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Canada v. Vaillancourt-Tremblay, 2010 DTC 5079 [at 6833], 2010 FCA 119
2010 DTC 5079 [at 6833], 2010 FCA 119
Docket: A-61-09
A-62-09
Citation: 2010 FCA 119
CORAM: BLAIS C.J.
NADON J.A.
TRUDEL J.A.
Docket A-61-09
DANIELLE VAILLANCOURT-TREMBLAY
GÉRARD TREMBLAY
BETWEEN :
MARTIN TREMBLAY
THE ESTATE OF HÉLÈNE TREMBLAY
Heard at Montréal, Quebec, on March 23, 2010.
Judgment delivered at Ottawa, Ontario, on May 12, 2010.
REASONS FOR JUDGMENT BY: TRUDEL J.A.
CONCURRED IN BY: NADON J.A.
DISSENTING REASONS BY: BLAIS C.J.
REASONS FOR JUDGMENT
[1] This decision addresses four appeals of a decision of Justice Favreau of the Tax Court of Canada (2009TCC6, [2009] 4 C.T.C. 2127). The appeals were consolidated by order of Justice Décary of April 22, 2009 pursuant to the Federal Courts Rules, SOR/98-106, r. 342.
[2] The respondents are members of the Tremblay family who held shares in 9000-8855 Québec Inc. (8855). In contemplation of their emigration from Canada, the respondents engaged in a series of transactions ultimately leading to the exchange of their 8855 shares for subordinate common shares in Le Groupe Vidéotron Ltée (Vidéotron). The Minister of National Revenue (the appellant) reassessed the respondents, ruling that the disposition of their 8855 shares gave rise to a deemed dividend under subsection 84(2) of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the Act). On appeal to the Tax Court, Justice Favreau (the Tax Court Judge) ruled that subsection 84(2) did not apply. For the reasons that follow, I agree with the Tax Court Judge and would dismiss the appeal.
Statutory provisions
[3] This appeal relates primarily to the interpretation of subsection 84(2) and, to a lesser extent, section 85.1 of the Act. Both provisions are found in Subdivision h of Division B of Part I of the Act, which provides rules for the computation of income of Canadian resident corporations.
[4] Section 84 deems a taxable dividend in the case of certain distributions by Canadian resident corporations. Subsection 84(2) operates to prevent corporations, upon the winding up, discontinuance, or reorganization of their business, from issuing to shareholders what should be taxable earnings in the form of an ostensibly tax-free return of paid-up capital, by deeming amounts distributed in excess of paid up capital (PUC) to be taxable dividends. It states as follows:
Distribution on winding-up, etc.
(2) Where funds or property of a corporation resident in Canada have at any time after March 31, 1977 been distributed or otherwise appropriated in any manner whatever to or for the benefit of the shareholders of any class of shares in its capital stock, on the winding-up, discontinuance or reorganization of its business, the corporation shall be deemed to have paid at that time a dividend on the shares of that class equal to the amount, if any, by which
(a) the amount or value of the funds or property distributed or appropriated, as the case may be,
exceeds
(b) the amount, if any, by which the paid-up capital in respect of the shares of that class is reduced on the distribution or appropriation, as the case may be,
and a dividend shall be deemed to have been received at that time by each person who held any of the issued shares at that time equal to that proportion of the amount of the excess that the number of the shares of that class held by the person immediately before that time is of the number of the issued shares of that class outstanding immediately before that time.
Distribution lors de liquidation, etc.
(2) Lorsque des fonds ou des biens d'une société résidant au Canada ont, à un moment donné après le 31 mars 1977, été distribués ou autrement attribués, de quelque façon que ce soit, aux actionnaires ou au profit des actionnaires de tout catégorie d'actions de son capital-actions, lors de la liquidation, de la cessation de l'exploitation ou de la réorganisation de son entreprise, la société est réputée avoir versé au moment donné un dividende sur les actions de cette catégorie, égal à l'excédent éventuel du montant ou de la valeur visés à l'alinéa a) sur le montant visé à l'alinéa b):
a) le montant ou la valeur des fonds ou des biens distribués ou attribués, selon le cas;
b) le montant éventuel de la réduction, lors de la distribution ou de l'attribution, selon le cas, du capital versé relatif aux actions de cette catégorie;
chacune des personnes qui détenaient au moment donné une ou plusieurs des actions émises est réputée avoir reçu à ce moment un dividende égal à la fraction de l'excédent représentée par le rapport existant entre le nombre d'actions de cette catégorie qu'elle détenait immédiatement avant ce moment et le nombre d'actions émises de cette catégorie qui étaient en circulation immédiatement avant ce moment.
[5] Section 85.1 creates a "rollover". When a taxpayer receives proceeds of disposition of an asset in excess of the tax cost of the asset (the adjusted cost base), he or she generally realizes a taxable capital gain. In certain situations, a taxpayer is permitted to defer the recognition of a capital gain on the disposition of an asset until the asset is disposed of again, further down the line. In these situations, the tax characteristics of the asset are said to be "rolled over" until the ultimate taxable disposition. Section 85.1 provides a rollover where shares of a Canadian resident corporation are issued to a taxpayer in exchange for shares in another Canadian resident corporation (a "share-for-share exchange"):
Share for share exchange
85.1 (1) Where shares of any particular class of the capital stock of a Canadian corporation (in this section referred to as the "purchaser") are issued to a taxpayer (in this section referred to as the "vendor") by the purchaser in exchange for a capital property of the vendor that is shares of any particular class of the capital stock (in this section referred to as the "exchanged shares") of another corporation that is a taxable Canadian corporation (in this section referred to as the "acquired corporation"), subject to subsection 85.1(2),
(a) except where the vendor has, in the vendor's return of income for the taxation year in which the exchange occurred, included in computing the vendor's income for that year any portion of the gain or loss, otherwise determined, from the disposition of the exchanged shares, the vendor shall be deemed
(i) to have disposed of the exchanged shares for proceeds of disposition equal to the adjusted cost base to the vendor of those shares immediately before the exchange, and
(ii) to have acquired the shares of the purchaser at a cost to the vendor equal to the adjusted cost base to the vendor of the exchanged shares immediately before the exchange,
and where the exchanged shares were taxable Canadian property of the vendor, the shares of the purchaser so acquired by the vendor shall be deemed to be taxable Canadian property of the vendor; and
(b) the cost to the purchaser of each exchanged share, at any time up to and including the time the purchaser disposed of the share, shall be deemed to be the lesser of
(i) its fair market value immediately before the exchange, and
(ii) its paid-up capital immediately before the exchange.
