The State of Hawai'i is grappling with its #1 industry. How does Hawaii create a framework for sustainable tourism? It is widely acknowledged that the islands are popular, and in some cases, they have become too popular. Over the last decade considerable growth in the number of flights and carriers into the state rendered impressive occupancy figures for the traditional lodging sector. As demand surged, the value driven consumer, equipped with a screen and keyboard, shopped for alternate accommodations. The net-effect was the securitization of what once was shelter and a shortage of permanent housing options across the state. In many cases, without verifying zoning ordinances, property owners opted to vacation rent their properties versus long term rent. The net effect is less permanent housing across the state.
Kauai County just released its Kauai Tourism Strategic Plan entitled Refocusing Tourism to Find Balance. Mayor Carvalho writes, "While this (tourism) has created a valuable economic sector for Kaua'i, tourism's success is straining the patience of residents and the island's environment and infrastructure. It is our kuleana, our responsibility, to continue to create a viable economy for our people while maintain all that makes Kaua'i unique and special." The intent is to achieve balance for the well-being of the island, its residents and visitors. As long as Hawai'i has a housing crisis, I anticipate that counties across the state will move to enforce zoning laws and restrict properties that are not vacation rental zoned from pursuing this use.
On Kaua'i, we see the supply of rentals and homes declining. With interest rates rising and 30 year conforming mortgages at +4.500%, buyers exhibit some angst. A recent search reflects just 5 homes for sale on Kaua'i with an asking price of $500,000 or less, 70 listings from $501,000 to $750,000 and 41 listings from $751,000 to $999,000. Reasonable alternatives to buying a home include building; yet with negative unemployment and a statewide boom in construction, architects and contractors can have long lead times. Meanwhile, long term rentals advertise at prices that reflect inflationary tendencies.
With no curbing of demand for housing in sight, I anticipate a strong conclusion to 2018. As of month-end September 2018, Kauai produced 987 closed transactions translating into sales volume of $883,000,000. Additionally, sales are up over 2017 by 7.52% with volume up by a staggering 33.25%.


Signaling ultimate reality and the spiritual meaning of all the Indian dharma, the OM necklace remains one of the most recognized symbols thought history. Each piece uses AAA handset stones along the face of the pendant to create its iconic look. Meanwhile, the 2.5mm, 26" stainless steel Franco chain provides the perfect pairing.


Talc Powder for Cosmetic Industry is a versatile ingredient used in a wide variety of cosmetic products and has many different uses. Talc is good at absorbing moisture and so is used in Body Powders (also known as talcum powder or baby powder). It is also good filler, so it is used in face and body powders to fill the tiny nooks and crannies on the skin surface, creating a soft, even feel. Cosmetic talc also functions as a very good base material for color cosmetics such as eye shadows and powder blushers. These are only a few of the ways in which this highly versatile ingredient is used in cosmetics.
We are engaged in offering a wide range of China Clay Powder. Our products increases the strength of the material in which it is mixed. We are proud to introduce ourselves as one of the prominent suppliers of these products in India. This range of product also called Hydrated Aluminium Silicate, which is widely used in plastics, rubber, detergent, paints, china ware and ceramic industry. These products are soft, earthy and white color mineral. Clients can avail these products as per their need.


text:
Home latest Linkedin social media LinkedIn Bring in Trending Storylines to Keep Users Interested
LinkedIn Bring in Trending Storylines to Keep Users Interested
It's hard to regard the social media race as, well, a race. Companies will try and best each other on different fronts, but as a whole, each one has a very different set of goals, to the point where none of them are directly competing. For LinkedIn at the moment, it's mainly about ensuring that their almost half-billion users stay interested.
While LinkedIn is the only viable job-hunting social media platform on the market, they have historically struggled to maintain a solid core of active users. For many people, it makes more sense to just completely disconnect job hunting and networking from the social media experience, and LinkedIn doesn't seem to offer much of a reason to rethink that ethos.
One of LinkedIn's earliest ploys to keep people on the platform was the in-house content - articles written and shared on LinkedIn and nowhere else, but now the allure of that is wearing off, and they've introduced something else - Trending Storylines. These are essentially clouds of related news stories, sourced both from outside and inside of LinkedIn. It's launching first in the US only, with just three categories to choose from - tech, finance and healthcare.
Rather than being arranged by algorithm, Trending Storylines will be curated by 24 living, breathing people. Machine learning gets involved after that, but only for rearranging the clusters depending on which users are viewing them - so basically no two people viewing the same cluster will necessarily see the same thing, it will depend on what they like, post and comment on in their daily activity.
LinkedIn have been trying to make content more personalised since they picked up the Pulse app back in 2013, and recently they completely revamped their desktop website, so this was likely in the works even before that, intended to follow shortly after the new coat of paint.
As well as lumping relevant topics together, new hashtags allow you to bounce between the different Storylines depending on which aspect of them you're most interested in. This bunny-hopping effect could make LinkedIn a far more viable platform for news browsing, which addresses their most significant problem - the amount of time people actually spend on there.
Tags: latest, Linkedin, social media

redpajama_set_name: RedPajamaCommonCrawl


How does one program a God?
Yikes, religion on the internet!
Ha, funny. I'm talking about god games, simulators that give you power over a worldspace or the creatures and elements within it, typically on a massive scale. It could include such features as mass terraforming, devastating 'miracles' that can be seen as good or bad depending on the target, development of said powers from simple to overwhelming, and maybe even helping supplicants and acolytes grow to the top of the pack.
I have very fond memories of Populous: The Beginning, one of the first god games I ever enjoyed. You start off with a shaman, the head honcho of the tribe through which miracles and spells are cast, and you wander the solar system gathering followers to increase your power and influence. If people won't join you (as they follow other gods and their shaman can unleash the same powers as you can), it's up to you to convert or destroy them. No peaceful coexistence in this universe. Your powers in this game ranged from summoning hordes of stinging insects to directing tornadoes to incinerating entire villages in fiery volcanoes. I'll never forget that at the end of the game, you finally have enough power as a god to do the spell casting yourself without a range limit, and the resulting destruction of your enemies is incredibly satisfying.
You know, I never understood how the 'swamp' spell meant instant death to anyone who walked through it. Invisible crocodiles? Fast-acting trench-foot? Psh, I dunno, but man, it made for an effective deterrent.
What a quaint village. Would be a shame if something… happened to it while the shaman is away.
I then played a game later in my childhood called Black and White, a game made by one of my favorite now-defunct studios, Lionhead Studios. Admittedly, I really couldn't get into this game. At all. Why in the world would an all-powerful god put so much time and effort into training a giant creature who, for all intents and purposes, does nothing but annoy your villagers, cause property damage, and poop everywhere? I'm sure they can be trained to not do that, as I have seen insisted on many a website touting the game as a masterpiece. I never got very far in the game because I couldn't figure out what to do with the leashes and my creature would inevitably go off and cause trouble, getting itself killed in the process (despite me nailing its super-extendo-leash to a tree near my village).
So, getting both good and bad as a kid, why do I believe that god games like Populous still haven't tapped an incredibly deep well of potential?
It's because of how broad of a subject 'god games' have become these days.
If you search on Steam under the tag 'god games', you're going to see a lot of different types of games, from RTS (like War for the Overworld) to sandbox games (Like Universe Sandbox) and even casual pixel games (like The Sandbox). Spore and its expansions are on this list, and while I could make a joke about a 'god game' featuring evolution, I'll skip it. They even have the gall to put in the glorified screensaver that is Mountain, and the philosophical Everything. Games that I would consider to truly be 'god games' (complete with the spiritual and mystical aspect, the miracles, and the followers) are often not well received, with the good ones showing up few and far between (good examples are Reus, which I plan on reviewing soon, and From Dust, which is an excellent game despite belonging to Ubisoft and their terrible Uplay system). I don't like this broad idea that if the game gives you complete control over your own little population or worldspace, it's automatically a 'god game'. If so, that makes Civilization or Endless Space 2 'god games'. It makes Planetary Annihilation a 'god game'. It makes The Sims a 'god game'.
These aren't 'god games'. Strategy, yes, but not 'god games'.
In From Dust, you play as a god. Ergo, this is a 'god game'.
But this doesn't mean 'god games' have to always be large-scale fire-and-brimstone destruction-fests. Let's shrink the concept of the all-powerful 'god game'. Imagine if The Sims were still all about the home-building and decorating, but you had no control over your sims in the slightest. What if they lived their own lives based on a list of their likes and dislikes, developed relationships with other sims all by themselves, and developed their skills without any input from you? Sounds boring? (As boring as Mountain? I digress.) Well, what if, as some malevolent or benevolent spirit or 'god', you could become the sim's conscience? What if you could 'train' your sims to take a unique path through their lives, being the angel (or devil) on their shoulder as they live day-to-day?
What if they could ignore you if you gave them a command that didn't match their 'code of ethics'? This could be for good or evil, as simple as influencing a child sim to disobey their parents or as complicated as attempting to persuade a burglar sim to give back his hard-earned loot. What if, through your subtle influence, you earned enough 'god points' to start influencing your sims in more supernatural ways, such as through dreams, through strange 'coincidences'… or perhaps through frightening 'bumps' in the night? These could give major bonuses towards future life goals, and grant convictions, changes of habit, or even phobias. What if your sim came into a choice that happened because of your influence that could change their course forever, maybe even other sims' life courses, and they didn't have the 'attributes' necessary to make the 'correct' choice, for good or ill?
What if you could drive your sim to become a shining beacon of humanity? Or drive them into an insane asylum after hearing self-destructive voices?
Yes, a wholesome modern family, with a spirit from the netherworld influencing their every thought and choice. Doesn't sound too far from the original game, to be honest.
Okay, maybe only I'm intrigued by this new Sims game. Maybe this sounds too similar to the actual game. Maybe it would give a programmer an aneurysm. But you have to admit, it's an interesting idea that giving the player less control over their subjects can simultaneously give them more in terms of results variation. This could lead to the possibility of more replayability because of unexpected and entertaining results. This isn't even talking about actual religious doctrine, although I suppose it could be seen that way. I see it as more of a balance between total player control (which is fun for a moment but doesn't last long) and a complete uncontrollable game of chance (which is fun until you don't win). And it's all about maintaining the fun factor.
In my opinion, 'god games' put a fine line of separation between the player and his subjects. In Populous, if you lose your shaman, you couldn't cast miracles until she respawned. In From Dust, you don't have a mystical 'hand of god' to save your subjects from floods of water and fire; you can issue simple commands, but you have to bend the elements to protect your followers and wait for them to brave the treacherous wilds themselves to reach relics and settlement beacons which strengthen your miracles. I think this is where Black and White went wrong for me: it put one too many lines in between the player and the population in the form of an annoying giant mascot. A good 'god game' will balance the influence the player has with the characters onscreen, not too separated that the player feels like they have absolutely no control, but enough that it doesn't become 'The Sims' where the player can control everything. You can 'simulate' being a god, but not every strategy game is a 'god game'.
Does that shrink the genre into obscurity? Maybe it does. But I think people want a 'god game' with this philosophy in mind, one with some element of choice and ethical dilemmas, but one with a fine line of separation that makes the game rewarding and challenging. Breaking my own rules, you can see how excited audiences were for the very recent release of Frostpunk, a game where you have to make life-or-death decisions for a population living in a steampunk arctic hell. I'm surprised that isn't a 'god game', according to Steam. (I want to review it as well, it looks ridiculously difficult.) I would love a 'god game' that limited your influence over a small isolated community to small 'miracles' that grew more powerful as faith in you increased. One where morality could go either way.
I'm ashamed of how much game time I have in Godus. Like all 'Molyneux Specials', I didn't know it by its reputation before I bought it.
I want to see another really good god game like Populous appear again. A more complex From Dust with enemy tribes and tough decisions to make, maybe. Different belief systems and powers related to them. A few of the other games under the 'god games' tag in Steam look intriguing enough to make me want to take a look, so maybe in the future, you'll see a god game review where I adjust my perceptions of the genre. Until then, I'll take any suggestions on how I can change my viewpoint, as I feel disappointed in my love for this very specific niche itch I can't scratch.


