$.

\noindent
To define $\delta_\epsilon$
in the limited $x-$range $[0-1]$, (ii) is better modified
into:

(ii b) $1-\alpha\epsilon^2$ $<$
$\int_0^1 dx' \delta_\epsilon(x-x')$
$<$ 1, with $\alpha$ $\sim$ 1. This property is valid only
for $x$ $>$ $\epsilon$ and $x$ $<$ $1-\epsilon$, so values
of $x$ near 0 and 1 will not be considered in this work.

Such functions are
normally used to define the ordinary $\delta(x-x')$
function in the
$\epsilon$ $\rightarrow$ 0 limit.
Several functional choices for $\delta_\epsilon(x-x')$
are possible, the most useful for us is (for $\epsilon$ $>$ 0, else
$\epsilon$ $\rightarrow$ $\vert \epsilon\vert$):

\noindent
\begin{equation}
\delta_{\epsilon}
(x-x')\ \equiv\
{1\over \pi} {\epsilon \over {\epsilon^2 + (x-x')^2}}
\nonumber
\end{equation}
\begin{equation}
\equiv\ \delta_{\epsilon+}(x-x')\
+\ \delta_{\epsilon-}(x-x')
\equiv\
{i\over {2\pi}} {1 \over {x-x' + i\epsilon}}\ -\
{i\over {2\pi}} {1 \over {x-x' - i\epsilon}}.
\end{equation}

Causality implies the substitution
\noindent
\begin{equation}
\delta_{\epsilon}(x-x')\ \rightarrow
\delta_{\epsilon\pm}(x-x').
\end{equation}
that corresponds, in its Fourier transform, to
\begin{equation}
exp(-\epsilon \vert \xi \vert)\ \rightarrow
\theta(\pm\xi)exp(\mp\epsilon \xi)
\end{equation}

Since all the relations interesting us contain a function
$\theta(\xi)$ related with causality,
$\delta_\epsilon$ actually means $\delta_{\epsilon+}$,
i.e. one pole only is encircled in the complex plane integrations.

We are especially interested in the calculation of integrals
of the form $\int_0^1 dx' f(x') \delta_{\epsilon+}(x-x')$.
For $\epsilon$ $<<$ 1, and $x$ far from its kinematic
limits 0 and 1 ($x$ $>$ $\epsilon$ and $1-x$ $>$ $\epsilon$)
such integrals
may be assumed to be dominated by the $\delta_{\epsilon+}$ pole
$x'$ $=$ $x+i\epsilon$.

More precisely, we map
the $[0,1]$ $x-$range onto the $[-\infty,+\infty]$ $z-$range
by the transformation

\noindent
\begin{equation}
x\ \equiv\ {e^z \over {1+e^z}}\ \leftrightarrow\ z\ \equiv\ ln(x/1-x)
\label{eq:map1}
\end{equation}

\noindent
Since $dx$ $=$ $e^z/(1+e^z)^2dz$, and
for $x$ near the complex point $a$ we have
$1/(x-a)$ $\approx$
$(1+e^z)^2/e^z\cdot 1/(z-A)$
(where $A$ $\equiv$ $z(a)$)
we have

\noindent
\begin{equation}
{{dx} \over {x-a}}\ \approx\ {{dz} \over {z-A}}
\hspace{0.5truecm}for \ x\ \approx\ a.
\label{eq:map2}
\end{equation}

If the integral
$\int_0^1 f(x') \delta_{\epsilon+}(x-x')$ is dominated by the
$x'$ $=$ $x'-i\epsilon$ singularity we have:

\noindent
\begin{eqnarray}
\int_0^1 f(x') \delta_{\epsilon+}(x-x') dx'\ =\
{1 \over {2\pi i}}
\int_{-\infty}^\infty {{f[x'(z')]} \over {[z' - z(x+i\epsilon)]}} dz'
\\
\ =\ f(x + i\epsilon)
\ =\ f(x)\ + {i \epsilon} {{df} \over {dx}}\ +\ O(\epsilon^2).
\label{eq:approx1}
\end{eqnarray}

\section{Insertion of factorization breaking interactions}

Let us define

\noindent
\begin{equation}
q_0(x)\ \equiv\
\int d\xi e^{-ix\xi}
< P \vert \psi(\xi)\psi^+(0) \vert P >,
\label{eq:q_0}
\end{equation}

\noindent
\begin{equation}
q_\epsilon(x)\ \equiv\
\int d\xi e^{-ix\xi}
< P \vert \psi(\xi) F_\epsilon(\xi) \psi^+(0) \vert P >.
\label{eq:q_epsilon}
\end{equation}

Of the previous two equations, the former defines a parton-model
leading twist quark distribution, the latter includes the effect of
a rescattering operator $F_\epsilon(\xi)$, where a parameter
$\epsilon$ quantifying the strength of $F$ is explicitly
reported. For $\epsilon$ $=$ 0,
$F_\epsilon$ reduces to unity, and $q_\epsilon$ to the parton
model definition.

We assume that $F_\epsilon$ is scalar, only to simplify the following
relations (else, a double sum is present, see the end of this
section). We introduce the frequency spectrum $f_\epsilon(x-x')$:

\noindent
\begin{equation}
F_\epsilon(\xi)\ \equiv\
\int dy e^{-iy\xi} f_\epsilon(y), \hspace{0.5truecm} -1\ <\ y\ <\ 1.
\label{eq:freq_spectr0}
\end{equation}

\noindent

For $f_\epsilon(y)$
we assume the following properties:

1) Although $f_\epsilon(y)$ is not a delta function,
it consists of a peak at $y$ $=$ 0.

2) This peak is regular on the real axis.

3) The width $\epsilon$ of the peak is small:
$\epsilon$ $<<$ 1.

4) $f_\epsilon(y)$ is negligible for $|y|$ $>>$ $\epsilon$.

5) For $\epsilon$ $\rightarrow$ 0, $f_\epsilon(y)$ $\rightarrow$
$\delta(y)$.

6) The shape of this frequency spectrum is causality-modified,
so that $F(\xi)$ contains the factor $\theta(\xi)$. In other words,
$f_\epsilon(y)$ is not an ordinary function but a distribution,
associated with given integration rules.

The previous hypotheses allow one to approximate $f_\epsilon(y)$
the following way:

\noindent
\begin{equation}
f_\epsilon(y)\ \approx\
\delta_{\epsilon+}(y).
\label{eq:freq_spectr}
\end{equation}

Now we may write

\noindent
\begin{eqnarray}
q_\epsilon(x)\ =\
\int d\xi e^{-ix\xi}
< P \vert \psi(\xi)
\int dy e^{-iy\xi} \delta_{\epsilon+}(y)
 \psi^+(0) \vert P >
\ =\\
=\
\int dy \delta_{\epsilon+}(y) \int d\xi
e^{-i(x+y)\xi}
< P \vert \psi(\xi) \psi^+(0) \vert P >
\ =\\
=\ \int dy \delta_{\epsilon+}(y) q_0(x+y)
\ =\
\int dy \delta_{\epsilon+}(x-y) q_0(y).
\label{eq:dist_q1}
\end{eqnarray}

Applying the approximation eq.\ref{eq:approx1} we get

\noindent
\begin{equation}
q_\epsilon(x)\ \approx\ q_0(x + i\epsilon)\
\approx\ q_0(x)\
+\ {i \epsilon} {{dq_0} \over {dx}}\ +\ O(\epsilon^2). \label{eq:dist_q2}
\end{equation}

If one wants to be more precise and consider the non-scalar
operator nature of $F_\epsilon$, one may introduce explicitly
the matrix sum
$<P\vert \sum_{i,j}....\vert P>$,
and apply the previous
considerations to each of the terms of the sum.

\section{Detection of the finite imaginary part of the amplitude pole
as a T-odd distribution}

For making the above imaginary shift observable in the form of
a T-odd $\vec k_T-$dependent distribution function,
factorization breaking interactions
must also produce nonzero interference between orbital states differing
by one unit.

So, we apply the considerations of the previous subsection to
the impact parameter dependent distribution $q(x,\vec b)$.

As a reference example, we consider the Sivers distribution.
A Sivers contribution in agreement with the Trento definition\cite{Trento}
may be introduced in the unpolarized quark distribution of a
transversely polarized proton as

\noindent
\begin{equation}
q(x,k_x,0) \ =\
q_U(x,k^2)\ +\ {k_x \over M} q_S(x,k^2),
\label{eq:trento_sivers}
\end{equation}

\noindent
where we have assumed that the proton is fully polarized along the
$\hat y$ axis.