Where s. (1) does not apply
(2) Subsection 85.1(1) does not apply where
(a) the vendor and purchaser were, immediately before the exchange, not dealing with each other at arm's length (otherwise than because of a right referred to in paragraph 251(5)(b) that is a right of the purchaser to acquire the exchanged shares);
(b) the vendor or persons with whom the vendor did not deal at arm's length, or the vendor together with persons with whom the vendor did not deal at arm's length,
(i) controlled the purchaser, or
(ii) beneficially owned shares of the capital stock of the purchaser having a fair market value of more than 50% of the fair market value of all of the outstanding shares of the capital stock of the purchaser,
immediately after the exchange;
(c) the vendor and the purchaser have filed an election under subsection 85(1) or 85(2) with respect to the exchanged shares;
(d) consideration other than shares of the particular class of the capital stock of the purchaser was received by the vendor for the exchanged shares, notwithstanding that the vendor may have disposed of shares of the capital stock of the acquired corporation (other than the exchanged shares) to the purchaser for consideration other than shares of one class of the capital stock of the purchaser; or
(e) the vendor
(i) is a foreign affiliate of a taxpayer resident in Canada at the end of the taxation year of the vendor in which the exchange occurred, and
(ii) has included any portion of the gain or loss, otherwise determined, from the disposition of the exchanged shares in computing its foreign accrual property income for the taxation year of the vendor in which the exchange occurred.
Échange d'actions
85.1 (1) Les règles suivantes s'appliquent, sous réserve du paragraphe (2), dans le cas où une société canadienne (appelée « acheteur » au présent article) émet des actions d'une catégorie de son capital-actions en faveur d'un contribuable (appelé « vendeur » au présent article), en échange d'immobilisations du vendeur qui sont des actions d'une catégorie du capital-actions (appelées « actions échangées » au présent article) d'une autre société qui est une société canadienne imposable (appelée « société acquise » au présent article):
a) sauf lorsque le vendeur a, dans sa déclaration d'impôt pour l'année d'imposition au cours de laquelle a eu lieu l'échange, inclus dans le calcul de son revenu pour cette année, toute partie du gain ou de la perte, par ailleurs déterminée, provenant de la disposition des actions échangées, le vendeur est réputé :
(i) avoir tiré un produit de disposition des actions échangées égal au prix de base rajusté de celles-ci, pour lui, immédiatement avant l'échange,
(ii) avoir acquis les actions de l'acheteur à un coût, pour lui, égal au prix de base rajusté des actions échangées, pour lui, immédiatement avant l'échange;
en outre, lorsque les actions échangées étaient un bien canadien imposable du vendeur, les actions de l'acheteur qu'il a ainsi acquises sont réputées être un bien canadien imposable du vendeur;
b) le coût pour l'acheteur de chaque action échangée à un moment donné qui n'est pas postérieur au moment où il a disposé de l'action est réputé être le moins élevé des montants suivants :
(i) la juste valeur marchande de l'action immédiatement avant l'échange,
(ii) le capital versé au titre de l'action immédiatement avant l'échange.
Non-application du par. (1)
(2) Le paragraphe (1) ne s'applique pas dans l'un ou l'autre des cas suivants :
a) le vendeur et l'acheteur avaient un lien de dépendance immédiatement avant l'échange (autrement qu'à cause d'un droit visé à l'alinéa 251(5)b) qui permet à l'acheteur d'acquérir les actions échangées);
b) le vendeur, les personnes avec qui il a un lien de dépendance ou le vendeur et les personnes avec qui il a un lien de dépendance :
(i) soit contrôlaient l'acheteur,
(ii) soit avaient la propriété effective d'actions du capital-actions de l'acheteur dont la juste valeur marchande est égale à plus de 50 % de la juste valeur marchande de toutes les actions en circulation du capital-actions de l'acheteur,
immédiatement après l'échange;
c) le vendeur et l'acheteur ont présenté un choix en vertu du paragraphe 85(1) ou (2) à l'égard des actions échangées;
d) la contrepartie, à l'exception d'actions de la catégorie donnée du capital-actions de l'acheteur, a été reçue par le vendeur en compensation des actions échangées, malgré le fait que le vendeur ait pu disposer d'actions du capital-actions de la société acquise (à l'exception des actions échangées) en faveur de l'acheteur moyennant une contrepartie autre que des actions d'une catégorie du capital-actions de l'acheteur;
e) le vendeur, à la fois :
(i) est la société étrangère affiliée d'un contribuable résidant au Canada à la fin de l'année d'imposition du vendeur au cours de laquelle l'échange a été effectué,
(ii) a inclus, dans le calcul de son revenu étranger accumulé, tiré de biens pour son année d'imposition au cours de laquelle l'échange a été effectué, une partie du gain ou de la perte, déterminé par ailleurs, provenant de la disposition des actions échangées.
The transaction on appeal
[6] As I indicated earlier, the respondents are members of the Tremblay family. Until 1989, the Tremblay family, through its company "Les Placements M.H.T. Inc." (MHT), owned Télésag Inc., a cable television distribution company. In February 1989, MHT sold its shares in Télésag to Vidéotron in exchange for Vidéotron preferred shares.
[7] In 1994, the respondents decided to emigrate from Canada and sought to reorganize their business affairs to facilitate their departure. Accordingly, they incorporated 8855 on February 2, 1994. On February 15, 1994, the respondents sold their shares in MHT to 8855 in exchange for Class A shares of 8855. The respondents deferred the recognition of any capital gain on this transaction through the use of a rollover provision in subsection 85(1) of the Act.
[8] The next day, February 16, 1994, MHT used the rollover provision in subsection 85(1) of the Act to transfer the following Vidéotron securities to 8855 (the convertible securities):
a. 425,174 Series B 8% cumulative first preferred shares, convertible into subordinate voting shares at a rate of three subordinate shares for each Series B preferred share (the preferred shares);
b. 92 unsecured subordinate debentures bearing interest at the rate of 11 3/4% with a face value of $5,175,000 overall ($56,250 per debenture), convertible at
Vidéotron's call into subordinate voting shares at a rate of 3,000 subordinate shares per debenture (the debentures).