text:
Tim McGraw pays tribute to Lynn Anderson in the best way possible
Tim McGraw pays tribute to the late Lynn Anderson. Photo via YouTube
After news hit yesterday that Lynn Anderson had passed away, many stars paid tribute on Facebook and Twitter by revealing memories and expressing their feelings. Tim McGraw decided to pay tribute in another, more musical way by singing one of Anderson's biggest hits.
Usually before shows, Tim records a video of him and the band warming up. On Friday before their show in Cleveland, Ohio Tim decided to use the time to sing (I Never Promised You a) Rose Garden and dedicated to Lynn and her family.
Amazing. Check it out.
Lynn Anderson, Tim McGraw, tribute
PrevPreviousKip Moore covers Jimmy Eat World's "The Middle"…excuse us while we faint.
NextMan! Miranda Lambert Feels Like a Woman!Next
Zac Brown apologizes for drug bust and being at the wrong place at the wrong time
After news broke yesterday that Zac Brown Band lead singer Zac Brown was involved in a drug bust at a Florida hotel last week, many people were doubtful that the story was true since it was TMZ who first reported on it. Turns out, however, the story is true and Brown himself decided to address it by releasing a heartfelt apology on his band's website.
Only thing better than a Blake Shelton concert is a free Blake Shelton concert!
So that's what more than 60,000 people look like? Dayum. Guess putting on a FREE concert with Dan + Shay opening, a special guest named Danielle
Chart Roundup – Week of April 20th, 2013 (ACMs Special)
Post-ACMs a number of artists have had a bit of a sales boost this week. Florida Georgia Line are back at #1 with 'Cruise' long
Tyler Farr Walks Into a Bar
If you are going to have a single called "A Guy Walks Into a Bar" and said single goes to Number 1, there is really
Lindsay Ell Covers (and Slays) The Weeknd's "Can't Feel My Face" (Watch!)
Stoney Creek Records (Broken Bow Records) artist Lindsay Ell is perhaps best known in the industry for her incredible guitar-playing ability and bluesy voice that
Your first preview of Carrie Underwood performing the Sunday Night Football theme song
Finally! After months of waiting, fans of Carrie Underwood are finally getting their first taste of the superstar performing the 2013 Sunday Night Football theme
Tim McGraw's Daughter Finds Her Prince
Tim McGraw and Faith Hill are having a Twitter war and it's adorable
Tim McGraw messes up lyrics to own song thanks to Storme Warren…
Which Male Country Stars Are the Sexiest?
Tim McGraw & Faith Hill To Be Honored On Walk Of Fame


text:
Небесное озеро — название озёр:

 Небесное озеро — также Тиберкуль.
 Небесное озеро — также Чхонджи.

redpajama_set_name: RedPajamaWikipedia


TENGU [email protected] 400% Custom by Fakir Design!
Earlier this week, when we said to keep an eye out for more Fakir Design work coming in the near future (read HERE) we wasn't expecting another awesome 400% [email protected] custom but we'll take it because this one is waaaaaay better than the HYOTTOKO custom released on April 1st. In our humble opinion, of course.
TENGU is going to be released in limited numbers (five) on Monday 8th April. Priced at 700euro (about £603). You will be able to purchase from the Fakir store HERE on Monday. Each TENGU wears an authentic Japanese material kimono. TENGU stands at around 11inches tall.
Remember, you can find Fakir on Instagram HERE. And as we said before, keep your eye on more Fakir news in the future. We hear good things are coming your way!


Save the date and mark your calendar for Sunday, September 23rd and join me at Locust Grove in Poughkeepsie between 10am – 5pm for Hudson Valley Holistic Market's Embracing Autumn Spiritual and Metaphysical fair, sponsored by Askasha's Journey. I'll be there to personalize your copy of Discovering Angels. Admission is free!
Hope to see you on September 23rd. You may purchase a book from me at the fair or bring you're own from home for me to sign. Books can be purchased by going to barnesandnoble.com, amazon.com, or balboapress.com/bookstore.


YANTRAM STUDIO, flourished out as a Global Brand in the world of Imagination and designing. Our architectural outsourcing Company strongly represent our decade old arduous journey to become a top class renowned brand for 3D Building construction drawings & Design, an envy to every studio in the CGI world.
Since 2004 At our architecture visualisation Firm, we proudly offer 3D Architectural (Exterior, Floor Plan - Interactive 3D Floor Plan , Rendering Images Walkthrough Animation) 3D Interior Design , Virtual Reality Application Development (Interactive Virtual Tour), Augmented Reality Apps Development , Corporate Animated Video Production , Movie and Game Character Modeling and Animation, 360 Degree Panoramic Tour and Product Modeling & Animation. We take pride in offering the highest quality of Architectural / Entertainment Industry.
Our Exterior Designer Artist is expert in all type of exterior Design like Hotels, Resort, Buildings and residential Properties.
Our Firm Interior Designer Artist is expert in all type of Interior Design like Home, Hotel, Resort, Malls and Offices.
We provide high quality dynamic 3D Virtual Walkthrough and 3D walk-through animation for all verticals of projects.
Our firm believes in the emotional and commercial focal point of client's decision of buying or investing any real estate property.
Yantram served the 3D Services where visualization required!
601 cross timbers road Flower mound,Texas, 75028, USA.


PITTSBURGH, Nov. 6, 2018 – PPG (NYSE:PPG) today announced that it will exhibit its full range of advanced coatings, ink and specialty material solutions for printed and flexible electronics at the IDTechEx Show at the Santa Clara Convention Center in California, Nov. 14-15.
PPG will feature its entire array of conductive inks and coatings, as well as microwave absorber materials and PPG TESLIN® substrate, which is a synthetic paper technology that is used globally for commercial printing and specialty applications that require a tough, high-performance material.
As the world leader in providing electromagnetic interference (EMI)/RFI shielding and electrostatic discharge solutions, PPG will display the conductive coatings it supplies to many of the world's most recognized consumer electronic, medical device and aerospace companies. Typical applications include desktop and laptop computers, mobile phones, entertainment and gaming systems, wireless modem systems, medical devices, and aircraft frame and rotor blade systems.
To learn more, visit PPG at IDTechEx booth P27 or log on to www.ppgindustrialcoatings.com, www.teslin.com or www.cumingmicrowave.com.


text:
Muslim separatists blamed for 'China's 9/11' rail station massacre which saw 29 people hacked to death by armed men and women
Authorities claim Muslim Uighur community of Xinjiang responsible
Experts claim they have been marginalised by President Xi Jinping
Police today questioned every Uighur in Kunming - a few dozen people
Believed to be 10 attackers - four shot by police, one detained, five missing
By Mia De Graaf
Published: 15:18 EDT, 3 March 2014 | Updated: 17:35 EDT, 3 March 2014
Muslim separatists from far-west China have been blamed for the brutal murder of 29 people in a frenzied knife attacked that left 143 others critically wounded.
The killers launched the horrific slaughter at Kunming railway station in Yunnan province at around 9pm local time on Saturday.
It is believed that more than 10 people took part in the attack. Four were shot by armed police, one was taken alive, and the rest are still being hunted.
Today armed police patrolled the streets as members of the Uighur community were questioned
Panic: Police are urgently questioning all Uighur Muslims in Kunming after the attack that left 143 injured
CCTV shows there to have been 10 masked attackers randomly knifing bystanders in Kunming station
Their identities have not been confirmed, but evidence at the scene showed that it was carried out by Uighir Muslims, native to far-west Xinjiang, 900 miles away, local media claim.
Since President Xi Jinping was elected in 2009, Xinjiang has been simmering rebellion against Chinese rule by some members of the Uighur population.
Shock and mourning as China absorbs the full horror of... Chinese authorities say two WOMEN were part of...
In a desperate bid to make sense of the attack, police rounded up every member of Kunming's small Uighur community - a few dozen people - for questioning.
'How do we know them?' said a Uighur man who gave only his first name, Akpar. 'We could not tell if the assailants were Uighurs as they were all dressed in black. We did not like the attack either.'
Most attacks blamed on Uighur separatists take place in Xinjiang, where clashes between Uighurs and police or the Han majority are frequent.
But Saturday's assault happened more than 900 miles to the southeast in Yunnan, which has no recent history of unrest.
Residents, mainly of the Han ethnic majority, have called for the Uighur minority to be driven out of Yunnan
Lighting candles for the 29 dead, Kunming residents said they were scared to go out at night
If correct, it would be the deadliest violence attributed to Uighur-Han conflicts since the 2009 riots in Xinjiang capital Urumqi, when Uighurs stormed the streets randomly slaying women and children. Han mobs responded, and nearly 200 people died.
One Kunming resident, Jiang Hua, said the attack has made people scared to go out at night and Uighurs should be banished.
'I think we should chase off the Uighurs and let them be independent,' Jiang said. 'And local authorities should be held accountable for providing public safety.'
However, one man paying tribute, restaurant worker Xie Yulong, expressed sympathy toward ethnic Uighurs.
He said the attackers were 'worse than animals', but added that the Uighur region has come under severe security crackdowns in recent months under the government of President Xi Jinping.
'It's the pressure,' Xie said. 'Beijing has put too much pressure on them since Xi Jinping took over. They are under so much pressure they do not want to live, and they did that.'
Police chief and head of the government's central commission for political affairs Meng Jianzhu visited the wounded on Sunday and was given an update by Kunming officers on their investigation
Crackdown: He said the terrorists will be 'severely punished' to prevent similar cases in the future
Distressing photos circulating online showed bodies, pools of blood and abandoned luggage scattered across the terminal floor in the wake of what authorities termed an 'organised, premeditated, violent terrorist attack'.
According to CCTV, the Chinese state broadcaster, at least two of the attackers were female.
One was killed by police and the other was the woman who was captured. She has been taken to hospital for treatment.
'All-out efforts should be made to treat the injured people, severely punish terrorists according to the law, and prevent the occurrence of similar cases,' said China's chief police official, Meng Jianzhu, who unusually travelled on a Sunday to visit the scene - an indication of how seriously authorities viewed the attack.
Yesterday, residents flooded the province's hospitals to donate blood for the wounded.
Others took to the streets with candles, calling on the authorities to clamp down on the Uighur community.
Muslim separatists blamed for China Kunming knife attack