We may Fourier-transform this equation with respect
to $\vec k$, for $k_y$ $=$ 0, and write the result in the form

\noindent
\begin{equation}
q(x,\vec k)\ =\
\int d^2 b e^{i b_x k_x}
\Big(
Q_U(x,b^2)\ +\ i b_x {\partial \over {\partial (b^2)}} Q_S(x,b^2)
\Big)
\ \equiv\
\int d^2 b e^{i b_x k_x}
\Big(
Q_U(x,b^2)\ +\ i b_x \epsilon''(b^2) Q_S''(x,b^2)
\Big)
\label{eq:Qb}
\end{equation}

\noindent
where $Q_{U,S}$ is the Fourier transform of $q_{U,S}$ with respect to
$exp(i\vec b \cdot \vec k)$, and all Q-functions are real and
$\vec b-$even.

If we apply the above eq.\ref{eq:dist_q2} to the impact parameter
dependent distribution, and explicitly separate the $b_x-$even and
$b_x-$odd parts of $\epsilon$:

\noindent
\begin{equation}
\epsilon\ \equiv\ \epsilon'(b^2)\ +\ b_x\epsilon''(b^2),
\label{eq:epsilon1}
\end{equation}

\noindent
\begin{eqnarray}
Q_\epsilon(x, \vec b)
\ \approx\
Q_0(x + i\epsilon, b^2)\
\approx\ Q_0(x, \vec b)\
+\ {i \epsilon} {{dQ_0(x,b^2)} \over {dx}}
\\ \equiv\
Q_0(x, b^2)\
+\ {i \epsilon'(b^2)}
{{d Q_0(x,b^2)} \over {dx}}
+\ {i b_x \epsilon''(b^2)}
{{d Q_0(x,b^2)} \over {dx}},
\label{eq:distq3}
\end{eqnarray}

\noindent
it is evident that a part of the frequency spectrum of the
interaction operator contributes to the
Sivers term in eq.\ref{eq:trento_sivers}.

\section{Conclusions}

In this work, we have considered the action of a set of
factorization breaking interactions, whose frequency spectrum
is regular and peaked near the condition of conserved $x$.
We required the width of this peak to be small:
$\delta x$ $\approx$ $\epsilon$ $<<$ 1.

We have shown that for such interactions it is possible
to retain the factorization scheme, and
write the result of the calculation of a distribution function
as a series expansion with
respect to $\epsilon$.

The zeroth-order term is the T-even and universal distribution
function $q(x)$ corresponding to the
complete absence of initial state
interactions. T-even corrections to $q(x)$ appear
at second order in $\epsilon$.

The first order correction is a T-odd distribution
function, detectable in angular even-odd interference terms.
It cannot be stated to be universal, at this level of analysis.

redpajama_set_name: RedPajamaArXiv


text:
info@woodfordarchitecture.ca
11 Rowan Street
Woodford Architecture
is a design studio located in St. John's, Newfoundland.
Woodford Architecture is a design studio located in St.John's, Newfoundland. The practice works primarily on community, commercial and residential projects across the island and Labrador. Our practice is directed by a focus on creating buildings in context that enhance experience of the natural landscape, and provide effective, useful spaces for our clients and their communities.
Since 2013 the firm has built varied portfolio of innovative context based design work with featured projects in a growing number of local and international publications. Our work includes community centres, private residences, commercial and retail establishments, heritage restoration and adaptive reuse projects, as well as institutional park and recreational facilities. We provide a full range of architectural and interior design services from concept to construction, from initial renderings to final finishes.
Firm Ethos
Our design work is rooted in the culture and economy of materials in an island condition. As a group, we are committed to using design and research as a tool to celebrate and enhance our communities – framed by context. We are working towards building a body of knowledge about historical and traditional uses of local materials to help inform all of our projects. We see this as a fundamental element of our practice.
Our office does not seek to fixate on the remoteness of Newfoundland and Labrador.
Instead it strives to create spaces and works of all scales that service their communities well. This ultimately entails an appreciation for the varied culture of Newfoundland and Labrador, and an earnest understanding of the complexity of life both on the island and the mainland.
To help form such spaces, and to further resolve the ideas driving their design, we continually seek to find opportunity for experimentation and aesthetic exploration. Ultimately hoping to endorse our vision of balancing social, economic and environmental concerns.
About Chris Woodford
CHRIS WOODFORD
MRAIC / NLAA / LEED-AP / MARCH / BEDS
partner / architect
A native of the Goulds, Newfoundland, Chris Woodford began his architectural education at Dalhousie University in the fall of 2000.
After working on several projects on the island, he headed west to Vancouver BC in 2006 to focus on design, sustainable building, and adaptive reuse of heritage buildings. In 2007, Chris began working at the small but recognized firm of Gair Williamson Architects. In 2011, he joined the team at Saunders Architecture in Bergen, Norway working on projects both locally and in Newfoundland.
Chris's priority in design is to ensure the physical realization of design through craft. He has focused on maintaining a strong working relationship with contractors and builders through a frequent presence on site. Chris has designed and has overseen the completion of several award winning built works.
KATHY OKE
M.ARCH / BFA
intern architect
After studying Visual Art and Art History at Memorial University – Grenfell Campus, Kathy worked for two years as an artist and arts administrator before heading to Vancouver to enter the Master of Architecture program at the University of British Columbia School of Architecture and Landscape Architecture in 2015.
Kathy's interests lay in the study of spatial heritage on the island of Newfoundland, examining the ways in which space has been occupied and defined throughout the history of this place. She is interested in the processes of making and object-based improvisational problem-solving exhibited throughout the province.
DEVAN BURRY
Born in Steady Brook, Newfoundland, Devan studied Visual Arts at Memorial University – Grenfell Campus, followed by a year-long artist residency in St. John's where his art explored concepts of the built form through the layers of printmaking. In 2011 he moved to Vancouver BC to complete his Master of Architecture at the University of British Columbia and spent the subsequent years working for award winning firms Mcleod Bovell Modern Houses and Office of Mcfarlane Biggar Architects + Designers. He moved home to the province in 2021 and joined Woodford Architecture shortly after.
He believes the most complex problems often have the simplest solutions and appreciates the experiential quality of a well-designed space. His work experience ranges in scale and typology from small retail fit-out, luxury homes, multi-family residential, institutional, community spaces, and transportation.
11 Rowan Street, Churchill Square
St. John's, Newfoundland
© 2023 Woodford

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text:
Q: How do I find which template is being referenced using smarty syntax? I currently have the following code that is written in with Smarty templates, and I'm a little unsure how to deal with the syntax:

{component ProfileActions profile_id=$actorId}

    {if $owner_mode && $componentManage}
        {component $profile_component_select}
    {/if}

I understand that there is a div being created here, and that within that div they've added a component called "profileActions"; however, i do have a file folder called "components" and there is a style sheet called "Profile Actions", but it's empty. I'm a little unsure where this is coming from exactly. I don't know how to make edits to this stylesheet. could someone please tell me what the code is saying?

A: What you see here:
{component ...}

component is the custom Smarty Function. You can find it in Smarty plug-in directory or in a file that keeps all functions (if there is one) for your project.
In case you want to find the ends, just search through your whole web-site directory for the following content:
smarty_function_component

It must be found anyway, because it's the only way you can register custom Smarty function.
EDIT 1:
If the plug-in is registered dynamically using registerPlugin method:
$smarty->registerPlugin("function","component", ...)

then you would have to search for the following instead:
registerPlugin("function","component"

or
registerPlugin(" function ", " component "