[9] On February 25, 1994, Vidéotron and the respondents entered into an agreement whereby Vidéotron agreed to "lend its assistance indirectly and subsidiarily during the final stage of the corporate reorganization". The Agreement stated that Vidéotron would participate provided the following conditions were met:
a. The respondents would waive $335,071.48 in dividends on the preferred shares and $200,928.52 in interest on the debentures;
b. The Vidéotron Board of Directors would approve the issue of subordinate shares of Vidéotron capital stock in consideration of the purchase of shares of a corporation controlled by the respondents;
c. The respondents would undertake to compensate Vidéotron for any claims arising out of the transaction and would provide an irrevocable bank letter of credit for at least $1,000,000, valid for at least five years from the date of issue;
d. Vidéotron would obtain exemptions from required stock exchanges and securities regulators, and the respondents would provide undertakings necessary to do so;
e. The respondents would pay all expenses incurred by Vidéotron in connection with the reorganization;
f. The reorganization would be completed by April 8, 1994.
[10] The Agreement also stated that Vidéotron would redeem the convertible securities on April 26, 1994 unless they had been converted by that date.
[11] On March 7, 1994, Vidéotron split its subordinate shares on a two-for-one basis; 8855 did the same for its Class A shares. On March 31, 1994 the Commission des valeurs mobilières du Québec granted the proposed transaction an exemption from prospectus and registration requirements.
[12] On April 6, 1994, Vidéotron and the respondents engaged in the share-for-share exchange contemplated by the Agreement, pursuant to the rollover provision in subsection 85.1(1) of the Act. The respondents transferred to Vidéotron all outstanding capital stock in 8855. Vidéotron then issued 3,103,044 new subordinate common shares to the respondents (the Vidéotron common shares). Immediately after the exchange, Vidéotron, now the owner of 8855, cancelled all 8855 debt owing to Vidéotron under the former subsection 80(3) of the Act. Vidéotron then wound up and dissolved 8855, cancelling the convertible securities for no consideration. Accordingly, the requirement that Vidéotron redeem the convertible securities on April 26, 1994 ceased to have any effect. The respondents then obtained the required letter of credit from the National Bank of Canada.
[13] The respondents left Canada on April 7, 1994.
[14] On December 30, 2004, the appellant reassessed the respondents for the 1994 tax year. The reassessments included in the respondents' income grossed-up taxable dividends deemed under subsection 84(2) in connection with the transaction.
The Tax Court Decision
[15] On appeal to the Tax Court, the parties made arguments similar to those presented before the Court. The respondents argued primarily that subsection 84(2) does not apply to the transaction, and that the transaction qualified for a rollover as a share-for-share exchange under section 85.1. The appellant conceded that the transaction qualified for a rollover under section 85.1, but argued that subsection 84(2) applied concurrently.
[16] The Tax Court Judge allowed the appeal and ruled that subsection 84(2) did not apply. First, he found that subsection 84(2) and section 85.1 can be applied concurrently. Second, the Tax Court Judge noted that the appellant did not argue that the transaction was a sham or that the general anti-avoidance rule in section 245 should apply. Accordingly, the Tax Court Judge based his decision only on whether subsection 84(2) applied. He noted that in RMM Canadian Enterprises Inc. v. Canada [1998] 1 C.T.C. 2300 at paragraph 22 [RMM], Chief Justice Bowman held that subsection 84(2) contains "words of the widest import [that] cover a large variety of ways in which corporate funds can end up in a shareholder's hands" (decision at paragraph 18).
[17] Third, the Tax Court Judge surveyed existing jurisprudence on the matter, including RMM, Geransky v. Canada, [2001] 2 C.T.C. 2147 [Geransky] and Merritt v. Canada (Minister of National Revenue – M.N.R.) [1941] Ex.C.R. 175. He considered RMM in particular depth. RMM concerned Equilease Corporation, an American parent corporation that sought to wind up its Canadian subsidiary, Equilease Limited, without incurring a non-resident withholding tax liability. To accomplish this, RMM secured a loan against the assets of Equilease Limited for the value of the assets of Equilease Limited. RMM used the loan to purchase Equilease Limited from Equilease Corporation and used the assets of Equilease Limited to pay back the loan. RMM also received $140,000 in outstanding leases owing to Equilease Limited. Chief Justice Bowman ruled that subsection 84(2) created a deemed dividend as RMM was "interested only in earning what was in essence a fee for acting as a facilitator or accommodator in the transaction" (RMM at paragraph 17, cited in decision at paragraph 32).
[18] Having surveyed the facts and relevant jurisprudence, the Tax Court Judge then ruled that the transaction in the case at bar was not caught by subsection 84(2), and accordingly allowed the appeal. He noted that Vidéotron was not an "accommodation company" as contemplated by RMM (decision at paragraph 46). He also stressed that the legal nature of the Vidéotron common shares received by the respondents was different from that of the preferred shares and debentures held by 8855. Indeed, the subordinated shares issued to the respondents were newly issued shares and therefore could never have been 8855 property (decision at paragraph 48).
[19] The appellant asserts that the convertible securities were distributed to the respondents and that the Tax Court Judge erred in requiring that the respondents have received identical property («biens identiques») in return for the 8855 shares.
Appellant's submissions
[20] The appellant argues that the overarching goal of the transaction was to permit the respondents to retain the Vidéotron common shares without incurring departure tax under section 128.1. Section 128.1 in essence deems a disposition of property at fair market value upon a taxpayer's emigration from Canada, but exempts taxable Canadian property. With this in mind, the appellant makes four arguments.
[21] First, the appellant argues that Vidéotron acted as a "facilitator." This in turn benefited Vidéotron, as the respondents waived dividends and interest payments on the convertible securities.
[22] Second, the appellant submits that the transaction had the effect of transforming the 8855 convertible securities into the Vidéotron common shares and then transferring those to the respondents. The appellant notes that the value of the convertible securities and the Vidéotron common shares was the same, and that the Commission des valeurs mobilières du Québec considered the two types of securities to have the same effect. Accordingly, even though the legal nature of the securities received by the respondents was not identical to that of the convertible securities, the property was substantially the same.