text:
Q: Inverse function theorem and its applications Let the space of all matrices over $\mathbb R$ of size $ n^2 $ , with the natural metric of $\mathbb R^{n^2 }$.

Prove that there exist a neighborhood of the identity matrix, such that all the matrices in that ball have a square root, i.e
  $$
\exists \varepsilon  > 0\,:\forall X \in B\left( {I,\varepsilon } \right)\,\,\exists \,Y:\,Y^2  = X .
$$
Hint: Consider the function $ F(X) = X^2 $ and use the Inverse Function Theorem

Help with this problem !! )=

A: You want to solve the equation $(I+X)^2=I+Y$ for the $(n\times n)$-matrix $X$ when $Y$ is a given matrix near $0$. This amounts to
$$Z(X):=2X+X^2\ =\ Y\ ,\qquad (*)$$
an equation in the $n^2$ unknowns $X_{ik}$. When $Y=0$ then $X=0$ is a solution of this equation. According to the assumptions of the implicit function theorem we have to check whether the $(n^2\times n^2)$-matrix
$$J:=\Bigl({\partial(Z_{11},Z_{12},\ldots,Z_{nn})\over
\partial(X_{11},X_{12},\ldots,X_{nn})}\Bigl)_{X=0}$$
is regular. As $Z_{ik}=2 X_{ik} +$ terms of degree $2$ in the $X_{ik}$, the matrix $J$ is $2$ times the $n^2\times n^2$ identity matrix; so it is certainly regular. It follows that the equation $(*)$ has a solution $X=F(Y)$ such that $F(0)=0$ and $F(\cdot)$ is a differentiable matrix valued function of (the matrix elements of) $Y$.
By the way, the square root $I+X$ of $I+Y$ for  $\|Y\|<1$ is given by the binomial series
$$\sum_{k=0}^\infty\ {1/2 \choose k}\ Y^k\ .$$

redpajama_set_name: RedPajamaStackExchange


Seriously, this is almost obscenely delicious. I've had a couple of versions of it around town and the other day suddenly felt the urge to try it myself… and of course MY version is the best! 😉 It's super easy, especially if you have a sous-chef to peel the langostines for you. Serve hot with some fresh crusty bread.


text:
Port lotniczy Lizbona-Portela
 Liga i Samoobrona
 system informacji o terenie -
 LIS (język programowania)


How did the Wall Street Journal make $2 billion on a mailing that didn't change for 25 years?
Storytelling is a powerful technique that is rooted in the history of human psychology. In today's world, it is more important than ever for companies to understand when and why they are telling a story.
Banishing the misconception that long-copy simply makes a story, Andy Maslen, author of Persuasive Copywriting, describes the main ingredients for powerful storytelling, from the protagonist and narrative to the solution, to ensure your copy engages with customers and encourages them to act.


Israeli Prime Minister Ariel Sharon said on Saturday he would not meet with French Foreign Minister Dominique de Villepin as Israeli forces raided a West Bank Palestinian refugee camp.
Sharon's decision came a day after the French foreign ministry announced that de Villepin would meet Palestinian President, Yasser Arafat.
Israel and its US ally have adopted a policy of bypassing Arafat and accusing him of fomenting violence.
De Villepin will visit the Occupied Territories and Israel this weekend to hold talks with Palestinian and Israeli officials on the internationally backed "road map" plan for peace in the Middle East.
On Friday, Sharon said he was ready to back the plan and seek his cabinet's approval in exchange for an American commitment to address Israel's reservations regarding the plan.
A senior State Department official said Saturday that the US promise to deal with Israeli concerns did not necessarily mean it would agree with Israel on every point.
Palestinians back the plan, which was drafted by the United States, European Union, United Nations and Russia. The "road map" calls for the establishment of a Palestinian state by 2005.
The French foreign minister is scheduled to meet his Israeli counterpart, Silvan Shalom, on Sunday. The following day, he will meet Arafat, Palestinian Prime Minister, Mahmoud Abbas and Palestinian Foreign Minister, Nabil Shaath, in the West Bank town of Ram Allah.
De Villepin's visit comes as Israeli incursions to the areas in the Occupied Territories continued.
Around 50 Israeli armoured vehicles attacked the Tulkarem West Bank Palestinian refugee camp on Saturday.
Israeli soldiers conducted house-to-house searches for resistance fighters and imposed a curfew, witnesses said. The occupation forces also took control of buildings in the neighbouring town of Thannaba, turning them into barricades.
The army said it wanted to destroy what it called the camp's "terrorist infrastructure". Israeli forces have repeatedly made incursions into Tulkarem's camp during the past two years.
There were no immediate reports of clashes or casualties in the raid that began at dawn.
In the Gaza Strip, a Palestinian was shot dead by Israeli soldiers, who claimed that he was armed and trying to slip into Israel from the Gaza Strip, Israel's army radio said.
Aljazeera correspondent reported that Israeli forces opened fire from heavy machine guns and launched missiles on the Abu Safiya district, east of Beit Lahiya in Gaza.
As a result, farms in eastern Gaza were damaged as well as a Palestinian security site.


text:
Early New Zealand Settlers
Carlukes history is revealed in numerous stories here on our website, but equally our grandparents were seeking their fortunes in Canada, Australia and New Zealand. We will be expanding on the fortunes of William Brownlee in the Marlborough region of New Zeland in another story but first, here is the tale of the first settlers in the Rai Valley just miles from where Carluke, NZ would eventually be settled. The story is taken up, with kind permission, by Don Donovan of Auckland.
The Rai Valley Cottage, Carluke
This sturdy pioneers' cottage in the Rai Valley, between Blenheim and Nelson, is in remarkably good condition not only because it was well built in the first place but also because it has been carefully looked after by volunteers and the Historic Places Trust in recent years.
It was built by Charles and Arthur Turner, the first settlers in the valley, in 1881, and was occupied by Charles and his wife Matilda and their children for the next twenty-five years. They lived remotely for the first four of those years until the coach road from Nelson was formed, and one can only imagine the hard times they must have endured, the constant danger from injury, the lack of medical help, the absence of easy communication.
Apart from a corrugated iron chimney, the cottage was entirely made of local materials: split Totara slabs for the walls and roof shingles, and round stones from the local riverbed to support the chimney. Charles would spend weekdays working as a bushman in Pelorus Valley – a fair distance away even by horse - while Matilda and the children worked at undergrowth clearing around the house. Eventually they cleared enough to fell the bush
and establish a cattle farm and so succeeded through the diligence and faith that marked those courageous pioneer families.
They were also well known for their hospitality and welcomed passers by. Indeed a diary note by one of the children recorded a hardly believable 500 visitors in 1894 alone!
Various additions were made to the cottage as time passed: a separate cookhouse and bakery, dairy, milking shed and a 'bloke's shed' to where Charles could escape to play his violin. (Which might also have been a relief for the family!)
A settlement of about 100 developed nearby, with a school and sawmill founded by William Brownlee. It was named Carluke after Brownlee's birthplace in Scotland.
Read more stories from the Places section
Law Hospital (the next story in sucession)
A History of Education
Carluke Market Place
Hamilton Clock History
Hillhead Cottage


Editor's note: As preachers develop their signature method of sermon preparation over the years, they often enhance their process by "cherry picking" from the sermon prep schedules and checklists of others. When someone preaches in a way that consistently intrigues and speaks to us, and we wonder how they do it, the answer may well be found in those schedules and checklists.
PreachingToday.com: Are there any key questions you normally answer, or paths of thought you typically take, as you study a text and write the sermon?
What are the big ideas in the text?
Am I preaching from a natural unit of Scripture?
What is this text about? What is it saying about what it's about?
Why did the original audience need to hear this message?
What question is this text answering? And what is its answer?
What does this text say about Jesus? Have I stayed in this text until I met the Lord of this text?
What is the good news of this text?
How is this passage supposed to make me feel?
Very insightful information. I had the opportunity to hear Bryan Loritts during the EK Bailey Preaching conference a week ago. Great expositor!
The article was very helpful , I appreciated the bottom line approach!