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Last week's slew of economic data from the CSO did little to provide a clear picture of the current direction of the economy. In the national accounts data, 2013 GDP was down, albeit only slightly, while GNP was up a hefty 3.3 per cent.
GDP is a measure of the output that takes place in a region; GNP is a measure of the income that accrues to residents of a region. A rise in GNP should be unambiguously good. However, across the economy there is little to indicate what is driving the increase in income for Irish residents. Employment is up but little else is.
Also released were the Balance of Payments data and this seems to paint a very positive picture.
In part the improvement was driven by the fall in imports after the end of the credit-fuelled consumption and construction boom in 2008.
On issue with this is that the fall was abrupt and was completed by 2009 as construction, car sales and other elements of the economy ground to a halt. So what has driven the continued improvement in the current account since 2010?
Last year, Prof. John Fitzgerald in a useful note outlined the impact that the retained earnings of companies re-domiciling to Ireland had on the figures. In essence, when a company moves its headquarters to Ireland any retained earnings it has are counted as Irish "income" at the time the company moves to Ireland. These are added to GNP as the companies have become Irish resident but they have no impact on the domestic economy. If the companies subsequently remit them as dividends to their foreign shareholders they will subtract from GNP at that time.
The rise in the inflow of these earnings in 2010 is fairly clear.
Again, one issue with this is the stepped nature of the increase. This undoubtedly led to an improvement in the current account but in relative terms the current account continued in 2012 and 2013 when the impact of retained earnings seemed to have levelled out (though 2013 figures are not available).
Within the Balance of Payments the CSO provide a breakdown between the "IFSC economy" and the "non-IFSC economy". The performance of the current account for each are shown below.
In 2012 and 2013 the current account associated with "IFSC" companies has been increasing while that associated with "non-IFSC" companies has been flat. The "non-IFSC" current account has improved since 2008 – because of the import reduction and also likely because of the re-domiciled firms – and there is only a very small "non-IFSC" surplus.
It is not clear to what extent the re-domiciled firms are "IFSC" or "non-IFSC" but it can be seen that the "IFSC" current account was largely unchanged in 2010 and 2011 when the effect identified by the John Fitzgerald was increasing. It seems as though the impact of the re-domiciled firms is reflected in the 2010 improvement in the "non-IFSC" current account.
We can further break the "IFSC" balance into that determined by trade (service exports minus service imports) and that attributable to income (income inflows minus income outflows).
Both improves in 2013, but the balance of services for "IFSC" companies improved in both 2012 and 2013. What is noticeable is that the service trade gains for IFSC companies is not reflected in an outflow of IFSC income. The trading gains are likely accruing to Irish-resident companies and are thus recorded as part of GNP.
If the changes in the IFSC balances were due to the timing of the re-domiciling of companies it would only show up on the income side. As the IFSC service balance is also improving it is the case that the improvement in the Balance of Payments current account (and thus the improvement in GNP) is down to the activities of IFSC companies.
There aren't many who would consider that an improvement in "Irish" income. There are gains from this as around €1 billion of corporation tax is paid by IFSC companies annually (though this is a claim from the IFSC itself). All this highlights the difficulties in ascertaining anything about the direction of the Irish economy given the impact things like the IFSC and MNCs have on the national aggregates.
In 2008 and 2009 Ireland's current account improved because of the large drop in imports. It seems much of the improvement since then can be attributed to re-domiciled firms (which are foreign owned) and the activities of IFSC companies. They are unlikely to be of much use in helping to pay down our external debt.
The relative importance of SMEs to the Irish economy has been touched on during the recent discussion of SME debt. Sometimes it is stated that SMEs provide 70 percent on employment. That is not quiet true. Something along the lines of 70 per cent of people engaged (employee or proprietor) by private sector enterprises are with SMEs is better but it can be seen that this excludes all public sector workers and the self employed.
In 2011, SMEs (employing less than 250 persons) accounted for 99.8% of active enterprises, 68.6% of persons engaged, 50.1% of turnover and 46.0% of gross value added (GVA). GVA is the gross income from operating activities and is the balance available to enterprises to pay employees and realise a return on investment. It is noticeable that while SMEs employed almost seven in every ten persons in the business economy, they accounted for less than half of GVA.
The seven in ten statistic clear refers to "the business economy". As stated this excludes public sector employees and the self-employed.
SMEs count for around 42 per cent of employment in Ireland. SMEs are the largest source of employment but not 70 per cent of it.
Here is the submitted text for an article in this week's SBP on SME debt, the state of the banks and this year's stress tests for eurozone banks. It continues below the fold.
Should we fear an SME loan meltdown?
In 2007 Prof. Morgan Kelly identified the likely 50 per cent fall in Irish house prices. He set out the implications this would have for construction employment but suggested that the larger banks were "well-capitalized" with unemployment and "macroeconomic dislocation" being the main problems that would emerge. The analysis was incredibly accurate on house prices and the consequences for employment and it wasn't long before the impact on the banking sector also became clear.
The underlying factor to the most recent warning is not property price falls but the banks calling in loans provided to small and medium enterprises (SMEs) and in the event of their inability to repay the banks would foreclose on the businesses. Again the threat is to employment but it is not limited to 300,000 construction jobs; it is to SME employment across the entire economy.
Is there a "special" two per cent rate in Ireland for Apple?
Is there a "loophole" that allows Irish-incorporated companies to be non-resident here?
Is there a deal in Ireland to allow for "income taxed at lower rates"?
Should Apple have paid $890 million Irish corporate tax based on the 12.5 per cent rate instead of the $36 million paid?
At the time of the US Senate last May they was a lot of noise around a special 2 per cent tax rate that Apple had apparently negotiated with the Irish government. There is no doubt that there were targeted and generous tax breaks given to MNCs who set up operations in Ireland in the 1970s and 1980s but there is no 2 per cent rate for Apple.
Apple have never withdrawn this assertion, but at the same time they have stood back and let the Government kick up as much dust as they can around the issue.
The counter narrative advanced by the Government was that there is no special deal but Apple instead availed of a loophole in Irish law that allowed companies to be Irish registered but not Irish domiciled. This quirk of Irish tax law opened the door to low tax heaven we were told.
The loophole was closed in the Budget and the Government seems to have got the "no special deals" narrative back on track. Until last week that was.
Yes, Irish law does allow Irish registered companies to be non-resident. There is nothing unusual or "quirky" about that. The change announced in the Budget was not about making Irish-incorporated companies resident here. The change was a minor one which did not change the residency rules.
It merely said that if an Irish-incorporated company owned or controlled by foreign residents was not deemed to be resident in Ireland, under the test of management and control, that the company had to tell the Revenue Commissioners where they were resident. There is no change in the ability to have non-Irish resident, Irish-incorporated companies it is just that such companies have to declare their tax residence and cannot be "stateless". These residency rules apply to all companies; not just Apple.
To conclude McManus goes back to rates with reference to "income taxed at lower rates" in ASI's 2009 accounts.
Is this then the special deal that Apple told the US Congress existed but the Government denies? In the absence of any clarification it is a basis for legitimate suspicion and potentially a fatal hole in the "no special deals " claim.
This puts them in a very difficult position because the EU and the European Commission – who seem to have bought the no special deal line – may be wondering quite rightly if they have been sold a pup. They no doubt would like to know what "income taxed at lower rates" means as should anyone else paying the full statutory rate of 12.5 per cent corporation tax.
The meaning of "income taxed at lower rates" is a legitimate question. The answer is a tax rate of zero because the US allows Apple to defer the US taxes its owes on certain foreign-source income.
ASI will be taxed on the profits it generates from holding the global rights to Apple's intellectual property in the country in which it is resident. This could be in Cayman or Bermuda where there is no corporation tax or a corporation tax of zero. Instead Apple set up a structure and chose to have ASI tax resident "no where". The corporate tax rate in "no where" is also zero.
Everything ASI does is in the US but because it is not incorporated there it is not deemed to be resident there. ASI is incorporated in Ireland but it is a 'relevant' company to which the test of management and control is applied to determine residency. ASI is not managed and controlled in Ireland.
The "income taxed at lower rates" is achieved by ASI because it is "stateless". The US does have the right to collect corporation tax on all the profits earned by ASI but this has been deferred until the profit is repatriated as dividends to the US.
The corporate tax liability on ASI's profits is 35 per cent. The corporate tax paid on ASI's profits is almost nil. The US does not want to see Apple pay corporation tax on this profit in another country as it will reduce the amount it can collect. Ireland does not have any questions to answer on this. It is a US decision to allow ASI to defer its US tax liability.
is Apple avoiding paying $850 million of Irish corporation tax?
These are all legitimate questions but the answers are known.
There is no "special" two per cent rate in Ireland.
There is nothing unusual about Ireland's residency rules.
The "income taxed at lower rates" is taxed at zero as allowed by the US.
UPDATE: The Tánaiste, Eamon Gilmore, was asked these questions in the Dáil today by Joan Collins T.D. The answer he provided is here.
It deals with some of the issues but avoids others. It is noticeable that the United States, US corporation tax or deferral provisions are not mentioned at all. In the Senate hearing last May the US Senators were quick to heap blame on Ireland for outcomes caused by US tax laws – many that they had voted for. On this side of the Atlantic we daren't even say the name the country.
Ireland's corporate tax regime continues to attract attention. The 12.5 per cent rate is low by any standards but it is the regime around the rate that is in the spotlight.
Much of the recent attention focuses on the test of residency Ireland applies to companies. This is an important part of any corporation tax regime. Apple Sales International is an Irish-incorporated company but is not resident here. Is this unusual?
Ireland's corporation tax regime is not unusual in one way: Ireland taxes resident companies on their worldwide income. This is in contrast to a territorial system where resident companies only pay taxes on profits earned in the country they are resident in. Some countries, most notably France, adopt territorial systems. The US, notoriously, has a worldwide system, but unlike the US there are no deferral provisions for Irish companies paying Irish corporation tax on their non-Irish source income.
The deferral provisions available in the US tax code are the key factors behind the tax outcomes attracting attention in the current debate. But tax residency is also important. If a company is not a tax resident in Ireland but has operations here it will still be subject to Irish corporation tax, but only on the profits actually sourced here.
This is a common official line in the debate. Ireland can tax the worldwide profits of companies which are resident here and also the Irish-source of non-resident companies. A company cannot have profits in Ireland that are untaxed. Naturally, Ireland cannot tax the worldwide profits of companies which are not resident here. Claims to the contrary are wide of the mark and in the case of Apple people should remember that Apple is a US company.
Ireland's residency rules are a relatively straightforward. In general, a company is resident in Ireland if it is either incorporated in Ireland or has its place of central management and control in Ireland.
However, there are some exceptions to this and for certain companies only the test of management and control is used to determine if they are resident in Ireland. The test of incorporation is not applied.
Under the "trading" exemption an Irish incorporated company is not treated as Irish resident if it is a 'relevant' company. A 'relevant' company must either carry on a trade in the State or be related to a company that carries on a trade in the State and is one that is either ultimately controlled by non-residents or owned by non-residents (based on the stock market its shares are traded on), where the non-residents are in an EU or tax treaty country. A company will not be a 'relevant' company if it is centrally managed and controlled in Ireland.
Thus, only the test of management and control is applied to some foreign-controlled or foreign-owned companies to determine their residence in Ireland even if they are incorporated here. This provision is not available to "brass-plate" operations. There must be a trade or "presence of substance" in Ireland. Foreign companies can have non-resident, Irish-incorporated companies but only if they have a presence, i.e. employment, here.
The fact that the residency of some companies is solely based on the test of management and control is a factor in the "double-Irish" tax strategy used by some US companies to facilitate the deferral of their US tax liability while holding the profits in a low/no tax jurisdiction.
The "double-Irish" depends crucially on the "same-country" exemption in Subpart F of the US tax code. Without this exemption the strategy is redundant. In general, US corporation tax must be paid on US companies' foreign-source passive income as soon as it is earned. However, there are a number of provisions that allow the deferral of this tax until the profits are repatriated as dividends to the US.
The "same-country" exemption is one such provision. Transfers of certain passive income between two companies in the same country do not trigger a US corporation tax payment – the view being that a transfer between two companies in the same country would not be done for US tax purposes.
However, what the US views as two companies in the same country (based solely on the test of incorporation) and what other countries view as two companies in the same country (perhaps based on the test of management and control) may not coincide.
In Ireland's case some US companies have two Irish-incorporated subsidiaries. The first can be a sales operations which is deemed as resident here and the second a related holding company to which the Irish "trading" exemption applies. Though incorporated here the holding company will not be deemed a resident here as its effective management and control does not take place here (nor any other part of its structure or operations). In many cases the holding company will be based in a low/no tax jurisdiction in the Caribbean.
The Irish-resident sales company will make patent royalty payments (passive income) to the Caribbean-resident holding company. This will not trigger a US tax payment as the US tax laws view the two Irish-incorporated companies to be Irish residents and then the transfer between them benefits from a deferral under the "same-country" exemption.
As stated, the most crucial part of this scheme is the "same-country" exemption in the US tax code. There would be no "double-Irish" without it. The second part is the interaction with another country where companies incorporated there are not automatically deemed resident there. The use of the test of management and control facilitates this. This allows the companies to be in operated in different countries but the US law views them as being in the same country.
It could be equally be a "double-Cypriot" or a "double-Mexican" or a "double-Sri Lankan", and it is almost certain that some US MNCs have set up twin-incorporated companies in these countries to avail of the "same-country" exemption. It just seems the companies that do it from those countries haven't been put under the glare of public scrutiny.
But they are there. Here is a report of Yahoo using a "Double-Singapore" and it even has a "Dutch-Sandwich".
Yahoo recently introduced another circuitous path through the Netherlands to cut the taxes on profits from its Asian sales: Royalties travel from Singapore, through Dooves's house, to another subsidiary in Mauritius, a tax-friendly island off the southeast coast of Africa.
They may be about to set up a similar arrangement in Ireland! But it is not because of anything unusual or unique in Irish residency rules. As the list above shows ten countries base residency on the test of management and control on which the "same-country" exemption depends.
There is nothing unique or unusual about Ireland's residency rules despite much opprobrium to the contrary. The current international corporate tax regime confers the right on the US to tax the profits earned by Apple through its intellectual property. The fact that the US does not immediately exercise that right and allows a deferral of the tax (in theory the tax must be paid – eventually) is a matter for the US and the US alone.
Maybe the system will change and the tax rights will be assigned differently, perhaps by formulary apportionment, and it would be helpful if the debate moved to such a discussion. But why do that when you can just shout about Ireland.
Who is to blame for ASI's effective tax rate of 0.1%?
The current OECD-led network of tax treaties is about conferring the rights to tax income that is earned across borders. The purpose of the treaties is to avoid double taxation so the right to tax is determined by the rules that underpin the treaties.
Under the current system the rights to tax Apple's profits (earned from US research and development) lie with the US. The fact that the US, through its deferral provisions, doesn't exercise that right when the profit is earned but allows a deferral until the profit is "repatriated" is an issue for the US and the US alone.