[23] Third, the appellant submits that nothing in subsection 84(2) required the active participation of 8855.
[24] Fourth, the appellant claims that the Tax Court Judge erroneously added an extra condition to subsection 84(2) by requiring that the property transferred and received be identical.
Respondents' submissions
[25] The respondents broadly make seven points in their submissions. First, they argue that the ratio of the Tax Court Judge's decision was not that the property transferred and received must be
identical. Rather, the ratio of the decision was that since the shares received by the respondents were newly created, there could not have been any appropriation of 8855 property.
[26] Second, the respondents dispute the appellant's suggestion that the goal of the transaction was to avoid a deemed dividend under section 128.1. They note that the 8855 shares were considered taxable Canadian property before the transaction and therefore would not have been subject to the deemed disposition in section 128.1. Rather, the respondents claim that the only benefit they sought to achieve was increased liquidity resulting from their ability to sell Vidéotron shares without the need to obtain a clearance certificate or withhold part of the purchase price.
[27] Third, the respondents argue that the 8855 assets were not attributed to them in the form of Vidéotron common shares. They provide four arguments in support. First, 8855 retained all of its assets until it was wound up by Vidéotron. Second, the Vidéotron common shares were newly issued and could not have previously been the property of 8855. Third, the legal nature of the Vidéotron common shares was different from that of the convertible assets, as different rights attach to different classes of securities. Finally, a taxpayer's legal relationships must be respected absent a sham (see Shell Canada Ltd. v. Canada, [1999] 3 S.C.R. 622 [Shell Canada]). Since the appellant does not allege a sham, the legal effect of the transaction is paramount.
[28] Fourth, the respondents argue that RMM can be distinguished on five different counts. First, in RMM the property remitted to the shareholder was legally identical to the assets of the corporation. Second, in RMM the assets of Canadian subsidiary were pledged as collateral to pay the bank loan used to purchase it. Third, RMM was created as "a mere instrumentality" to facilitate the transaction; Vidéotron, on the other hand, is a well established corporation, and the Tax Court Judge explicitly found that it was not a mere facilitator. Finally, in RMM the Tax Court found that the transaction was a "surplus strip" of the Equilease Canada assets. In this case, the respondents submit that the purpose of the transaction was to increase the liquidity of their Vidéotron holdings.
[29] The respondents submit that the case at bar is closer to Geransky. In Geransky, the appellant and his brother owned all of the shares in Geransky Brothers Construction Ltd. (GBC), a concrete construction and manufacturing business. For business reasons, GBC decided to sell off the manufacturing part of the business to Lafarge Canada Inc. To effect the sale, the brothers transferred shares in their holding company, Geransky Brothers Holding Ltd. (GH), to a numbered company (NumCo) in exchange for NumCo shares. GBC then transferred the target assets to GH as a $1 million dividend-in-kind. GH in turn bought back its stock from NumCo in exchange for the assets, thereby giving NumCo the target assets. The brothers then sold their NumCo shares to Lafarge for $1 million, giving Lafarge control of the assets. The Minister of National Revenue assessed a deemed dividend under subsection 84(2). Acting Chief Justice Bowman (as he then was) ruled that subsection 84(2) did not apply, basing his decision in part on an interpretation that Lafarge was not the type of accommodation company contemplated by RMM (Geransky at paragraph 21(c)).
[30] Fifth, the respondents argue that the Tax Court Judge did not add an extra condition to subsection 84(2). When the Tax Court Judge used the word "identical" he only used it as a qualifier to make clear that 8855 property was not distributed to the respondents.
[31] Sixth, the respondents argue in the alternative that if there was a distribution or appropriation of corporate property to the shareholders, the distribution or appropriation was not made on the winding up of 8855, as 8855 continued to hold the convertible securities until it was wound up by Vidéotron after the exchange.
[32] Finally, in the further alternative, the respondents submit that even if 8855 property was distributed or appropriated on its winding up, section 85.1 and subsection 84(2) cannot apply concurrently. They argue that concurrent application would render it impossible to determine the proceeds of disposition of the shares of 8855 or the cost base of the Vidéotron common shares, would result in double taxation, would run contrary to the maxims of statutory interpretation, and would defeat tax policy goals.
[33] The appellant claims that the Tax Court Judge erred in requiring the exchange of identical property. This is a question of law and is therefore reviewable on a standard of correctness (Housen v. Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 at paragraph 8).
[34] I agree with the Tax Court Judge that subsection 84(2) cannot apply because the property received by the respondents was never the property of 8855. As such, the property of 8855 was never "distributed or otherwise appropriated in any manner whatever" to the respondents and the appeal must fail. I rely on two sources to justify this interpretation. First, I believe that the plain and ordinary meaning of subsection 84(2) is clear. Second, I believe existing jurisprudence confirms this interpretation.
Plain and ordinary meaning
[35] In Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 [Canada Trustco] at paragraph 10, the Supreme Court held that "When the words of a provision are precise and unequivocal, the ordinary meaning of the words play a dominant role in the interpretive process." The appellant argues that the phrase "distributed or otherwise appropriated in any manner whatever" must be given a broad meaning. That may well be the case, but the part of subsection 84(2) most relevant to this case is actually the opening phrase "Where funds or property of a corporation resident in Canada .…" The only tenable understanding of this phrase is that the property distributed to or appropriated by the recipient must be property of the Canadian resident corporation in question. In this case, the Vidéotron common shares were newly issued securities and had never been the property of 8855. As the respondents point out, 8855 retained its assets until it was eventually wound up into Vidéotron.