We exist to make Mendoza College of Business the hub for ethical leaders that can drive human centric innovations in the tech industry; to build a vibrant community of people with interest in high-tech; to provide networking opportunities with students from other schools and professionals; to support and facilitate recruiting efforts of students and companies; and to raising awareness of technology and trends.
Our members accept internships and full-time positions in various roles—marketing, finance, product management, business development, and general management—at both well-established and emerging tech firms.
ND MBA candidates at Salesforce office as a part of Bay Area Trek. Oct, 2017.


text:
Here Are the First Week Numbers Projections for 'Tha Carter V'
ByTara Mahadevan
Chicago-based journalist // @mhdvn
Image via Getty/Erika Goldring
Tha Carter V finally dropped this week, to much fanfare—and its anticipation can be directly seen in album sales projections.
According to Hits Daily Double, Lil Wayne's long-delayed album is set to move 475,000 to 525,000 units during its first week, which amounts to about 165,000 to 180,000 in pure sales. This projection solidly places him at the top of the Billboard 200—and if the numbers pan out, he'll have the third largest opening week of the year, after Drake and Travis Scott.
Weezy's last album, 2013's I Am Not a Human Being II moved about 217,000 copies in its first week, while Tha Carter IV sold an incredible 964,000 in 2011, per MTV.
For Lil Wayne fans, Tha Carter V almost became a false promise, as Weezy endured a few tumultuous years of lawsuits. In June, after a long legal battle, Wayne finally settled his lawsuit with Birdman and Cash Money Records for a confidential amount. Wayne's attorney Ron Sweeney said in a statement, "I can say that my client is happy. He is his own man, a man that owns his assets, his music and himself. At some point, Wayne will let his fans know what's going to happen next."
Drake and Post Malone Were Supposed to Appear on Lil Wayne's "What About Me" Track
Birdman and Young Thug Under Criminal Investigation Over 2015 Lil Wayne Tour Bus Shooting
6 Takeaways From Lil Wayne's 'Tha Carter V'
NewsLil WayneAlbumsTha Carter Valbum salesprojections


Kate Carlisle. (2015). Ripped From the Pages. Penguin Publishing Group.
Kate Carlisle. 2015. Ripped From the Pages. Penguin Publishing Group.
Kate Carlisle, Ripped From the Pages. Penguin Publishing Group, 2015.
Kate Carlisle. Ripped From the Pages. Penguin Publishing Group, 2015. Web.
Excited to explore the secrets of wine country, Brooklyn attends an excavation of the caves hidden deep under her parents' commune—and the findings are explosive. A room is unearthed, and it contains a treasure trove of artwork, rare books, a chest of jewelry...and a perfectly mummified body.
A closer examination of the murdered man's possessions reveals a valuable first edition of Jules Verne's A Journey to the Center of the Earth. Hidden in the book is a secret map that unveils an even greater hoard of treasures brought to California by French winemakers fleeing the Nazi invasion with the commune leader's grandfather, Anton, among them.
While Brooklyn has temporarily relocated to her parents' place in Sonoma, she attends an excavation of the caves hidden deep under their commune. A room is unearthed, revealing artwork, rare books, cases of wine, a chest of jewelry...and a perfectly mummified body. A closer examination of the murdered man's possessions reveals a valuable first edition of Jules Verne's A Journey to the Center of the Earth containing a secret treasure map.


text:
Find fun and friendliness on a family holiday in Fiji
Fiji Family Holidays
Fiji Family Holidays 2021/2022
Idyllic islands, calm lagoons, swaying palm trees and fun activities for all ages set the scene for one of the most magical family holidays you will ever take! But Fiji promises so much more than perfect paradise islands... it's the people of Fiji who will win your hearts and stay with your forever. Considered one of the happiest and friendliest nations on the planet, Fijians welcome you and your tribe with open arms and wide smiles. With their heartfelt warmth and genuine friendliness and compassion, Fijians make you feel instantly relaxed and 'at home'... only this is better than home, because not many of us are lucky enough to have such awe-inspiring natural beauty on our doorstep!
We'll admit that the 333 islands in Fiji are two long-haul flights away from the runway at Heathrow, but we hand-on-heart promise the journey is worth it! Consider spending a night or two enroute to the South Pacific in sunny Santa Monica or in the bright lights of Singapore or Hong Kong to break the journey, stretch the legs and throw an extra element of family adventure into the mix! Once you're in Fiji, we recommend mixing at least two regions to get a deeper understanding of the islands and to maximise the variety of experiences for young and old.
Fiji family holiday highlights
For some families, having the option of an all-inclusive family holiday can help remove the stresses of added costs during your adventure. Fiji has resorts which offer all-inclusive packages, so it's great to have this option for families in such a remote location. Having said that, locals are warm and friendly and if you fancy wandering traditional villages, then lunch at a local restaurant is a great idea, too.
Choice of hotels
As it's a far-flung destination in the South Pacific, Fiji is often mistaken as primarily a destination for couples or honeymooners. However, there's actually a wealth of choice when it comes to family-friendly island resorts in Fiji. Whether you'd like to do tree planting and kids' yoga at Six Senses Fiji, while a team of seven staff at Taveuni Palms Resort means you need not lift a finger during your family holiday and you can go swimming with manta rays at Paradise Cove. For the best Fiji resort for toddlers, then Kokomo Island Resort is the ultimate escape, with personal nannies available and a fantastic kids' club.
Kid-friendly activities
Children won't be bored in Fiji, that's for sure. Family-friendly resorts in Fiji have some of the best kids' clubs across the South Pacific, while the things to do in this island nation for kids are limitless. There's marine adventures in the form of snorkelling and swimming with gentle giants like manta rays, while wonderful walks through the jungle really bring your child's learning of the rainforest in school to life. If your youngsters are energetic, Pacific Harbour offers family activities like zip-lining and kayaking, while we're also sure children will be captivated on visits to local villages.
Our top family resorts in Fiji
Less than an hour's drive south of Nadi by private transfer, the InterContinental Fiji Golf Resort & Spa sits on a beautiful stretch of beach and is perfectly positioned to enjoy the activities in Sigatoka Valley, such as a jetboat safari and a memorable ride along the rails with Ecotrax. Further along the Coral Coast, Fiji's adventure capital - Pacific Harbour - is home to a multitude of activities with varying adrenalin levels, from white-water rafting and zip-lining to sea kayaking and waterfall treks. A fantastic base for all these activities, as well as being a superb luxury retreat for families to relax and reconnect, Nanuku Auberge Resort offers over 20 on-site activities and has its own private island for a family picnic to remember!
When paradise island life beckons, head to one of our firm family favourites, Vomo Island, in the picture-postcard Mamanucas, where little ones can get used to the underwater world on a 'Bubble Blowers Course' and have fun with their Baby Butler, whilst mum and dad enjoy the adults-only pool and Rocks Bar at the tip of the island. Another family gem is Six Senses Fiji, the barefoot luxury brand's first South Pacific resort, where kids yoga, tree planting and pizza making go hand-in-hand with an abundance of family activities both on and off the sparkling lagoon.
Further north, the Yasawa Islands feature dazzling white sand beaches and gentle, lapping lagoons... perfect for little ones to splash about in and an ideal spot for older kids to try scuba diving! Nestled in the heart of the Yasawas, Paradise Cove is a haven for families, with an array of accommodation choices from beachfront villas to your own beach house. Intrepid families can explore the Sawa-i-Lau Caves and even swim with graceful manta rays from May to October.
Fiji's northern islands are a verdant wonderland, where waterfall hikes and hidden beaches reveal a wilder side of Fiji, and where the heavenly Taveuni Palms Resort promises new-found levels of service and memorable family time thanks to the team of seven private staff catering to your every need!
For the crème de la crème of Fiji family retreats, Kokomo Island Resort to the south of the mainland in the far-flung Kadavu archipelago, and Laucala Island in Fiji's north near Taveuni, both offer unsurpassable luxury twinned with a sense of place and truly outstanding service alongside world-class diving.
Here's a suggested family itinerary exploring the breathtaking Yasawas followed by plenty of adventure in Pacific Harbour. Chat to our team of experts and let us create a tailormade journey you and your family.
Discover a Fijian family adventure
Top family resorts in Fiji
Please Select Mr Mrs Miss Ms Mstr Prof Dr Lady
Please provide a value for Title
Forename *
Surname * Last Name...
Please provide a value for Surname
Please provide a value for Email Address
Please provide a valid value for Email Address
Please provide a value for Contact Number
Holiday Enquiry Information *
Please provide a value for Holiday Enquiry Information
Approximate Travel Dates *
Please provide a value for Approximate Travel Dates
Interested In * Destination Name
Please provide a value for Interested In
Blog/Website Brochure Conde Naste Traveller Daily Telegraph Don't know Friends and Family Google search Guides for Brides House and Garden Referral Repeat Client Saturday Times Sheerluxe Show/Event Social Media Sunday Telegraph Sunday Times Wedding Show You and Your Wedding Other
Please provide a value for How did you hear about us?
I would like to be added to the mailing list. Privacy is paramount at the Turquoise Holiday Company, we will never pass any of your details onto anyone else.
Fiji family holiday FAQ
Where are the islands of Fiji located?
Fiji is an archipelago of 333 islands in the South Pacific Ocean, found to the east of Australia and to the north of New Zealand. The three largest islands are Viti Levu, Vanua Levu and Taveuni, while there are also several smaller island groups, including the Yasawas and the Mamanucas.
What is there to do in Fiji for families?
There's lot of fun activities for children! Lots of the resorts have brilliant kids' clubs to keep youngsters of all ages entertained. Beyond the resorts, kids will have fantastic fun discovering the wonderful waterworlds that lie in the turquoise lagoons beyond the beach. We're sure their eyes will be widened by the rainbow-coloured reefs and myriad marine creatures they discover while snorkelling! Depending on where you are in Fiji, there's wild walks to waterfalls like the Waitavala Natural Waterslide, the zip-lining and kayaking adventures of Pacific Harbour and interesting village visits.
What is the best island in Fiji for families?
There isn't really a wrong answer to this question! Everyhwere in Fiji offers something a little bit different which children will love. Obviously, the zip-lining, kayaking and rafting fun you can have at Pacific Harbour is a big draw and the family-friendly Nanuku Auberge Resort lies close by, too. If you want to be whisked off to somewhere truly remote as a family, then the beautiful beaches and tropical islands of the Yasawas is a great option. Paradise Cove is a affordable but brilliant base if you want the unforgettable chance to swim with manta rays, as well as a number of other water sports. We also love Kokomo Island Resort, which is the ultimate family escape. There are personal nannies for your young ones if you'd like them, fantastic opportunities for diving on the Great Astrolabe Reef and an incredible kids' club.
Is Fiji safe for families to visit?
Yes! Fiji is one of the happiest and friendliest nations on the planet, so we'd argue your children couldn't be anywhere safer. There's a real family culture in Fiji, so locals and those who work in your resort will be great with your children. They'll make you feel at home instantly, so your little ones will feel comfortable right from the start of your holiday.
How much does a family holiday to Fiji cost?
A family holiday to Fiji starts from around £10,500 per family, which includes two adults and two children, for a seven-night holiday including flights and with daily breakfast. This can rise, depending on your duration, the resort you choose and the board basis you stay on.
Does my family need any vaccinations to visit Fiji?
No vaccinations are currently recommended, although Fiji is deemed to have a risk of the Zika virus. If you're entering Fiji from a Yellow Fever zone, possession of a valid Yellow Fever inoculation certificate is required. For any current travel health advice, you should seek guidance from your GP at least four to six weeks prior to travel.
Does my family need a visa to visit Fiji?
British passport holders don't need a visa to visit Fiji.
How long does the flight take to Fiji from the UK?
Flights to Fiji operate regularly from London via Los Angeles. Alternatively, Fiji may be reached via Hong Kong, Tokyo, Singapore or San Francisco. Total flying time is approximately 26 hours via the west and 24 hours if travelling via the east. Ask your consultant about stopping over in LA, San Francisco or Southeast Asia to break the journey and enjoy city life en route to Fiji. New Zealand and Australia are also excellent destinations to twin with Fiji.
Specailists
Meet our Fiji family specialists
Fiji family inspiration
Head to our blog CANVAS for more inspiration, insider secrets and diaries from our team on Fiji.
Head to CANVAS