Neither Ireland, Australia nor any other country have to right to tax those profits. Ireland can affect the rate levied on profits earned in Ireland but Ireland has no jurisdiction over the profits of non-residents earned in other countries. There is nothing that can be done here to change that. Ireland has no right to tax the profits of non-resident companies earned outside of Ireland.
Is Ireland to blame for the US not collecting US taxes? No, but it suits Capitol Hill that Ireland is blamed.
The current corporation tax system could be changed so that the right to tax the profits is conferred differently but that requires a change of the source, residence and transfer pricing principles currently used. The OECD's BEPS programme which change things but the debate is around the system as it is now.
Ireland's corporation tax regime is deliberately attractive for foreign investment. In general, however, these deliberations have given more thought to what not to change as opposed to what to change.
A major part of the attraction is stability. Things don't change - or at least they didn't up to last October. Ireland's corporation tax rate and regime get a lot of attention but what elements can be changed to change the outcome - the amount of tax paid either here or elsewhere?
There is no change that can be introduced in Ireland that will result in more corporate income tax being collected in say, Australia. Australia could move to impose a greater tax on Apple for the "profits" it earns there but that would violate every tax treaty Australia has entered into which sets out what should be taxed where (source and residence) and how much should be taxed (transfer pricing). Apple doesn't earn profit by selling to customers in Australia; it earns profit by designing a product in the US that Australians want to buy. The current rules attribute the profit to the activity in the US. If Australia wants to collect more tax from the sale of Apple products there it can do so via an increase in sales taxes.
There is also no change that can be introduced in Ireland that will result in more tax being collected in the US. There are a huge range of structures that can be put in place to allow US companies to defer the payment of their US corporate tax liability on their foreign-source income. The "double-Irish" and "stateless income" have got some public attention but many more are possible.
Why do companies engage in these particular strategies? Stability. Companies don't like having to change and reorganising their structure is time-consuming and costly.
The "double-Irish" (so-called even though it would work in numerous countries) is based on residency and, crucially, on the "same-country" exemption in Subpart F of the US tax code which allows the transfer of passive income between two related companies without triggering a US corporate tax payment. Companies use the "same country" exemption because it is a permanent feature of the US tax code – it needs a vote in Congress to be repealed. And the US law won't change. The other part involves finding a country that with appropriate residency rules. There are lots of possibilities. The US companies want a country that determines residency on the basis of the test of management and control.
Legally that is all that is required to set up a "double-Irish" type structure. The US company can establish two Malaysian-incorporated companies but have the management of one in another country – such as a Caribbean Island. The US parent company can transfer passive income between the two companies and use the "same-country" exemption to avoid triggering a US tax payment. Malaysia won't tax the second company, the one holding the profits, because it is managed in another country. This is the "double-Irish", Malaysian style.
Why don't US companies use Malaysia instead of Ireland? There are many reasons but stability is an important one. They don't want to have to reconfigure their arrangement because the country changes its rules. They want stability.
However, there are exceptions to this is. One is a 'relevant company' that is ultimately controlled by persons resident in the EU or in a country with which Ireland has concluded a double taxation treaty and is related to a company that carries on a trade in the State - the "trading" exemption.
This is a key feature of the Irish corporation tax regime. It allows the residence of some companies to be determined by their ultimate control – the test of management – but only for companies that are related to companies that trades here. You can only trade if you have employees. A "brass-plate" operation is not sufficient; companies need a presence of substance, i.e. employment, to be able to avail of this provision.
Could we change our tax residency rules to make all companies incorporated here resident here? Of course we could. That would definitely end any reputation for stability and it would end the opportunity for US companies to avail of the "same-country" exemption here.
We could do this and it is the case that the US companies don't need the Irish residency rules (or equivalent based on management and control) to achieve the same tax outcome. In fact using the "look-through" rule they don't need any residency rules at all to facilitate the passive income transfer to a related company in a low/no tax jurisdiction. Certain related companies in any two countries will do.
The "look-through" rule is far less restrictive than the "same-country" exemption and could be considered the "any country" exemption. Under the "look-through" rule hierarchical subsidiaries of a US company can be treated as a single entity by looking through the lower level to reach the higher level. Using this, passive income transfers can be made between subsidiaries in different countries as the transfer is considered to have happened within the same entity, so in essence is not considered to have happened at all.
Ostensibly, this was introduced to allow US companies to redeploy their foreign earnings in one country for re-investment and expansion in another country without triggering a US corporate tax payment. This is true for the majority of companies who use the rule but a small number of hugely profitable companies can use the rule to accumulate profits in low/no tax jurisdictions without triggering a US corporate tax payment.
So why don't companies use the flexible "look-through" rule instead of the more restrictive "double-Irish"? Many do but the "look-through" rule is only a temporary feature of the US tax code. Unlike the "same-country" exemption which requires a vote in Congress to be repealed, the "look-through" rule requires a vote in Congress to be continued. It actually expired at the end of the 2013 tax year but there is still plenty of time for it to be appended to any bill for it to apply for the 2014 tax year and beyond.
The "look-through" rule gave legislative effect to the "check-the-box" election introduced by the IRS in 1996/7. "Check-the-box" is little more than an administrative process in the IRS (but obviously one that has huge implications). "Check-the-box" allows US companies to determine if an entity in their structure should be treated as a taxable entity on its own right or combined with several subsidiaries to form a single taxable entity. By combining subsidiaries in a single tax entity the company can make passive income transfers between them without triggering a US corporate tax liability – the tax is deferred.
The "check-the-box" provision can be changed at any time. The IRS actually proposed doing so in both 1998 and 2003 but a non-binding resolution was passed in Congress asking the IRS not to change the provision – the IRS complied. And anyway, Congress went ahead and partly formalised "check-the-box" with the introduction of the "look-through" rule in 2005.
However, there is sufficient doubt around the provision such that companies will seek a structure that is not dependent on it. They use it but if "check-the-box" changes they will ensure they can achieve the same result without it. The "same-country" exemption offers that security hence the use of "double-Irish" type structures.
The "stateless income" scheme of Apple was also based on stability. First was the certainty that the US would not change its company residency rules. They didn't. And certainty that 'stable' Ireland would not change its residency rules. But we did!
Although it was a very small change, and will have no effect on tax outcomes, the knock-on consequences of Ireland changing have yet to be determined. It is likely that a significant amount of thought went into the decision and as stated above more thought in Ireland goes to determining what not to change rather than what to change.
A company shall be regarded as a resident of Ireland if it is managed and controlled in Ireland. It is agreed that this provision does not prevent the application, according to Irish law, of the corporation profits tax in the case of a company incorporated in Ireland which is not managed and controlled in France.
A company shall be regarded as a resident of France if it is managed and controlled in France.
That is pretty clear. The residence of a company is based on the test of management and control. There is no possibility of setting up a "stateless company" between Ireland and France; it has to be managed and controlled somewhere.
US law does not recognise management and control. It is a US judgment that a US company which carries out all its operations in the US is not tax resident in the US. Who is to blame for that?
Ireland's rate and regime undoubtedly play a role in determining the very low effective tax rates attributed to some US companies but not one that is overly significant. The 12.5% rate is nice but that only applies to profits earned here (the companies will be subject to making up the balance at the 35% US rate anyway – if the US wants to collect it). The regime has its attractions but none are so significant that if they were removed the same tax outcomes could not be achieved by US companies. The government are trying to foster a reputation for transparency and cooperation. That sort of reputation doesn't concern the companies; a reputation for stability does. On the tax side companies use Ireland because they don't like change.
Yes, we have a low rate. Plenty of other countries do too. Yes, we have favourable residency rules for US companies. Plenty of other countries do too. We have a reputation for stability, not many countries have that. Britain's "patent box" is unlikely to form a major part of MNC tax strategies until it becomes embedded as a part of the UK tax system that is unlikely to change (which will take a couple of years of Labour in power).
If Ireland is guilty of anything in the international application of corporation tax, it is stability. A good reputation is hard won but easily lost. A bad reputation can be hard to shake off. In any debate if you are explaining you are losing; Ireland is losing.
The media debate about Apple's tax strategies continues, and continues to be wrong. The Irish Times today features an editorial under the heading 'Apple's lucrative tax loophole'.
The first thing to note is that Apple is a US company and therefore has to pay US taxes on all its profits. If Apple operates in other countries, as it does, in those countries it only has to pay tax on the profit it actually generates within those countries.
Apple takes on limited risk outside the US. It engages in manufacturing, distribution, and retailing. In Apple's operations none of these are very risky and none of them are very profitable.
The main source of Apple's profits are the products it designs. If Apple designs a good product, activity along its manufacturing, distribution and retailing arms will increase. If Apple designs a poor product that people don't want to buy, the activity along Apple's manufacturing, distribution and retailing arms will decrease.
Apple's manufacturing, distribution and retailing arms contribute almost no risk to Apple and do not add significant value to Apple's operation; designing innovative products does that. Apple could, and sometimes does, outsource manufacturing, distribution and retailing. It does not, nor will not, outsource designing. Apple is a designer of products.
Apple is rightly taxed where the intellectual property that results from this innovation is located. That is in the United States and the US rightfully taxes US companies on their global profits.
If Apple makes profits from selling to customers in Australia, the UK, Japan, Ireland or any other country it will have to pay tax at 35% to the US Treasury (less credits for any income tax paid on the profits from any low-margin manufacturing, distribution or retail activities it carries out itself in those countries).
Apple does not owe taxes on the profits earned by its intellectual property to any country but the US. That investment took place in the US; the R&D was organised and carried out in the US; and the resulting patents and copyrights (and of course Apple's trademark) are held in the US. Apple is a US company that owes US taxes.
But here is where the wrinkles come in. In many instances the US does not immediately collect the tax on the foreign-source (i.e. outside the US) income of US companies. The US levies the tax but does not collect it. Provisions in the US tax code allow the payment of the corporate tax by US companies to be deferred until the profit is repatriated from certain foreign subsidiaries to the US parent.
There is a universal deferral for the active income from manufacturing. However, Apple and related "new economy" companies don't make their profits from manufacturing; they make them from ideas. Ideas generate what is known as passive income. A patent holder earns money by charging to allow the use of the idea. The patent holder doesn't have to do anything, they charge someone to allow them to do something.
If a US company earns money from passive income it is immediately subject to the 35% US federal rate of corporation tax. If this was universal it would be end of the story. Apple earns lots of profits from selling to customers and most of this is rightfully attributed to the high-risk R&D it engages in so if the profits earned by Apple's patents were taxed at 35% this vacuous debate would not be happening.
In fact, it might be that a proper debate of the global system of corporation tax would occur. One that discusses, and understands, the merits and faults of the current system based on the source and residence principles, and the oft-proposed moved to formulary apportionment.
Alas, we are a long way from that. Why is that the case? The reason, and almost the only reason, that gives oxygen to this debate is that the US does not collect its 35% federal corporate income tax on the passive income earned by foreign subsidiaries of US parents. There is a raft of deferral exemptions built into the US tax code that allow these deferrals.
Apple earns huge profits as a result of its US-created intellectual property. Apple enters a cost-sharing agreement with a foreign subsidiary and licenses it to use its intellectual property in markets outside the US. This subsidiary, in turn, charges hefty license fees to Apple's manufacturing and retailing divisions right around the world.
Given the current success of Apple this subsidiary accumulates massive profits. Under US tax law the earning of this subsidiary are passive income (they come from the licensing of intellectual property) and therefore immediately subject to the 35% corporation tax. The subsidiary is using intellectual property developed in the US so this is what could be expected to happen.
But it doesn't. Although passive income should immediately trigger the US 35% corporate tax it is very simple for US companies to avail of some of the many deferral provisions that have been appended to Subpart F of the US tax code over the years. These have a variety of names that include the "check the box" provision, the "look-through rule" and the "same- country exemption".
The detail is unnecessary but the effect of these is to allow US companies to defer US corporation tax on their foreign-source passive income that would otherwise be immediately subject to the 35% US corporation tax (with credits for any income tax paid in other countries). If interested there are some useful details in this Forbes article, opprobrium aside.
The starting point is the cost-sharing agreement the parent company enters with the foreign-subsidiary to allow it to avail of the intellectual property. In Apple's case this subsidiary is Apple Sales International.
ASI was, under Irish law, regarded as a "stateless" company.
There is, nor ever was, a provision under Irish law that allowed a company to be "stateless". Ireland has a pretty standard set of rules for determining whether a company is resident here. Using those rules ASI is not resident in Ireland and there is nothing untoward about that. International companies are non-resident in most of the countries they operate. They are a resident in one.
The key is the other country ASI operates in. In fact almost all of ASI's operations are in this other country but that country did not judge it to be resident there. All of ASI's activities are carried out in the US, but under US law residency is determined on the basis of place of incorporation. ASI in incorporated in Ireland. Again there is nothing unusual about companies being incorporated in one country and being resident somewhere else.
The key here was that Apple designed a company that was tax resident nowhere. It was gaps between tax codes that allowed this not any loophole in the Irish tax code. Ireland has moved against it but not to make companies like ASI resident here. The change will merely ask companies that fail the test of management and control here to state where they are resident with a failure to do so resulting in them being deemed resident here.
This was a move for reputational reasons only. It will have no impact whatsoever on the tax paid by Apple. Apple is a US company that owes US tax. It is laws passed by the US Congress in Washington that allow Apple to defer the tax due on its passive income.
The US companies are happy with this and despite much loud gnashing of teeth the US politicians are happy with this. The fact that much of the ire is being directed at Ireland suits all the US participants.
If the US immediately taxed the foreign-source passive income of its companies the residency of ASI would almost be an irrelevancy. If that was the case you can be sure that the US would not be happy if ASI was deemed Irish resident. Then Ireland would be collecting tax at 12.5% on profits which are the result of US activity and risk-taking. If so, the amount collected by the US 35% corporate tax rate would be reduced by the 12.5% tax collected in Ireland. Ireland has no entitlement to tax the profits earned by Apple's intellectual property (but can, and does, tax Apple for the limited activities that take place here).
Apple is not avoiding any Irish tax on the profits earned by its intellectual property. There is no sane reason to argue that Apple owes corporate tax to Ireland for sales to customers in Australia, Germany, the UK and Japan which generate profits based almost entirely on intellectual property developed in the US (some manufacturing and retailing that takes place here aside).
It is a nonsense argument but one that continues. And in any debate if you are explaining you are losing. Ireland is losing.
If the US wants to collect tax on Apple's foreign-source passive income rather than allow it be deferred it could do it almost overnight. It would be an easy change.