[36] The appellant argues that even though the legal nature of the property received by the respondents was different from the 8855 shares, the transaction substantively involved the same property throughout, subject to a transformation from the convertible securities to the Vidéotron common shares. This argument does not hold. In income tax law, the legal nature of the transaction is paramount. In Canada Trustco, the Supreme Court stated at paragraph 11 that "Where Parliament has specified precisely what conditions must be satisfied to achieve a particular result, it is reasonable to assume that Parliament intended that taxpayers would rely on such provisions to achieve the result they prescribe." In Shell Canada, the Supreme Court stated as follows:
39 This Court has repeatedly held that courts must be sensitive to the economic realities of a particular transaction, rather than being bound to what first appears to be its legal form: Bronfman Trust, supra, at pp. 52-53, per Dickson C.J.; Tennant, supra, at para. 26, per Iacobucci J. But there are at least two caveats to this rule. First, this Court has never held that the economic realities of a situation can be used to recharacterize a taxpayer's bona fide legal relationships. To the contrary, we have held that, absent a specific provision of the Act to the contrary or a finding that they are a sham, the taxpayer's legal relationships must be respected in tax cases. Recharacterization is only permissible if the label attached by the taxpayer to the particular transaction does not properly reflect its actual legal effect: Continental Bank Leasing Corp. v. Canada, [1998] 2 S.C.R. 298, at para. 21, per Bastarache J.
40 Second, it is well established in this Court's tax jurisprudence that a searching inquiry for either the "economic realities" of a particular transaction or the general object and spirit of the provision at issue can never supplant a court's duty to apply an unambiguous provision of the Act to a taxpayer's transaction. Where the provision at issue is clear and unambiguous, its terms must simply be applied: Continental Bank, supra, at para. 51, per Bastarache J.; Tennant, supra, at para. 16, per Iacobucci J.; Canada v. Antosko, [1994] 2 S.C.R. 312, at pp. 326-27 and 330, per Iacobucci J.; Friesen v. Canada, [1995] 3 S.C.R. 103, at para. 11, per Major J.; Alberta (Treasury Branches) v. M.N.R., [1996] 1 S.C.R. 963, at para. 15, per Cory J.
(Emphasis added).
[37] In this case, the appellant does not allege a sham and has not proceeded under the section 245 general anti-avoidance rule. The legal transaction and the provision in question are clear. Accordingly, the narrow and unambiguous legal effect of this reorganization must be respected and subsection 84(2) cannot apply.
[38] The appellant relies heavily on RMM. However, I do not believe RMM is on all fours with the case at bar. In RMM, there was no "transformation" of the property in question. RMM paid cash to Equilease Limited for Equilease Limited shares. RMM then liquidated Equilease Limited and repaid Equilease Corporation (the American parent corporation of Equilease Limited) the exact amount it used to purchase the shares in the first place. Nowhere did the nature of the property transform.
[39] Indeed, Chief Justice Bowman clearly turned his mind to the legal substance of the transaction:
18 What of the fact that there was a sale of shares? Of course there was a sale. It was not a sham. "Sale of shares" is a precise description of the legal relationship. Nor do I suggest that the doctrine of "substance over form" should dictate that I ignore the sale in favour of some other legal relationship. That is not what the doctrine is all about . Rather it is that the essential nature of a transaction cannot be altered for income tax purposes by calling it by a different name. It is the true legal relationship, not the nomenclature that governs. The Minister, conversely, may not say to the taxpayer "You used one legal structure but you achieved the same economic result as that which you would have had if you used a different one. Therefore I shall ignore the structure you used and treat you as if you had used the other one".
19 One cannot deny or ignore the sale. Rather, one must put it in its proper perspective in the transaction as a whole. The sale of [Equilease Limited's] shares and the winding-up or discontinuance of its business are not mutually exclusive. Rather they complement one another. The sale was merely an aspect of the transaction described in subsection 84(2) that gives rise to the deemed dividend. . . . I do not think that the brief detour of the funds through RMM stamps them with a different character from that which they had as funds of [Equilease Limited] distributed or appropriated to or for the benefit of [Equilease Corporation]. Nor do I think that the fact that the funds that were paid to [Equilease Corporation] by RMM were borrowed from the bank and then immediately repaid out of [Equilease Limited's] money is a sufficient basis for ignoring the words "in any manner whatever".
(Emphasis added)
[40] Chief Justice Bowman therefore clearly stated that in RMM the funds received were the same property as that which had been distributed. For the foregoing reasons, however, in the case at bar the property received by the respondents simply never existed in the hands of 8855. Deeming the Vidéotron common shares received by the respondents to have been the corporate property of 8855 would be tantamount to saying "I shall ignore the structure you used and treat you as if you had used the other one." Such an interpretation would contradict RMM, Shell Canada, and Canada Trustco.
[41] While the respondents urge the Court to find support in Geransky, there is no need to either rely on or distinguish it. In the case at bar, the plain and ordinary meaning of subsection 84(2) is dispositive: since the Vidéotron common shares received by the respondents were never the property of 8855, it simply cannot be the case that subsection 84(2) is engaged. Subsection 84(2) requires the appropriation or distribution of corporate assets, but 8855 retained the entirety of its assets until it was wound up by Vidéotron. Accordingly, I find that there was no distribution or appropriation of 8855 property and the transaction therefore does not give rise to a deemed dividend.
[42] In light of my finding that there was no distribution or appropriation within the meaning of subsection 84(2) and the appellant's concession that section 85.1 applies, there is no need to address whether the transaction occurred upon wind up or whether subsection 84(2) and section 85.1 can apply concurrently. On the facts of this case, subsection 84(2) does not apply and section 85.1 does.
[43] The parties have also made submissions with respect to the respondents' motivation to pursue the transaction under review. Once again, the appellant argues that the goal of the transaction was to avoid a deemed disposition under section 128.1 The respondents argue that section 128.1 would have applied regardless of the transaction as 8855 assets were taxable Canadian property, and that the goal was to increase liquidity by avoiding the need to obtain a clearance certificate prior to disposition. However, the appellant does not argue the transaction was in any way a sham. Accordingly, the respondents' motivation does not matter. The appellant assessed the respondent under subsection 84(2) and the subsection makes no reference to the motives of the parties; therefore, the reason for which the respondents entered into the transaction is entirely irrelevant to the disposition of the case.
[44] At its root, this case is about whether there was a distribution of 8855 property to the respondents. As stated above, the respondents never received 8855 property. Accordingly, section 84(2) is not triggered. I would dismiss the appeal and award one set of costs to the respondents in this Court and the Court below. These reasons will be placed in file A-61-09 with a copy in each of files A-62-09, A-64-09, and A-65-09.
"Johanne Trudel"
M. Nadon J.A."
CHIEF JUSTICE BLAIS (Dissenting Reasons)
[45] I have had the benefit of reading the reasons of my colleague Trudel J.A. While the factual background is not in dispute, with all due respect, I am unable to agree with her conclusion.