text:
Macao SAR Government Portal
Administrative and legal affairs
Public safety and migration
Entrepreneurship and business
Notary and registry
Tourism and gambling
Chief Executive, Principal Officials, Legislature and Judiciary
Policy Consultation
Policy Address
About Macao SAR
Macao Law Portal
LegisMac
MSAR Legislation
Multilateral treaties
Events & Festivities
Macao Exhibition and Conference
SMEs' Business Opportunities and Services
Public Servants Website
Discussions on developments in Cuiheng New District
The seminar on the developments to adequately diversify the economy of Macao held in Zhongshan.
A seminar was held in Zhongshan to study the planning of the Cuiheng New District and developments to adequately diversify the economy of Macao. Organised by Guangdong authorities and the Macao Polytechnic Institute, the seminar was attended by academics from Beijing, Guangzhou and Macao, and representatives of the Macao Government: they discussed issues on the framework agreement for the development of the Cuiheng New District in Zhongshan and the first meeting last month of the Taskforce for the Promotion of Zhongshan-Macao Co-operation. At the seminar, held on 10 March, the group discussed the positioning of the Guangdong-Macao co-operation display zone, measures to combine Zhongshan's geographic advantages and experience in light industry with Macao's "One country, two systems", platform and management experience, and to bring more opportunities to small- and medium-sized enterprises and young people. In the long run, the governments should make best use of the country's strategic development and the development of Guangdong and Macao. Representing the Macao Government at the seminar were the head of the committee for the strategic development of Guangdong and Macao, Consultant of the Chief Executive's Office Mr Kou Chin Hung; and the deputy head of the committee, Mr Yang Daokuang.
Previous: Consumer Council released its latest 'Supermarket price survey' Surveyed spots included over 10 supermarkets in Santo António Parish
Next: Cultural Affairs Bureau publishes "The Cuisine of Macao From My Grandfather's House"
NEWS-1-2-58516
The Secretary for Economy and Finance, Mr Lei Wai Nong, attends a plenary session of the Legislative Assembly, which holds a second reading and a vote on a bill of tax incentive scheme for science, technology and innovation business.
The Secretary for Security, Mr Wong Sio Chak, attends a press conference on a public consultation regarding a legal regulation on the management of dangerous goods.
Officials of the Infrastructure Development Office open tender documents for the construction of road network on the periphery of the starting and ending points of the fourth Macao-Taipa bridge – Avenida Wai Long connection.
The Secretary for Social Affairs and Culture, Ms Ao Ieong U, attends a ceremony to mark the signing of a cooperation agreement between the University of Macau's Centre for Constitutional Law and Basic Law Studies and an association for the promotion of the Macao Basic Law (Associação de Divulgação da Lei Básica de Macau).
The Chief Executive, Mr Ho Iat Seng, attends a Spring Festival reception hosted by the Liaison Office of the Central People's Government in the Macao SAR.
The Secretary for Social Affairs and Culture, Ms Ao Ieong U, represents the Chief Executive at the opening ceremony for the celebration and open day events to mark the 40th anniversary of the University of Macau
The Chief Executive, Mr Ho Iat Seng, meets with Deputy Secretary of the CPC Guangdong Provincial Committee and the Secretary of the CPC Shenzhen Municipal Committee, Mr Wang Weizhong, in Shenzhen during the four-day Guangdong-Hong Kong-Macao Greater Bay Area tour.
The Chief Executive, Mr Ho Iat Seng, visits a base in Shenzhen of an information and communications technology company, before returning to Macao on completion of the four-day Guangdong-Hong Kong-Macao Greater Bay Area tour.
The Chief Executive, Mr Ho Iat Seng, visits Shenzhen Stock Exchange while in that city for the four-day Guangdong-Hong Kong-Macao Greater Bay Area tour.
The Chief Executive, Mr Ho Iat Seng, arrives in Shenzhen and visits an Internet-based platform company.
Help us improve GOV.MO
What went wrong *
GOV.MO
All information on this site is based on the official language of the Macao Special Administrative Region. The English version is the translation from the Chinese originals and is provided for reference only. If you find that some of the contents do not have an English version, please refer to the Traditional Chinese or Portuguese versions.
Site footer links
Co-ordinating Organization : Public Administration and Civil Service Bureau