Instead the US continues to allow deferral provisions that exempt foreign-source passive income from immediately paying US corporation tax (the tax is due but only has to be paid when the foreign-source profit is repatriated to a US-resident company, and in the absence of this transfer then payment of the tax can be deferred indefinitely).
Suggestions that Apple "reduced its Irish tax bill by over €850 million" as claimed by The Irish Times are beyond ludicrous. Apple takes almost no risks in Ireland so to suggest that Apple in Ireland generated €850m/0.125 = €6.8 billion in profit (and that just from selling to Australians) is absurd. Apple owes US taxes on that profit and it is up to the US to collect it. We don't have to be their policeman.
The risk Ireland faces is that the US reforms its tax code and closes off some of the deferral provisions that the US technology and pharmaceutical companies come here to use. There is lots of noise around US tax reform but no sign of anything substantive emerging.
For now, we should just remember that Apple is a US company that owes US taxes and stop falling into the trap that suits those in the US – blaming Ireland.
The tax strategies of Apple get plenty of coverage in today's papers. This follows from an extensive report published by the Australian Financial Review yesterday. There is no doubt that Apple aggressively manages its global tax affairs and while Ireland is a part of that it is by no means the most important part.
The first part is that corporation tax is not organised on the basis of the some form of "destination" principle like for VAT or sales taxes. Under a such a system (or one based on formulary apportionment) some corporate income tax would be collected in the jurisdiction in which the products are sold. There are many complaints from countries where companies like Apple have huge sales but pay very little corporation tax. This is an argument against the system of corporation tax, not Irish corporation tax.
Corporation tax is based on a combination of the residence and source principles and tax treaties help manage the crossover of taxing rights via rules on double taxation.
Source refers to where the value added is created (albeit subject to shifting through transfer pricing) and residence refers to the domicile or location of the company. In general, companies deemed resident in a country are taxed on all their net income regardless of where it is earned and non-resident companies are taxed only on their profits sourced within that country.
Apple has large sales in Australia but because corporation tax is only charged on the profits sourced there Apple is able to use transfer pricing to shift the profits out of Australia. Apple can (legitimately) argue that very little value added is created in Australia and that all it does there is sell to customers. In Australia, Apple is taking on limited risks, limited functions and has limited assets, thus the logic within transfer pricing principles would say that its return should also be limited.
An argument for corporation tax on the basis of customers needs a huge change in the international system of corporation tax. It could be done but it is not in place now.
For a company like Apple the key elements of its operation to which added value can be attributed are research and development, intellectual property, manufacturing, distribution and retailing. Under the current system Apple logically asserts that their added value does not come from their customers but principally from the creativity underpinning their products, which is captured through patents and copyrights.
So once Apple has attributed the value added to the intellectual property the next question is the residence of the company that owns the intellectual property. As the IP is owned in that country all the net income earned by the IP will be taxed in that country.
And this is where Ireland comes in. Or is it?
The company that owns Apple's intellectual property (outside the US) in this case is Apple Sales International (ASI). ASI is an Irish-incorporated company but incorporation played no role in the description above – residence did.
ASI is not an Irish-resident company. It, for want of a better description, is like a company that was born here but now lives somewhere else. Under Irish tax law the residence of some companies is evaluated on the basis of where they are managed and controlled. ASI is one such company to which this test is applied. Where is ASI managed and controlled?
Today we have reports in The Irish Times here and the Irish Examiner here making various claims about Ireland's role in Apple's tax strategies. The most important detail is that ASI is not resident in Ireland.
More than $AUD8.9bn (€5.8bn) in profits have flown from Apple's Australian operations in the past 10 years to Apple's Cork subsidiary, it has emerged.
Certain Apple companies registered in Ireland pay no tax in the country due to a loophole in both the Irish and US tax codes.
There is no loophole allowing certain companies to "pay no tax" here. It is a standard rule. In fact, in the OECD's Model Tax Treaty the tie-break rule for determining the residence of a company is the test of management and control, which is what is applied by Ireland.
According to accounts obtained by The Irish Times for one of those unlimited companies, Apple Sales International (ASI), the consumer electronics giant cut its Irish tax bill by more than €850 million between 2004 and 2008, using an unexplained "lower rate".
ASI provides "sales and marketing services" to Apple subsidiaries around the world that sell iPods and iPads. Between 2004 and 2008, it reported profits before tax totalling $7.11 billion on sales of more than $29 billion.
The accounts for those years state the corporation tax that would be due using Ireland's 12.5 per cent rate – €890 million over the five years. But they also show how much corporation tax ASI actually paid to Irish authorities – just €36 million.
As ASI is not resident here, it only has to pay corporation in Ireland here on profits actually sourced here. ASI generates most of its profits from the intellectual property it holds and that is not located here. It is located in Cupertino, California. These profits that ASI accumulates are managed by Braeburn Capital in Reno, Nevada and the money is deposited in New York banks. The money never even passed through Ireland.
Tax of €36 million on the profits indicated suggests a tax rate of 0.1%. A useful description that shows how such a low tax rate can be achieved was provided in a post from last May. None of this is news but it is deemed worthy of front-page coverage today.
So there is just one question that remains. Where is ASI resident? That is in the United States surely. Almost everything to do with ASI happens in the United States. Everything that is, except its incorporation. ASI is an Irish-incorporated or registered company.
Apple is exploiting a gap between tax codes rather than within them. Ireland uses the test of management and control to determine ASI's residency. As it is managed and controlled in the US it is not resident here. The US uses the test of incorporation to determine ASI's residency. As it is incorporated in Ireland it is not resident there.
It seemed incredible at the time but ASI was tax resident nowhere. The "lower rate" that The Irish Times refer to is that tax rate that applies to "stateless income", i.e. zero. It is not a rate that is applied by either country [there are no "special" rates in Ireland – well not now anyway; see here and here] it is a rate created by claiming the company is resident nowhere. That is wrong.
Either or both of Ireland and the US could have moved against this. Ireland did with the announcement in last October's budget that Irish-incorporated companies that are not judged to be resident here under the test of management and control must state to the Revenue Commissioners where they are actually resident or they will be deemed to be resident here. It closed the loophole between the Irish and US tax systems.
The US could have moved in a number of ways. Apple is, after all, a US company.
The US could follow Sen. Levin's approach and judge ASI to be an instrumentality of the parent and therefore taxable in the US through its parent.
The US could apply the test of management of control to companies operating there.
And finally the US could examine the cost-sharing agreement between Apple and ASI that transfers the global rights of the intellectual property to ASI. After all, another possible source of the value added is not the intellectual property but the R&D that resulted in the design of the products in the first place.
But it was Ireland that moved.
Will it make any differences to Apple's tax bills? Probably not. There are lots of provisions in the US tax code that will allow it to continue to defer its US taxes – the "check the box" provision, the "look-through" rule and the "same country" exemption will achieve the same result. Apple will have to adjust its tax strategy if it wants to maintain the zero rate that it achieved on the "stateless income" until repatriation but that can be achieved by shifting the profits to Bermuda where the rate of corporation tax is … … … zero.
The dance between companies and countries continues but there is no sign that the countries have cornered them. There are a lot of eyes on Pascal Saint Amans but apart from an increase in transparency it is still not clear what the OECD BEPS project will actually deliver. It will not be a shift to a destination-style system of corporation tax based on customers but some system of formulary apportionment is possible (though not in the near term). The dance will continue for a good while yet.
Yesterday's release of the Q4 arrears statistics had a stinger that potential mortally undermines the credibility of the figures. It appeared in the very first paragraph (emphasis mine).
The number of mortgage accounts for principal dwelling houses (PDH) in arrears, fell for the second consecutive quarter in Q4 2013. A total of 136,564 (17.9 per cent) of accounts were in arrears at end Q4 2013, a decline of 3.3 per cent relative to end-Q3, although the size of the decline was impacted by asset sales over the quarter.
In the Q3 figures there were 141,269 PDH accounts in arrears so the Q4 figures indicate a drop of around 4,700 in the number of accounts in arrears. That would be good news if it were true but the end of the paragraph tells us that "asset sales" impacted the size of the decline.
It turns out that a bank (well a former bank actually) sold mortgages and such sold mortgages are not reported for the purposes of the Central Bank's arrears statistics.
Lloyds Banking Group plc (the Group) announces today that it has agreed the sale of a portfolio of non-performing Irish retail mortgages (the Portfolio) to Tanager Limited, an entity affiliated with Apollo Global Management, LLC (NYSE:APO), for a cash consideration of £257 million. The transaction is part of the Group's continued non-core asset reduction programme.
The gross assets subject to the transaction are £610 million. The Portfolio generated losses of £33 million in the year to 31 December 2012. The sale proceeds will be used for general corporate purposes and the transaction, although capital accretive, is not expected to have a material impact on the Group, due to existing provisions taken against these assets.
The key points are the gross amount of the loans at £610 million (around €725 million @ €1 = £0.84), that they were sold at a discount of 58 per cent and, most crucially for our purposes here, that the loans were non-performing. In the Q3 mortgage arrears figure of 141,269 these non-performing loans were included; in the Q4 mortgage arrears figure of 136,564 they were excluded.
If we assume a (high) average mortgage account size of €250,000 then the sale would have involved around 3,000 accounts. These are non-performing which could relate high LTVs, borrower risks but probably means arrears and the loans could also be spread across PDH and BTL accounts.
Nearly two-thirds of the reduction in the number of PDH accounts in arrears could be because of this sale. This was the first time that such asset sales were mentioned in the Central Bank's arrears releases and it is only the Q4 2013 figures (so far) that have been affected by this.
The fact that sold mortgages are excluded from the Central Bank's arrears figures hugely undermines the value of the series. The assumption would have been, for me anyway, that the series included all mortgages that originated in Ireland. For example, when BOSI actually closed in Ireland back in December 2010 and transferred the servicing of its mortgages and other loans to Certus they remained in the CB's arrears statistics. There have also been a large amount of mortgages securitised in recent years and they remained in the statistics (though much of this was for self-held bonds).
Differences between the amounts covered in the Mortgage Arrears Statistics and the Credit, Money and Banking Statistics indicated that there was different coverage between the two, i.e. that the arrears statistics were at the level of the borrowers and the banking statistics and the level of the institutions. For example, Table 18 of the Credit, Money and Banking Statistics show that at the end of September 2013 Irish-Resident Credit Institutions had €95.5 billion of PDH mortgages (€63.9 billion on balance sheet from Table 18.1 and €31.5 billion securitised but serviced by them from Table 18.2). The Mortgages Arrears statistics cover €108.5 billion. This €13 billion difference cemented a view that the arrears statistics were more than just banking statistics, or at least were different.
If mortgages can be excluded from the Arrears Statistics just because they are sold it is not clear what value is in the series. It undermines future attempts to update analysis such as this which used the historical series (which was not affected by such asset sales) to assess the level of aggregate repayments being made on Irish mortgages. The problem of omitted mortgages will be further exacerbated by subsequent sales such as the impending sale of the INBS mortgage book and possible further sales by BOSI and maybe by Danske.
Unless the impact of these transactions is explicitly included in the arrears figures produced by the Central Bank it is likely it will be very difficult to tell anything from forthcoming releases. The Central Bank will know but will they tell us?
The labour market results from the Quarterly National Household Survey continue to be impressively positive. There is no doubt that this is a good thing, but the overall impact of the improvements remains uncertain. The employment gains are not be reflected in other data series: household disposable income, exchequer income tax returns, core retail sales etc.
In the standard discussion of recessions it is put forward that improvements in unemployment/employment lag behind a general upturn in the economy by two or more quarters. Ireland seems to be an unusual case where we are seeing employment improvements first.
The annual change in the number of people employed paints a very positive picture in recent quarters.
In percentage terms, employment is growing at close to rates, which unsurprisingly, have not been seen since 2006 and 2007. But overall conditions are not like they were then. Here are the annual percentage changes in total employment and aggregate wages received by households.
Employment growth has been positive in annual terms for more than a year. Growth in aggregate (nominal) wages remains absent, though the series only goes as far as Q3 2013 and recent data are subject to revision.
The pattern of household disposable income reflects the above changes in wages received. Here is the level of household disposable income for the past eight years. The point of note here is the absence of any notable upturn in 2013 (during which employment was growing).
Of course, even if aggregate wages were increasing the impact on disposable income would be offset by certain tax increases. However, if we are looking for labour market improvements it might be useful to just look at income tax. Cumulative income tax by month does not show any improvement in 2013 relative to 2012.
Finally, core retail sales could be used a positive affirmation of the labour market statistics. It is not much but a pattern of rising core retail sales since the spring of 2013 is discernible.
However, the increase is driven by volume (+2.7 per cent in the year to January) as opposed to value (+0.9 per cent on the year). We might be buying more but we are not really spending more (the motor trades excepted).
Of course, a drag on household spending continues to be the debt overhang that many households are carrying. The household sector continues to deleverage relatively rapidly.
Since peaking at nearly €204 billion at the end of 2008 the total loan liabilities had declined to €168 billion by the third quarter of 2013.
It would be useful to dig further into the QNHS figures but some re-classification problems mean that many of the sub-trend categories cannot be interpreted as actual changes. The CSO highlight this in relation to employment in the Agriculture, Food and Forestry sector (+26,800 but due more to statistical reclassifications than increased activity). This also has knock-on consequences for divisions into categories such as employee or self-employed, the patterns of which could be useful for explaining the wage, income and tax trends shown above.
So we are left with a position where labour market statistics are very positive – total employment up 3.3 per cent to the end of 2013 – but this is not reflected elsewhere. In nominal terms aggregate wages, income tax revenues, disposable income and consumption expenditure are all not doing much better than remaining static.
The increases in employment are undoubtedly positive but it is unusual that they are leading wage, income and consumption increases. It is not clear where these aggregates are currently heading but if the employment increases continue they will also start to rise. Surely?
There has been a lot of noise about the INBS mortgage book which is being sold as part of the liquidation of the IBRC. The last insight provided in the performance of these mortgages was in the IBRC Interim Report for June 2012. Page 72 contains this table on INBS's mortgages.
Only 41 per cent by loan amount are neither past due or impaired. For owner-occupied mortgages 48 per cent of loans were performing while for the buy-to-lets only 18 per cent of loans were performing. There is delinquency on a huge scale in the INBS mortgages.
Of the mortgages around 90 per cent were SVR loans with the remaining 10 per cent on fixed rates of various durations. INBS issued close to no tracker-rate mortgages (trackers make up less than 0.1 per cent of the mortgages).
Much has been made of the issue of whether the INBS mortgage holders will be protected by the provisions of the Mortgage Arrears Resolution Process (MARP). This is the IBRC MARP policy document.
the MARP will no longer apply" and the lender "may commence legal proceedings for repossession of the property immediately after classifying the borrower as not cooperating". The CCMA definition of "not co-operating" is below the fold.
It is not clear what responsibility the new owners have to comply with the CCMA/MARP but it is probably the case that very large number of INBS mortgage holders were not covered by the MARP provisions at the start of the IBRC liquidation to begin with.