[46] It cannot be disputed that, as the result of a pre-arranged series of transactions culminating in the winding-up of 8855, the respondents became the direct owners of an investment in Vidéotron in place of what had been an indirect investment in Vidéotron which they held through their ownership of 8855. Prima facie, that is a sufficient factual foundation for the application of subsection 84(2). The question is whether the application of subsection 84(2) is avoided simply because the respondents' direct investment in Vidéotron takes the form of newly issued shares of Vidéotron, rather than the shares and convertible debentures of Vidéotron previously owned by the respondents indirectly through 8855. In my opinion, the answer must be no.
[47] In my view, the result of this case is governed by Smythe v. Canada (Minister of National Revenue – M.N.R.), [1970] S.C.R. 64 [Smythe], in which the Court concluded that subsection 81(1) of the Income Tax Act, R.S.C. 1952, c. 148, applied to a series of transactions that in material respects is similar to the series of transactions in this case.
[48] The wording of subsection 81(1) as it read at the time is as follows :
81. (1) Where funds or property of a corporation have, at a time when the corporation had undistributed income on hand, been distributed or otherwise appropriated in any manner whatsoever to or for the benefit of one or more of its shareholders on the winding-up, discontinuance or re-organization of its business, a dividend shall be deemed to have been received at that time by each shareholder equal to the lesser of
a) the amount or value of the funds or property so distributed or appropriated to him, or
b) his portion of the undistributed income then on hand.
[49] The following is a summary of the facts in Smythe as provided in the decision :
In 1961, the appellants owned almost all the shares of an active company having substantial assets and an undistributed income of $728,652 on hand. A new company was incorporated in Ontario in which the appellants held shares in the same proportion as their respective holdings in the old company. All the assets of the old company were sold to the new company in exchange for a promissory note for $2,611,769. The new company obtained a bank loan to pay the old company which used the cash thus received to purchase preferred shares in two Vancouver based companies. The appellants sold their shares in the old company to the two Vancouver companies for cash at dollar for dollar on capital and 95 per cent on undistributed income. The appellants then reinvested part of that cash in debentures of the new company. When all the transactions had been completed, the undistributed income of the old company was in the hands of the appellants partly in cash and partly in debentures of the new company, without any income tax having been paid on such distribution. The Minister reassessed the appellants under s. 81(1) of the Income Tax Act, R.S.C. 1952, c. 148.
[50] Although Smythe involved the appropriation of undistributed income on hand to shareholders, the assets were transformed through various transactions which involved the incorporation of a new company and unrelated companies as well as bank loans until the assets in the desired form were back into the appellants' hands.
[51] At page 68, Justice Judson expressed the following :
There is only one possible conclusion from an examination of these artificial transactions and that must be that their purpose was to distribute or appropriate to the shareholders the "undistributed income on hand" of the old company. No oral or other documentary evidence is needed to supplement this examination. There was, however, an abundance of other evidence. This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income (…)
[52] On this basis, I would allow the appeal.
"Pierre Blais"
NAMES OF COUNSEL AND SOLICITORS OF RECORD
DOCKET: A-61-09, A-62-09, A-64-09, A-65-09
STYLE OF CAUSE: Her Majesty the Queen v. Danielle Vaillancourt-Tremblay
Her Majesty the Queen, v. Gérard Tremblay
Her Majesty the Queen v. Martin Tremblay
Her Majesty the Queen v. The Estate of Hélène Tremblay
PLACE OF HEARING: MONTRÉAL, QUEBEC
DATE OF HEARING: MARCH 23, 2010
Michel Lamarre
Nathalie Labbé
FOR THE APPELLANT
Richard W. Pound
Charles C. Gagnon
FOR THE RESPONDENTS
SOLICITORS OF RECORD:
John H. Sims, QC
Montréal (Quebec)
BCF LLP
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2)
s. 84(2) inapplicable to tuck-under transaction


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Two Centenarians Steal the Show at USATF Masters Indoor Championships
Julia Hawkins and Orville Rogers may not have had a ton of competition, but their efforts are still incredible.
By Morgan Petruny
The USATF Masters Indoor Track & Field Championships are a rare gem where a competitors' age will often exceed the event distance. Take for instance, 102-year-old Julia "Hurricane" Hawkins and fellow centenarian Orville Rogers, who demolished their respective 60-meter dashes this past weekend in Landover, Maryland.
Of the seven world records that fell during competition on Saturday, four of them were the spoils of this 100-year-old-plus crowd.
Hawkins set the new women's 100-plus age division record for the 60-meter dash in 24.79, besting contemporary Ida Keeling's 58.34 back in February. Following the race, the Baton Rouge native turned her sights on the field events, where she broke the indoor shot put record with a throw of 2.77 meters. (Watch her 60-meter race below, courtesy of USATF-TV.)
Surprisingly, Hawkins is relatively new to running. She's been at it for less than two years since officially getting into the sport on her 100th birthday, but has certainly made her time count, clocking record times from Birmingham to Baton Rouge. Last year, Hawkins set the 100-meter world record at the National Senior Olympic Games in 39.62, shaving six seconds off the current mark. One month later, she was back in her hometown for the USA Track & Field Masters Outdoor Championships, where she clocked a consistent 40.12.
While Hawkins doesn't do much running outside of competition, her current training plan seems to be working for her. She enjoys working in her backyard and tending to the house she and her late husband build in 1949. "I do a little running around each day—not a certain amount or time—but just to keep everything going." she told Runner's World. "I don't want to waste too many 100-yard dashes, because I only have so many left."
Among other notable performances at the indoor champs was the long-awaited 60-meter rematch between Orville Rogers and Dixon Hemphill. This time, 93-year-old Hemphill edged out 100-year-old Rogers in another close finish, crossing the line a mere 0.12 seconds sooner in 19.01. (See the race below, courtesy of USATF-TV.)
However, Rogers's time of 19.13 was still good enough to land him a world's best for his age division. Before the weekend was up, the Texan would enter the record books again for his 100-104 age group—clocking a 4:16.90 in the 400 meters and 20:00.19 in the 1500 meters.