text:
← Marital Deduction Planning
2010 Tax Outlook →
Asset Sales to Grantor Trusts: Antidote to New Estate Tax?
Posted on June 25, 2010 by David L. Silverman, J.D., LL.M. (Taxation)
PDF: Sales of Assets to Defective Grantor Trusts
Asset sales to grantor trusts exploit income tax provisions enacted to prevent income shifting by capitalizing on different definitions of "transfer" for transfer and income tax purposes. The objective of the sale is to effectuate a complete transfer for transfer tax purposes, but not for income tax purposes. Since no transfer occurs for income tax purposes, no income tax gain is recognized by the grantor on the sale. Despite this, the grantor has made a complete transfer for gift and estate tax purposes. In the past, some have referred to the resulting trust as "defective". However, the tax consequences of the sale are firmly grounded in federal tax law, and the use of asset sales to grantor trusts can effectively leverage the applicable exclusion amount for gift and estate tax purposes especially in prevailing low-interest rate environment.
II. Overview of Asset Sale
For income tax purposes, following an asset sale, the grantor trust holds property the income from which the grantor continues to report. However, the grantor is no longer considered as owning the asset for transfer tax purposes. Therefore, trust assets, as well as the appreciation thereon, will be removed from the grantor's estate
For as long as grantor trust status continues, trust income is taxed to the grantor. A corollary of the grantor trust rules would logically provide that no taxable event occurs on the sale of assets to the grantor trust because the grantor has presumably made a sale to himself of trust assets.4 If this hypothesis is correct, the grantor can sell appreciated assets to the grantor trust, effect a complete transfer and freeze for estate tax purposes, and yet trigger no capital gains tax on the transfer of the appreciated business into the trust.
Illustration. Assume the grantor sells property worth $5 million to a trust in exchange for a $5 million promissory note, the terms of which provide for interest payable over 20 years, and a balloon payment of principal when the note terminates. If the trust is drafted so that the grantor retains certain powers, income will continue to be taxed to the grantor, even though for transfer tax purposes the grantor will be considered to have parted with the property.
The result of the sale to the grantor trust is that the income tax liability of the profits generated by the business remains the legal responsibility of the grantor, while at the same time the grantor has parted with ownership of the business for transfer tax purposes. A "freeze" of the estate tax value has been achieved, since future appreciation in the business will be outside of the grantor's taxable estate. Nonetheless, the grantor will remain liable for the income tax liabilities of the business, and no distributions will be required from the trust to pay income taxes on business profits. This will result in accelerated growth of trust assets.3
Illustration. Assume grantor sells a family business worth $5 million to the trust, and that each year the business generates approximately $100,000 in profit. Assume further that the trust is the owner of the business for transfer tax purposes.2 With the grantor trust in place, the grantor will pay income tax on the $100,000 of yearly income earned by the business. If the business had instead been given outright to the children, they would have been required to pay income taxes on the profits of the business.
Grantor Trust Provisions
In Internal Revenue Code
Achieving grantor trust status requires careful drafting of the trust agreement so that certain powers are retained by the grantor. The following powers, if retained over trust property, will result in the IDT being treated as a grantor trust:
¶ IRC § 677(a) treats the grantor as the owner of any portion of the income of a trust if the trust provides that income may be distributed to the grantor's spouse without the approval or consent of an adverse party;
¶ IRC § 675(3) treats the grantor as owner of any portion of a trust in which the grantor possesses the power to borrow from the trust without adequate interest or security;
¶ IRC § 674(a) treats the grantor as owner of any portion of a trust over which the grantor or a nonadverse party retains the power to control beneficial enjoyment of the trust or income of the trust. [Sec. 674(a) is subject to many exceptions; for example, the power to allocate income by a nonadverse trustee, if such power were limited by an ascertainable standard, would not result in the trust being taxed as a grantor trust]; and
¶ IRC § 675(4)(C) provides that if the grantor or another person is given the power, exercisable in a nonfiduciary capacity and without the approval or consent of another, to substitute assets of equal value for trust assets, grantor trust status will result.
Caution. The objective is for the grantor to part with as many incidents of ownership as are required to effectuate a transfer for transfer tax purposes, while retaining enough powers to prevent a transfer for income tax purposes. Therefore, it is not necessarily advisable to include more powers than necessary to accomplish grantor trust treatment for income tax purposes, since the cumulative effect of retaining many powers which cause the trust to be a grantor trust for income tax purposes could also result in rendering the transfer incomplete for transfer tax purposes as well, entirely defeating the purpose of the sale. IRC § 675(4)(C), which provides that the grantor may in an nonfiduciary capacity substitute assets of equal value, should not result in an incomplete gift.
IV. The Note Received For Assets
Consideration received by the grantor in exchange for assets sold to the trust may be either cash or a note. If a business is sold to the trust, it is unlikely that the business would have sufficient liquid assets to satisfy the sales price. Furthermore, paying cash would tend to defeat the purpose of the trust, which is to reduce the size of the grantor's estate. Therefore, the most practical consideration would be a promissory note payable over a fairly long term, perhaps 20 years, with interest-only payments in the early years, and a balloon payment of principal at the end.5 This arrangement would also minimize the value of the business that "leaks" back into the grantor's estate. For business reasons, and also to underscore the bona fides of the arrangement, the grantor could require the trust to secure the promissory note by pledging the trust assets. The note should permit prepayment, which can be of benefit if the parties wish to terminate the transaction earlier, or in the event the assets fall in value, in which case the parties could renegotiate the term of the Note.
If there is insufficient cash flow to make payments on the Note, resort will have to be made to payments in kind. However, payments in kind conflict with the grantor's objective in selling assets to the trust to remove them from his estate. Payments in kind could also require costly valuations.
Caution. Although balloon payments may be desirable from a cash flow standpoint, periodic payments of principal and interest would imbue the note with a greater degree of commercial reasonableness. Provided the other terms of the note are commercially reasonable, the provision for a balloon payment of principal should not be problematic. However, the more the terms of the note deviate from those of a commercial loan, and the higher the debt to equity ratio, the greater the chance the IRS will assert that the debt is actually disguised equity. In this case, the IRS could argue that inclusion in the grantor's estate should result from IRC §2036.
If the value of the assets sold to the trust decreases significantly, the trust may seek to renegotiate the interest rate if the AFR has decreased since the date of the sale of assets to the trust. Alternatively, the grantor could sell the note, at a discounted value, to another grantor trust. However, to the extent renegotiation is not feasible, wealth will be transferred back into the grantor's estate.
The note issued in exchange for the assets must bear interest at a rate determined under § 7872, which references the applicable federal rate (AFR) under §1274.6 In contrast, a qualified annuity interest such as a GRAT must bear interest at a rate equal to 120 percent of the AFR. A consequence of this disparity is that property transferred to a GRAT must appreciate at a greater rate than property held by an IDT to achieve comparable transfer tax savings. As with a GRAT, if the assets fail to appreciate at the rate provided for in the note, the IDT would be required to "subsidize" payments by invading the principal of the trust.
While no taxable event occurs when the grantor sells assets to the trust in exchange for the note, if grantor trust status were to terminate during the term of the note, the trust would no longer be taxed as a grantor trust. This would result in immediate gain recognition to the grantor, who would be required to pay tax on the unrealized appreciation of the assets previously sold to the trust. Note that for purposes of calculating realized gain, the trust will be required substitute the grantor's basis.
Even though the assets were "purchased" by the trust, no cost basis under § 1012 is allowed since no gain will have been recognized by the trust in the earlier asset sale. Another situation where gain will be triggered is where the trust sells appreciated trust assets to an outsider. One way of mitigating this possibility is for the grantor to avoid selling low-basis assets to the trust. If this is not possible, the grantor may substitute higher basis assets of equal value during the term of the trust, if the trust is drafted to permit the grantor to substitute assets of equal value.
Care should be exercised in selling highly appreciated assets to the grantor trust for another reason as well. If the grantor dies during the trust term, the note will be included in the grantor's estate at fair market value. However, assets sold to the trust will not receive the benefit of a step-up in basis pursuant to § 1014(a).
Solution to Basis Problem. To avoid this result, the trust might either (i) authorize the grantor to substitute higher basis assets of equal value during his lifetime; or (ii) make payments on the note with appreciated assets.
If the grantor receives appreciated assets in payment of the note, those assets will be included in the grantor's estate, if not disposed of earlier. However, they would at least be entitled to a step-up in basis in the grantor's estate pursuant to § 1014.
What if Assets Decline in Value?
What happens if the assets in the trust decline in value so that the payments under the note can no longer be made?
Renegotiate Note. One option is for the trustee and grantor to renegotiate the terms of the Note, perhaps by lengthening the term and decreasing the interest rate. It is possible that the IRS would assert that a gift had been made in this situation.
Sell Note to Another Trust. Another option would be to sell the note to another grantor trust whose beneficiaries are the same. Since the purchase price would be lower, there is more of a chance that future appreciation would be shifted to family members.
Cancel the Note. Finally, the grantor could extinguish the Note in exchange for the return of the assets sold to the trust. This approach might violate the fiduciary obligations of the Trustee.
V. Avoiding Sections 2036 and 2702
IRC § 2702. The rules of Chapter 14 must also be considered. If § 2702 were to apply to the sale of assets to a grantor trust, then the entire value of the property so transferred could constitute a taxable gift. However, it appears those rules do not apply, primarily because of the nature of the promissory note issued by the trust. The note is governed by its own terms, not by the terms of the trust. The holder in due course of the promissory note is free to assign or alienate the note, regardless of the terms of the trust, which may contain spendthrift provisions. Ltr.Ruls 9436006 and 9535026 held that neither § 2701 nor § 2702 applies to the IDT promissory note sale, provided (i) there are no facts present which would tend to indicate that the promissory notes would not be paid according to their terms; (ii) the trust's ability to pay the loans is not in doubt; and (iii) the notes are not subsequently determined to constitute equity rather than debt.
IRC § 2036. As noted above, since the assets are being transferred to the grantor trust in a bona fide sale, those assets should be excluded from the grantor's estate. However, since the grantor is receiving a promissory note in exchange for the assets, the IRS could take the position that under IRC § 2036, the grantor has retained an interest in the assets which require inclusion of those assets in the grantor's estate.7 In order to minimize the chance of the IRS successfully invoking this argument, the trust should be funded in advance with assets worth at least 10 percent as much as the assets which are to be sold to the trust in exchange for the promissory note.8
In meeting the 10 percent threshold, the grantor should himself make a gift of these assets so that following the sale, the grantor will own all trust assets. The IRS stated in PLR 9515039 that IRC § 2036 could be avoided if beneficiaries were to act as guarantors of payment of the promissory note.9 To enhance the bona fides of the note, all trust assets should be pledged toward its repayment. To emphasize the arm's length nature of the asset sale, it is preferable that the grantor not be the trustee.
The grantor should be circumspect in employing guarantees. If the assets decline in value, the guarantee could result in wealth being retransferred to the grantor, which result is the opposite of the objective. In addition, the guarantee will be liability of the guarantor, and will be required to be shown on the guarantor's balance sheet.
Payment of trust income by the grantor is a desirable feature of sales of assets to grantor trusts, since trust assets continue to grow without imposition of income tax. The payment by the grantor of the income tax liability of the grantor trust can be considered a gift-tax free gift of the income tax liability by the grantor to the trust.
Although beneficial from an estate planning perspective, the grantor may at times not wish to pay the income tax liability of the trust. The trust instrument may authorize, but not require, the Trustee to reimburse the grantor for income tax payments made by the grantor. In that case, inclusion under IRC §2036 should not result. However, if there is even an implied understanding that the grantor will be reimbursed for the income tax payments, it is the IRS position that inclusion in the grantor's estate under §2036 will result. Rev. Rul. 2004-64.
If the grantor is cash-short, he may borrow money from the trust to pay income taxes, if the trust so permits. Recall that under IRC § 675(3), a provision in the trust allowing the grantor to borrow money from the trust without adequate security is a provision which actually causes the trust to be a grantor trust.
VI. GST Tax Considerations
The sale of assets to a grantor trust has particularly favorable Generation Skipping Transfer (GST) tax consequences. Since the initial transfer of assets to the grantor trust is a complete transfer for estate tax purposes, there would be no possibility that the assets could later be included in the grantor's estate. The transfer would be defined as one not occurring during the "estate tax inclusion period" (ETIP). Accordingly, the GST tax exemption could be allocated at the time of the sale of the assets to the grantor trust11.
In sharp contrast, the GST exemption may not be allocated until after the term of a GRAT has expired.12 If the grantor of a GRAT were to die before the expiration of the trust term, all of the assets in the GRAT would be included in the grantor's estate at their appreciated value. This would require the allocation of a greater portion of the GST exemption to shield against the GST tax. The inability to allocate the GST exemption using a GRAT is quite disadvantageous when compared to the IDT, where the exemption can be allocated immediately after the sale, and all post-sale appreciation can be protected from GST tax.