Clients must fulfil a number of duties with respect to a project in the interests of guaranteeing the Health and Safety of everyone involved and affected by the planned works. For larger projects, you may already have appointed a Designer, as part of their duties under CDM they should have already briefed you with regard to the CDM Regulations.
There are two levels of application for the Construction (Design and Management) Regulations 2015 these are defined by a simple rule regarding how many contractors are involved in your project.
CDM 2015 has a threshold regarding how many contractors are involved in the planned works. Where a single contractor is undertaking all the works, there are slightly different rules than if there is 'more than one contractor' involved with the works.
A simple example of this is, if you were having the toilets upgraded at your workplace and you employ a plumber then this would class a single contractor project. If, however, you decided that the tiling in the toilets needed upgrading as well and employed a contractor to do this, you now have a plumber and a tiling contractor involved in the works, it is therefore a multi-contractor project and additional duties apply to your project.
Appoint the right people at the right time.
Ensure there are arrangements in place for managing and organising the project.
Provide information to your Designer and contractor.
Communicate with your Designer and building contractor.
Ensure adequate welfare facilities on site.
Ensure a construction phase plan is in place.
Keep the Health and Safety file.
Protecting members of the public, including your employees.
Ensure workplaces are designed correctly.
Notify the HSE of your project if it meets the threshold.
If you are still unsure please contact our CDM department today for free impartial guidance on your project or to look at the ways that we can help you fulfil your duties as a CDM Client.