USATF Indoor Championships Will Return to Boston
Five Races to Watch at USATF Indoor Championships
Shannon Rowbury Wins Mile at USATF Indoor Championships
World Records Broken at Masters Championships
How to Watch the World Indoor Championships

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Our passage this week includes Matthew 18-22.
It seems that Jesus has completed His ministry, now it is time to head towards Jerusalem and Calvary. The emphasis in chapter 18 centers around understanding the Kingdom of God – what Jesus is actually going to establish versus the people's ideas. It becomes very clear that holiness is a must for the people of the Kingdom. So much so that it is better to maimed then to enter in with corrupted body parts.
Jesus uses the illustration of the Child numerous times. The disciples have several times denounced the "insignificant" child from bothering Jesus. Jesus must be seen as a lover of little children. Their innocence and pure love for him is refreshing in comparison to the agenda driven religious leaders and even the disciples. Matt 18:10, could be used to make the case for guardian angels of the little children.
Discipline within the body of Christ is necessary. However, many churches do not address sin in their midst. Matt 18:15-20 is the biblical formula for taking care of faults and restoring and/or removing fellowship of sinning church family. I have heard Matt 18:20 used so many times, I often cringe when I hear it used, for it is often used to support God hearing our prayers because two have gathered in His Name. This view does not fit the context of the passage. The purpose of the passage in correction and restoration. In other words when we come together to discipline with biblical counsel, Jesus is affirming our action being taken in the body of Christ. The continuing emphasis on forgiving follows to the end of the chapter. The reference to two or more gathering in His Name is in reference to doing the work of God, through the power of God, with the agreement of God.
In Matt 19 – Jesus brings up the children again, still the disciples don't get the Kingdom mindset. The Kingdom isn't for the socially accepted, but for those that often are rejected by the religious and the churched! [Matt 21:31] Jesus uses the parable literary genre to prove His case about conditions in the world. The Laborers in the Vineyard, speak clearly how we are people are greedy and want more than others. The rewards of God are grace and truth. Just because God has been gracious and called us to labor in His field longer, does not give us seniority over others that have come later. I find this often in churches, who feel that they are more deserving just because they have been members longer and that their way should be the right way. Both last and first have been treated graciously by God. We don't deserve anything – God doesn't owe us!
Hearing the truth isn't always freeing, often it is convicting and condemning. If truth is rejected by people we will become treacherous towards anyone who thinks otherwise. Truth cannot be destroyed by a lie, no matter how many accept the lie.


Class XII Biology Chapter 10 Microbes in Human Welfare NCERT Solution is given below.
Question 1: Bacteria cannot be seen with the naked eyes, but these can be seen with the help of a microscope. If you have to carry a sample from your home to your biology laboratory to demonstrate the presence of microbes under a microscope, which sample would you carry and why?
Answer Curd can be used as a sample for the study of microbes. Curd contains numerous lactic acid bacteria (LAB) or Lactobacillus. These bacteria produce acids that coagulate and digest milk proteins. A small drop of curd contains millions of bacteria, which can be easily observed under a microscope.
Question 2: Give examples to prove that microbes release gases during metabolism.
(a) Bacteria and fungi carry out the process of fermentation and during this process, they release carbon dioxide. Fermentation is the process of converting a complex organic substance into a simpler substance with the action of bacteria or yeast. Fermentation of sugar produces alcohol with the release of carbon dioxide and very little energy.
(b) The dough used for making idli and dosa gives a puffed appearance. This is because of the action of bacteria which releases carbon dioxide. This CO2 released from the dough gets trapped in the dough, thereby giving it a puffed appearance.
Question 3: In which food would you find lactic acid bacteria? Mention some of their useful applications.
Answer Lactic acid bacteria can be found in curd. It is this bacterium that promotes the formation of milk into curd. The bacterium multiplies and increases its number, which converts the milk into curd. They also increase the content of vitamin B12 in curd. Lactic acid bacteria are also found in our stomach where it keeps a check on the disease-causing micro-organisms.
Question 4: Name some traditional Indian foods made of wheat, rice and Bengal gram (or their products) which involve use of microbes.
Answer (a) Wheat: Product: Bread, cake, etc.
Question 5: In which way have microbes played a major role in controlling diseases caused by harmful bacteria?
Answer Several micro-organisms are used for preparing medicines. Antibiotics are medicines produced by certain micro-organisms to kill other disease-causing micro-organisms. These medicines are commonly obtained from bacteria and fungi. They either kill or stop the growth of disease-causing micro-organisms. Streptomycin, tetracycline, and penicillin are common antibiotics. Penicillium notatum produces chemical penicillin, which checks the growth of staphylococci bacteria in the body. Antibiotics are designed to destroy bacteria by weakening their cell walls. As a result of this weakening, certain immune cells such as the white blood cells enter the bacterial cell and cause cell lysis. Cell lysis is the process of destroying cells such as blood cells and bacteria.
Question 6: Name any two species of fungus, which are used in the production of the antibiotics.
Question 7: What is sewage? In which way can sewage be harmful to us?
Answer Sewage is the municipal waste matter that is carried away in sewers and drains. It includes both liquid and solid wastes, rich in organic matter and microbes. Many of these microbes are pathogenic and can cause several water- borne diseases. Sewage water is a major cause of polluting drinking water. Hence, it is essential that sewage water is properly collected, treated, and disposed.
Question 8: What is the key difference between primary and secondary sewage treatment?
Question 9: Do you think microbes can also be used as source of energy? If yes, how?
Answer Yes, microbes can be used as a source of energy. Bacteria such as Methane bacterium is used for the generation of gobar gas or biogas. The generation of biogas is an anaerobic process in a biogas plant, which consists of a concrete tank (10−15 feet deep) with sufficient outlets and inlets. The dung is mixed with water to form the slurry and thrown into the tank. The digester of the tank is filled with numerous anaerobic methane-producing bacteria, which produce biogas from the slurry. Biogas can be removed through the pipe which is then used as a source of energy, while the spent slurry is removed from the outlet and is used as a fertilizer.