VII. Choice of Trustee
Trustee designations should also be considered. Ideally, the grantor should not be the trustee of an IDT, as this would risk inclusion in the grantor's estate. If discretion to make distributions to the grantor is vested in a trustee other than the grantor, then the risk of adverse estate tax consequences is reduced. The risk is reduced still further if the grantor is given no right to receive even discretionary distributions from the trust. If the grantor insists on being the trustee of the IDT, then the grantor's powers should be limited to administrative powers, such as the power to allocate receipts and disbursements between income and principal. The grantor may also retain the power to distribute income or principal to trust beneficiaries, provided the power is limited by a definite external standard.
The grantor as trustee should not retain the right to use trust assets to satisfy his legal support obligations, as this would result in inclusion under §2036. However, if the power to satisfy the grantor's support obligations with trust assets is within the discretion of an independent trustee, inclusion in the grantor's estate should not result. However, if the grantor retains the right to replace the trustee, then the trustee may not be independent, and inclusion could result. Note that despite the numerous prohibitions against the grantor being named trustee, the grantor's spouse may be named a beneficiary or trustee of the trust without risking inclusion in the grantor's estate.10
The trust instrument should dispense with the typical requirement that the Trustee be required to diversify the investments of the trust.
VIII. Death of Grantor
The following events occur upon the death of the grantor: (i) the trust loses its grantor trust status; and (ii) presumably, assets in the trust would be treated as passing from the grantor to the (now irrevocable) trust without a sale, in much the same fashion that assets pass from a revocable living trust to beneficiaries. The basis of trust assets would not be stepped-up under §1014(a) on the death of the grantor, nor would the assets be included in the grantor's estate. In contrast to the problem arising with a GRAT when the grantor dies before the expiration of the trust term, trust assets will never be included in the grantor's estate, although the discounted value of the note will.
The tax consequences of the unpaid balance of the note must also be considered when the grantor dies. Since the asset sale is ignored for income tax purposes, the balance due on the note would not constitute income in respect of a decedent (IRD). The remaining balance of the note would be included in the estate and would acquire a basis equal to that value.13
Some authorities believe that if the grantor dies while the note is outstanding, the estate could realize capital gain to the extent that the debt exceeds the basis of the trust in the assets.
It may be possible to avoid inclusion of the note in the seller's estate if a self-canceling installment note (SCIN) feature is included . A SCIN is an installment note which terminates on the seller's death. Any amounts payable to the seller would are cancelled at death, and are excluded from the seller's estate. However, use of a SCIN requires that the payments under the note be increased to avoid a deemed gift at the outset.
As a result of the increased payments, if the seller does survive the full term of the note, the amount payable to the seller from the trust utilizing the SCIN will be greater than if a promissory note without a SCIN were used. This would tend to increase the seller's taxable estate.
An existing Promissory Note can be renegotiated to include a SCIN, provided the grantor is not terminally ill (i.e., not a 50% probability that grantor will die within 1 year). As noted, the inclusion of the SCIN will require an additional premium, determined actuarially.
In addition to not suffering from the same problems occasioned by the early death of the grantor as would be the case with a GRAT, the asset sale technique also accomplishes a true estate freeze by transferring assets at present value from his estate without being subject to the limitations imposed by IRC §§ 2701 or 2702, to which the GRAT is subject. As noted, the GST exemption may be allocated to the assets passing to the trust at the outset, thus removing from GST tax any appreciation in the assets as well. In these respects, sales to grantor trusts are superior to the GRAT. The principal disadvantages are that (i) no step-up in basis is received at the death of the grantor for assets held by the trust (or if the trust sells appreciated assets during its term); and (ii) the technique, though sound, has no explicit statutory basis, as does the GRAT.
IX. Possible IRS Objections
The general principles governing the tax consequences of the asset sale seem firmly grounded in the Code and the law, and their straightforward application appears to result in the tax conclusions which have been discussed. Nevertheless, the IRS could challenge various parts of the transaction, which if successful, could negate the tax benefits sought. In particular, the IRS could attempt to assert that (i) the sale by the grantor to the trust does not constitute a bona fide sale; (ii) § 2036 applies, with the result that the entire value of the trust is includible in the grantor's estate; (iii) the initial asset "sale" is actually a taxable sale which results in immediate tax to the grantor under IRC § 1001; or (iv) that § 2702 applies, the annuity is not qualified, and a taxable gift occurs at the outset.
The IRS has recently interposed the step transaction doctrine in situations where limited liability companies were formed shortly before the sale to the grantor trust. In view of this, it is advisable to permit the limited liability company (or partnership) to "age" prior to transferring the asset to the trust.
Although the sale to a grantor trust is not a gift, the grantor may wish to file a gift tax return solely for the purpose of commencing the statute of limitations. If this route is taken, the transaction should be disclosed on the return. Often, the transaction will be disclosed in any event by reason of the grantor's gift of "seed" money to the trust.
X. Sale of Discounted
Assets to Grantor Trust
By combining the LLC form with asset sales to grantor trusts, it may be possible to achieve even more significant estate and income tax savings. LLC membership interests are entitled to minority and marketability discounts since the interests are subject to significant restrictions on transfer and management. If the value of the LLC membership interest transferred to the trust is discounted for lack of marketability and lack of control, the value of that interest will be less than a proportionate part of the underlying assets. Consequently, in the case of an asset sale to the trust, the sale price will be less than if the assets had been directly sold to the trust.
Step 1. Parent forms an LLC with two children. Parent is Managing Member. Members each contribute $10,000 in exchange for a 33 percent interest in the LLC. Parent may give children the money to purchase their interests.
Step 2. Parent transfers real estate worth $1 million to the LLC. Parent's capital account is now $1.01 million, and Parent now owns 99.7 percent of all membership interests in the LLC;
Step 3. In determining the fair market value of the LLC membership interest to be sold by parent to the trust, parent engages the services of a real estate appraiser and a professional valuation discount appraiser. A copy of the LLC operating agreement (containing restrictions which depress value of membership interests). The valuation discount appraiser determines that the membership interests should be discounted by 30 percent after application of the lack of control and lack of marketability discounts.
Step 4. Parent decides to sell a 90 percent membership interest to the trust. Before doing so, parent makes a taxable gift of $90,000 (10 percent of the value of interests to be sold to the newly formed grantor trust). The children are the only beneficiaries of the trust. The gift reduces parent's available lifetime gift tax exclusion from $1 million to $0.91 million. The following year, a federal gift tax return is filed reporting the gift of "seed" money to the trust.
Step 5. Parent sells a 90 percent membership interest to the trust in exchange for a 10-year promissory note whose principal amount is $630,000, which bears interest at 4.47 percent pursuant to IRC § 1274 (the long-term AFR for May, 2010) and which calls for a balloon payment of principal at the end of the 10-year term of the Note;
The discounted value of the note is determined by the following formula:
Value of Note =
Value of undiscounted interest sold x (1 – discount)
Solving the equation:
Value of Note = $900,000 x (1 – .3)
= $900,000 x 0.7
= $630,000
The required yearly interest payments under the Promissory Note are $28,162. No income tax consequences attach on payments from the trust to the grantor, since they are considered to be the same taxpayer for income tax purposes.
Step 6. If the real estate appreciates at a yearly rate of 10 percent, the FMV of trust assets will increase by $90,000 in year one; ($900,000 x 0.10). The grantor will report and pay tax on trust's distributive share of income reported by the LLC. The payment by the grantor of the income tax liability of the trust will result in trust assets continuing to appreciate without the imposition of income tax on trust assets. The grantor trust provides that the trustee has discretion to reimburse the grantor for income tax payments made. No income tax consequences attach to the reimbursement by the trust to the grantor of income tax. [
[Had the membership interests not been discounted, the trust would have paid of $900,000, and the yearly interest would have been $40,230 (i.e., $900,000 x .0447). By discounting the property purchased by the trust, the required interest payment to parent was reduced from $40,230 to $28,162.]
If the underlying assets grow at a rate of 10 percent, then 68.71 percent of the growth ($61,838/90,000) will remain in the trust. If the trust had been required to pay income tax, the rate of growth of trust assets would be significantly lower.
Step 7. The LLC asset sale to the IDT will result in the following favorable tax and economic consequences: (i) $900,000 is transferred out of the grantor's estate; (ii) the value of the note is included in the grantor's estate if the grantor dies during the term of the note; (iii) future appreciation of the asset sold is transferred out of the estate; (iv) unlike the situation obtaining with a GRAT, the favorable tax result does not depend on the grantor surviving the trust term; (v) since the note could bears a lower rate of interest than a GRAT, fewer funds would be brought back into the grantor's estate, resulting in a more perfect "freeze" for estate tax purposes; (vi) since the LLC assets are discounted, the purchase price by the trust reflects that discount, making the effective yield of assets within the LLC even higher; (vii) the sale does not occur during an estate tax inclusion period (ETIP), meaning that GST exemption can be allocated initially, before the trust assets increase in value; and (viii) while no basis step up occurs at the grantor's death; however, this problem can be ameliorated by substituting assets with a higher basis during the grantor's life.
1. A grantor trust is a trust defined in Secs. 671 through 679 of the Code. To be taxed as a grantor trust, the grantor must reserve certain powers, the mere reservation of which in the trust instrument will confer grantor trust status, unless and until those powers are released.
2. IRC Secs. 2036 and 2038, which cause the retention of interests or powers to result in estate inclusion must be avoided when funding an IDT. The retention by a grantor-trustee of administrative powers, such as the power to invest and the power to allocate receipts and disbursements between income and principal will not result in inclusion, and will not negate the transfer for transfer tax purposes, provided the powers are not overbroad and are subject to judicially enforceable limitations. See Old Colony Trust Co., 423 F2d 601 (CA-1, 1970).
3. The IRS has indicated displeasure with the payment of income taxes by the grantor of a grantor trust when the grantor receives no distributions. However, as the payment of taxes by the grantor is mandated by the grantor trust provisions themselves, it is doubtful that the IRS would prevail on this issue were it to litigate.
4. The IRS takes the position that a wholly grantor trust is disregarded for income tax purposes, and that transactions between the trust and the grantor have no income tax consequences. Rev. Rul. 85-13, 1985-1, C.B. 184.
5. Treas. Reg. § 25.2702-3 prohibits this type of "end loading" with respect to a GRAT. That regulation provides that an amount payable from a GRAT cannot exceed 120 percent of the amount paid during the preceding year. However, if § 2702 does not apply to the IDT, which appears likely, then the promissory note could provide for a large principal payment at the conclusion of the term of the note.
6. A promissory note given in exchange for property must bear interest at the rate prescribed by § 1274. Sec. 1274(d) provides that a promissory note with a term of between two and ten years should bear interest at the federal midterm rate.
7. Fidelity-Philadelphia Trust Co. v. Smith, 356 U.S. 274 (1958), held that where a decedent, not in contemplation of death, transfers property in exchange for a promise to make periodic payments to the transferor, those payments are not chargeable to the transferred property, but rather constitute a personal obligation of the transferee. Accordingly, the property itself is not includible in the transferor's estate under § 2036(a)(1).
In an analogous situation, § 2701 requires that the value of common stock, or a "junior equity interest," comprise at least 10 percent of the total value of all equity interests.
9. Presumably, if the beneficiaries were to guarantee the note and if the value of the assets which secure the note were to decline, there would still be a realistic prospect of the note being repaid.
10. Sec. 677(a), which treats the grantor as owner of any portion of a trust whose income may be distributed to the grantor or the grantor's spouse, has no analog in the estate tax sections of the Internal Revenue Code.
11. Sec. 2642(f) prohibits allocation of any portion of the Generation Skipping Transfer tax exemption to a transfer during any estate tax inclusion period (ETIP). Sec. 2642(f)(3) defines ETIP as any period during which the value of transferred property would be included in the transferor's estate if the transferor were to die.
12. The period during which the grantor receives annuity payments from a GRAT is an ETIP. Therefore, no part of the GST exemption may be applied to the GRAT until after its term; at that point, the property inside the GRAT will have appreciated, requiring a greater allocation of the GST exemption.
13. Some argue that a sale occurs immediately before the death of the grantor, causing capital gain to be recognized by the grantor's estate to the extent the balance due on the note exceeds the seller's basis in the assets sold to the trust. This view is inconsistent however, with the central premise that the sale by the grantor of assets to the IDT produces no taxable event.
This entry was posted in Asset Sales to Grantor Trusts, Estate Planning and tagged asset protection, asset protection trusts, asset sales to trusts, estate planning, gift tax, grantor trusts, gross estate, idgts, surviving spouse, tax appeals tribunal, trusts. Bookmark the permalink.
Information Desk Cancel reply
Calculation of Federal Estate Tax Liability (October 1996)