Nigella's Jumbleberry Crumble is a great winter desserts. It's easy to make, and very versatile – we've made it with everything from apples to rhubarb to berries.
Lorraine, who is Not Quite Nigella, recently wrote about bargain-priced frozen blackberries for sale in nearby Marrickville, and I couldn't resist picking up a couple of bags ($4.50/kg!!). Our dessert was made with frozen blackberries, raspberries and blueberries.
This recipe makes more crumble topping than you actually need for this amount of fruit, so stash the extra in a ziplock bag in the freezer.
1. Preheat oven to 180C with fan.
2. Place the flour, baking powder and demerara sugar in a medium sized bowl and stir to combine. Cut the butter into small pieces, then rub it into the dry ingredients until crumbly (of course!).
3. Pour the frozen berries into the serving dish, and toss them with the cornflour and vanilla sugar. Top with about two-thirds of the crumble mix (although you really could use as little or as much as you like), then bake for approximately 30 minutes, or until the berries are just starting to ooze juice and the topping is brown and crunchy. You might need to turn the oven temperature up in the final 5 – 10 minutes to brown the top – resist the urge to do this too soon, or the topping will burn before the fruit is hot.
Serve with cream, icecream, or simply on its own (which is how I prefer it!).
It looks so yummy. The recipe seems easy and delicous! Can't wait to try it.
So disappointing that none of the family likes crumble – how can you not? I make it annually and then eat it all myself.
Actually, the French are mad for 'le crumble' – savoury versions too.
It's like time travel into the future visiting your blog :) Here the blackberries are just a thought as the flowers on the brambles are fading away now in readiness for August and fruit. That looks delicious though, just pop some over here would you?
I love the name of it, 'Jumbleberry'. Crumbles are great, and so versatile. In recent years my crumbles have morphed into more of a cobbler though. So easy and quick, when you want dessert now!
Is that a baby romertopf I see there before me?! hmmm?
I love the name 'jumbleberry' too!
delicious! look at all that sauce on the bottom, it's like two desserts in one!
Thank you all! It's really the nicest dessert – I'm going to make a big batch of crumble mix and stick it in the freezer now.
Tes, it really is sooo simple! And as Dana says, it's like two desserts in one – crumble and self-saucing pudding. My boys particularly like it with icecream.
Anna, I guess you'd call a savoury crumble a gratin? I took some up to P & E when we made this batch – used up the leftover crumble topping to make a second, smaller dish.
Jo, fresh blackberries are just stupidly priced here – sometimes $9 – $10/150g punnet IF you can find them. Which makes the frozen ones just so much of a bargain! Thanks for the headsup on the yoghurt too! And hopefully you and C and all the other UKers will get some proper summer weather soon!
Brydie, it's Nigella's name, but it is such a clever one. Apparently "jumbleberry jam" was a term used to describe a preserve made from all the bits and bobs left in the allotment at the end of the season.
What a fab looking oven dessert!! I so love to eat this served with hot devon custard,…oooh,…yes!!!!
I love the name as well. Are blackberries also called brambleberries? Or is that another fruit altogether?
I remember this recipe! I adore berries, I should pay a visit to that store too sometime!
In Canada, we called mixed berry desserts "bumbleberry," often used to make pies. And I have had people think it was some weird and wonderful kind of single fruit, until they saw the inside of a pie. Right now, however, strawberry-rhubarb is the pie de Jour since both are in season. Well, rhubarb is … most of the strawberries are still coming from California. With the strong Canadian dollar, they are quite inexpensive … as little as $1.50 a pound. Not as good as the local ones will be, of course.
Sophie, custard would be wonderful with this!
Gill, if you're just using rhubarb, I think you'd need more sugar. The blueberries were really sweet in ours.
Maria, thanks for stopping by – what a fabulous blog you have! Definitely worth a visit to Chef Express!
Local (Vancouver Island) strawberries will be quite pricey … but farmers have to make a living. Blueberries are grown commercially in the Vancouver area, on mainland B.C., and, in a good year, can be a good buy. Raspberries and cranberries are also big crops, with a lot going to the juice market and for frozen berries. U-pick farms are popular for berries, too, especially for smaller operations, given that it's hard to find agricultural workers. Organic fruit and veg is growing in demand and people are willing to pay the added cost. Becoming certified organic is expensive and time-consuming for farmers, so many farm organically without being certified and call their produce is organically grown or grown naturally. Eating "locally" is also a big deal with restaurants bragging of all the local product they use and people going on "100-mile diets" … eating only stuff coming from 100 miles or less away.
Our problem is climate – there aren't many places in Sydney really cold enough to grow berries en masse. Fresh raspberries and blueberries are often freighted in from interstate, and the prices reflect their delicacy and subsequent shipping problems. The organic/locavore movement here is gaining momentum here too, although our focus is mainly just to process as much of our food at home as possible. It takes a lot of commitment to eat purely organically, and more money than we have. We do try and eat only free range meat, although that's mostly driven by concern for the welfare of the animal.
Off topic question – I was just talking to my husband about this – do kids go to school in the summer in Australia, and then have "summer break" in the winter? That would be a total bummer.
Hi Celia – no- it was a crumble not a gratin. lMaybe a gratin is defined by just cheese and/or breadcrumbs? Have a look at this site.
I've had kumura crumble – no sugar in the topping but added pecans but I can't remember what it was served with!
I went out and bought Blackberries too! But I think I missed a section of the shop. I only went to the front section where the frozen fruit is. Is there are more to Chef's on Buckleys?