Feel good about the items in your home with these ethically made products.
Your shower routine just got much easier.
Dress up your space for the season with these affordable finds—all ringing in at under $100 but packing a seriously luxe punch.
Give your little ones the ideal place to sleep, play, and boost their creativity with these whimsical accessories.
Don't run out of lights! Find out how many feet and strings of Christmas lights you need to decorate your tree.
A cluttered shelf can be an eyesore, but a curated, coordinated one can be its own work of art. There's a reason #shelfie has been used almost 1.3 million times on Instagram—a well-organized bookshelf, cosmetic cabinet, or display case is gorgeous and attainable, and it doesn't cost a fortune to create.
Update any room in a flash with these illuminating options.


In expensive personal computers, user friendly software and the world of graphic design is your oyster. So in the spirit of everyone is a designer, builder, artist and even photographer we developed this stationery suite for Sydney based photographer Karl Schwerdtfeger.
We followed the typical design process, establishing brief, working through responses, working out the look and feel, establishing the elements and then the realisation is left up to Karl. Welcome to the world of "D.I.Y. brands".
The simple act of playing is often taken for granted by people.


Receive FREE Shipping on your order when you spend $75.00 or more. Enter Coupon Code "FS310" at checkout. Coupon code cannot combined with other codes. Free shipping only applies for domestic US addresses, and does not qualify for oversized packages or orders requiring special handling fees like Class 9 shipping.
0 Reviews for "Free Shipping Code – Purchases $75.00 or More"


text:
// Copyright 2018 The Chromium Authors. All rights reserved.
// Use of this source code is governed by a BSD-style license that can be
// found in the LICENSE file.

#include "ash/system/unified/top_shortcut_button.h"

#include "ash/style/ash_color_provider.h"
#include "ash/style/default_color_constants.h"
#include "ash/system/tray/tray_popup_utils.h"
#include "ash/system/unified/unified_system_tray_view.h"
#include "ui/base/l10n/l10n_util.h"
#include "ui/gfx/canvas.h"
#include "ui/gfx/paint_vector_icon.h"
#include "ui/views/animation/flood_fill_ink_drop_ripple.h"
#include "ui/views/animation/ink_drop_highlight.h"
#include "ui/views/animation/ink_drop_impl.h"
#include "ui/views/animation/ink_drop_mask.h"
#include "ui/views/controls/highlight_path_generator.h"
#include "ui/views/view_class_properties.h"

namespace ash {

TopShortcutButton::TopShortcutButton(const gfx::VectorIcon& icon,
                                     int accessible_name_id)
    : TopShortcutButton(nullptr /* listener */, accessible_name_id) {
  SetImage(views::Button::STATE_DISABLED,
           gfx::CreateVectorIcon(
               icon, kTrayTopShortcutButtonIconSize,
               AshColorProvider::Get()->GetContentLayerColor(
                   AshColorProvider::ContentLayerType::kIconPrimary,
                   AshColorProvider::AshColorMode::kDark)));
  SetEnabled(false);

  focus_ring()->SetColor(UnifiedSystemTrayView::GetFocusRingColor());
}

TopShortcutButton::TopShortcutButton(views::ButtonListener* listener,
                                     const gfx::VectorIcon& icon,
                                     int accessible_name_id)
    : TopShortcutButton(listener, accessible_name_id) {
  const SkColor icon_color = AshColorProvider::Get()->GetContentLayerColor(
      AshColorProvider::ContentLayerType::kIconPrimary,
      AshColorProvider::AshColorMode::kDark);
  SetImage(
      views::Button::STATE_NORMAL,
      gfx::CreateVectorIcon(icon, kTrayTopShortcutButtonIconSize, icon_color));
  SetImage(
      views::Button::STATE_DISABLED,
      gfx::CreateVectorIcon(icon, kTrayTopShortcutButtonIconSize,
                            AshColorProvider::GetDisabledColor(icon_color)));

  focus_ring()->SetColor(UnifiedSystemTrayView::GetFocusRingColor());
}

TopShortcutButton::TopShortcutButton(views::ButtonListener* listener,
                                     int accessible_name_id)
    : views::ImageButton(listener) {
  SetImageHorizontalAlignment(ALIGN_CENTER);
  SetImageVerticalAlignment(ALIGN_MIDDLE);
  if (accessible_name_id)
    SetTooltipText(l10n_util::GetStringUTF16(accessible_name_id));

  TrayPopupUtils::ConfigureTrayPopupButton(this);

  views::InstallCircleHighlightPathGenerator(this);

  focus_ring()->SetColor(UnifiedSystemTrayView::GetFocusRingColor());
}

TopShortcutButton::~TopShortcutButton() = default;

gfx::Size TopShortcutButton::CalculatePreferredSize() const {
  return gfx::Size(kTrayItemSize, kTrayItemSize);
}

void TopShortcutButton::PaintButtonContents(gfx::Canvas* canvas) {
  cc::PaintFlags flags;
  flags.setAntiAlias(true);
  flags.setColor(AshColorProvider::Get()->DeprecatedGetControlsLayerColor(
      AshColorProvider::ControlsLayerType::kInactiveControlBackground,
      kUnifiedMenuButtonColor));
  flags.setStyle(cc::PaintFlags::kFill_Style);
  canvas->DrawPath(views::GetHighlightPath(this), flags);

  views::ImageButton::PaintButtonContents(canvas);
}

std::unique_ptr<views::InkDrop> TopShortcutButton::CreateInkDrop() {
  return TrayPopupUtils::CreateInkDrop(this);
}

std::unique_ptr<views::InkDropRipple> TopShortcutButton::CreateInkDropRipple()
    const {
  return TrayPopupUtils::CreateInkDropRipple(
      TrayPopupInkDropStyle::FILL_BOUNDS, this,
      GetInkDropCenterBasedOnLastEvent(),
      UnifiedSystemTrayView::GetBackgroundColor());
}

std::unique_ptr<views::InkDropHighlight>
TopShortcutButton::CreateInkDropHighlight() const {
  return TrayPopupUtils::CreateInkDropHighlight(
      TrayPopupInkDropStyle::FILL_BOUNDS, this,
      UnifiedSystemTrayView::GetBackgroundColor());
}

const char* TopShortcutButton::GetClassName() const {
  return "TopShortcutButton";
}

}  // namespace ash

redpajama_set_name: RedPajamaGithub


text:
Lady Macbeth argumentative essay
FAIR IS FOUL, FOUL IS FAIR In the tragedy, Macbeth by William Shakespeare, the paradoxical theme of "Fair is foul, foul is fair" functions throughout the play. The line is a prophecy which means one thing seems like another. It implies especially to the characters that they are not as they seem to be.
The Three Witches are the ones who introduce the paradox that runs throughout the play. As this paper develops it will cover more on the different types of deceptions and how it plays an important role in Act 1.The different types of deceptions that will be discussed in this essay are deception of atmosphere, deception of Macbeth and the deception of witches.
In Macbeth, one of the things that was deceptive was the atmosphere. In Act 1, the atmosphere created by the author was very horrifying. The play sets the scene with a mysterious gathering of the three witches. The witches appeared suddenly in the mid-conversation, which was dramatic and created unclear ideas about the dubious topics of conversation. This in turn created an air of tension, suspicion and an ominous atmosphere.The presence of thunder and lightning was a symbol of evil and created a more hostile atmosphere.
This suggested that the rest of the play would be full of deceit, revenge, anger and pain, implying the play would be a tragedy. Later on the witches planned to meet Macbeth in the play on the heath. Antithesis was used in the ultimate stanza, where the witches chant a warning: Fair is foul, and foul is fair, Hover through the fog and filthy air? This implied that appearances were deceptive, and it created a sense of mystery and encouraged thought as to what significance this may hold for later in the play.The confused messages it conveyed provoked deep thought amongst the members of the audience. After the victorious battle, Macbeth's first words echoed the final words of the witches in the first scene, as he addressed Banquo: "So foul and fair a day I have not seen. " This referred back to the witches who stated the theme of the story, "Fair is foul and foul is fair" The significance of Macbeth's quote suggested the idea of being deceptive in appearances in terms of them winning the battle, but at the same time the weather being uncertain.
This was ironic as he was the character who later became two-faced and deceptive, so he was in fact talking about himself. Secondly, the characters in Macbeth are deceptive. The theme, "Fair is foul, foul is fair", occurs during all the scenes throughout the Act 1, and was mainly centered on the main character, Macbeth. Macbeth tried to obtain his position as a king by deceiving King Duncan. Possibly the most notable switch occurred between Macbeth and Lady Macbeth.
When Lady Macbeth learns of the witches' prophecy, she was absolute in her decision to kill the King.Another man who was full of deception was the thane of Cawdor. He betrayed his own country by aiding the Norwegian king to fight against his country in the battlefield. Another person who was deceptive was Lady Macbeth.
She was extremely welcoming and displayed kindness towards King Duncan, when in fact behind this she was planning his death making the scene very ironic. There was a great contrast in Lady Macbeth compared to her behaviour in the previous scene, in which she asked to lose her conscience to enable her to assist in the murder of King Duncan.This was again comparable to Macbeth in Act 1 where he planned to murder Duncan, but was extremely two-faced in the subsequent scene by being welcoming and kind to the King. Lady Macbeth made a great effort to ensure that Duncan felt completely relaxed and secure in her hands as hostess. The first impressions of Macbeth gained by the audience were positive which became increasingly negative as the play developed.
In great contrast, the very first impressions would be gained of Lady Macbeth were of an evil, scheming and ambitious character. She suggested that she was going to influence Macbeth into making sure he became a King.She had a hunger for power and was selfish, with no conscience. This scene appeared to suggest that Lady Macbeth was the dominant force in her relationship with her husband.
Finally, the deception was implied in the persona of the witches. The three witches were the ones who introduced the paradox that runs throughout the play. The theme affected the witches because although they speak of the future, they did not seem to affect the course of it.
They were the agents of fate because they only spoke of the truth of what would happen. When it came to deception, they were the one full of it. Macbeth referred to the Witches as the Weird Sisters.In fact the word "Weird" came from an old English word "wyrd," which means "fate. " In Macbeth's case, the prophecies served only to suggest the future, not to affect it. They predicted that he would become the king. The theme, "Fair is foul, and foul is fair" teaches some important moral values.
The line was a prophecy which means one thing seems like another. The author introduced the paradox through the witches as one of the themes, to show how deception would imply in the characters and the atmosphere of the play. It implied especially to the characters that they are not as they seem to be.
Related Posts about Lady Macbeth argumentative essay


gyldendal.no has a global alexa rank of 66019. With an estimated daily income of $65 (Sixty-Five dollars per day), gyldendal.no is estimated to be worth $53513 (Fifty-Three Thousand, Five Hundred And Thirteen dollars). Gyldendal receives around 34448 (Thirty-Four Thousand, Four Hundred And Forty-Eight) daily pageviews from around 18131 (Eighteen Thousand, One Hundred And Thirty-One) unique visitors.
P3P : CP="PHYi ONLa UIDa ADMa DEVa CURa"