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text:
Man stabbed by teen in Surrey village road rage attack
Mike Mackenzie
A man was stabbed in a village road rage attack.
Surrey Police is appealing for help following the stabbing in Saxbys Lane, near to the junction of Haywardens, in Lingfield.
Police want to speak to this teenager in connection with a road rage attack in Lingfield. Picture: Surrey Police.
A spokesman said: "The victim was driving towards the village when a black Ford Galaxy driving in the opposite direction blocked the road and wanted the victim to mount the grass verge.
"After he declined to do so, a teenage boy exited the rear door of the Ford and stabbed the victim several times in the arm with a sharp metal implement through the driver's window.
"The occupants of the Ford left the scene in the direction of Lingfield station."
The attack happened between 3.18pm and 3.22pm on January 10.
The victim was driving towards Lingfield when a black Ford Galaxy driving in the opposite direction blocked the road, said Surrey Police. Picture: Surrey Police
The victim suffered two 1cm puncture wounds and was given medical help by a resident and an ambulance crew.
Investigating officer PC Megan Williams said: "This was an extreme reaction to road rage so we're appealing to the public to help identify the two women and teenage boy in this photo and e-fit.
"If you recognise these three, please call us as the victim sustained two stab wounds to his arm and needed medical attention."
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The female driver was white, in her mid-30s or 40s, of a large build with light brown, mid length hair.
The female passenger was white, in her 30s, average build and had long blonde hair. She spoke with a South London accent.
The teenage boy depicted in the e-fit was white, approximately 16 years old, around 5ft 7 inches tall, of average build with short, straight mousey brown or fair hair.
Anyone with information should contact Surrey Police on 101 (999 in an emergency) or http://surrey.police.uk/TellUsMore, quoting reference PR/45190003357.
You can also give information, 100% anonymously, to the independent charity Crimestoppers on 0800 555 111; or through their anonymous online form: https://crimestoppers-uk.org/.