Question 10: Microbes can be used to decrease the use of chemical fertilisers and pesticides. Explain how this can be accomplished.
leguminous plants. Azospirillium and Azotobocter are free living nitrogen-fixing bacteria, whereas Anabena, Nostoc and Oscillitoria are examples of nitrogen-fixing cyanobacteria. Bio-fertilizers are cost effective and eco-friendly. Microbes can also act as bio-pesticides to control insect pests in plants. An example of bio-pesticides is Bacillus thuringiensis, which produces a toxin that kills the insect pests. Dried bacterial spores are mixed in water and sprayed in agricultural fields. When larvae of insects feed on crops, these bacterial spores enter the gut of the larvae and release toxins, thereby it. Similarly, Trichoderma are free living fungi. They live in the roots of higher plants and protect them from various pathogens. Baculoviruses is another bio-pesticide that is used as a biological control agent against insects and other arthropods.
Question 11: Three water samples namely river water, untreated sewage water and secondary effluent discharged from a sewage treatment plant were subjected to BOD test. The samples were labelled A, B and C; but the laboratory attendant did not note which was which. The BOD values of the three samples A, B and C were recorded as 20mg/L, 8mg/L and 400mg/L, respectively. Which sample of the water is most polluted? Can you assign the correct label to each assuming the river water is relatively clean?
Answer Biological oxygen demand (BOD) is the method of determining the amount of oxygen required by micro-organisms to decompose the waste present in the water supply. If the quantity of organic wastes in the water supply is high, then the number of decomposing bacteria present in the water will also be high. As a result, the BOD value will increase. Therefore, it can be concluded that if the water supply is more polluted, then it will have a higher BOD value. Out of the above three samples, sample C is the most polluted since it has the maximum BOD value of 400 mg/L. After untreated sewage water, secondary effluent discharge from a sewage treatment plant is most polluted. Thus, sample A is secondary effluent discharge from a sewage treatment plant and has the BOD value of 20 mg/L, while sample B is river water and has the BOD value of 8 mg/L.
Question 13: Find out the role of microbes in the following and discuss it with your teacher.
A single cell protein is a protein obtained from certain microbes, which forms an alternate source of proteins in animal feeds. The microbes involved in the preparation of single cell proteins are algae, yeast, or bacteria. These microbes are grown on an industrial scale to obtain the desired protein. For example, Spirulina can be grown on waste materials obtained from molasses, sewage, and animal manures. It serves as a rich supplement of dietary nutrients such as proteins, carbohydrate, fats, minerals, and vitamins. Similarly, micro-organisms such as Methylophilus and methylotrophus have a large rate of biomass production. Their growth can produce a large amount of proteins.
(b) Soil Microbes play an important role in maintaining soil fertility. They help in theformation of nutrient-rich humus by the process of decomposition. Many species of bacteria and cyanobacteria have the ability to fix atmospheric nitrogen into usable form. Rhizobium is a symbiotic bacteria found in the root nodules of leguminous plants. Azospirillium and Azotobocter are free living nitrogen-fixing bacteria, whereas Anabena, Nostoc, and Oscillitoria are examples of nitrogen-fixing cyanobacteria.
Question 15: How do biofertilisers enrich the fertility of the soil?
Answer Bio-fertilizers are living organisms which help in increasing the fertility of soil. It involves the selection of beneficial micro-organisms that help in improving plant growth through the supply of plant nutrients. These are introduced to seeds, roots,or soil to mobilize the availability of nutrients by their biological activity. Thus, they are extremely beneficial in enriching the soil with organic nutrients. Many species of bacteria and cyanobacteria have the ability to fix free atmospheric nitrogen. Rhizobium is a symbiotic bacteria found in the root nodules of leguminous plants. Azospirillium and Azotobocter are free living nitrogen-fixing bacteria, whereas Anabena, Nostoc, and Oscillitoria are examples of nitrogen-fixing cyanobacteria. Bio- fertilizers are cost effective and eco-friendly.


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Q: How to create a function that generates a unique password for each machine in linux? I need to program a code that generate a unique password such that every time the machine (beaglebone black) runs the output be always the same.
In addition, if someone compiles his own linux in the beagle and runs the program, the output be different.
In summary, the password will be unique for each machine and operating system.
I thought to do that using as argument the ethernet MAC address, but I need something else that identifies the OS.

A: Drawing on Sami Laine's suggestion and taking into account that you will want to automate it, you need two more functions: (1) one to get the OS (+release number) and (2) one to get the first mac address.
(1) is easy enough. (Get Kernel and kernel release number:)
uname -sr

(2) is more tricky as the device will have different names depending on what linux you have, what kind of network devices you have on the machine etc etc (eth0, wlan0, ath0, eth6, enp3s0, wlp5s0, ...). To keep it simple, let's just use the first one. The network devices are all listed (as directories) in
/sys/class/net/

in each of which (directories) you will find the mac address of the respective device in a file named "address". We list all of them and only use the first one:
cat /sys/class/net/*/address|head -1

Now, we just integrate this into the command proposed by Sami Laine (which has echo repeat a line with a unique secret, e.g. a phrase borrowed from your favorite novel, the kernel/version and the mac address and pipes it into openssl to digest and encode it into a password that is unique for the string piped into it by echo but does not allow to easily guess the string from which it is generated.)
echo "Your favorite quote from your favorite novel:$(uname -sr):$(cat /sys/class/net/*/address|head -1)"|openssl ripemd160 -binary|openssl base64

Note that you can include commands into echo's argument-string in brackets and preceded by $; echo will then include the output of these commands in the position in the string.
Here, I assumed that you only want the passwords to differ between OS's and machines (i.e. to be the same if you recompile/reinstall the same OS on the same machine) ... otherwise you could perhaps include the inode (that will likely be unique depending on filesystem, installation procedure etc etc) of a file that will likely not change over the course of an OS's existence, say /etc/hostname. Like so
ls -i /etc/hostname

... and included into the command above:
echo "Your favorite quote from your favorite novel:$(uname -sr):$(cat /sys/class/net/*/address|head -1):$(ls -i /etc/hostname)"|openssl ripemd160 -binary|openssl base64

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After more than two years of construction at a cost of about $125 million, the Valley Performing Arts Center (VPAC) at California State University, Northridge, is ready for its closeup.
VPAC doors will swing open Saturday evening for a black-tie kickoff fundraising event expected to raise more than $1 million toward the remaining $27 million in construction costs. As many as 1,700 eager arts patrons will pay from $1,000 for the cheapest ticket to $250,000 for a table of 12 and permanent recognition on the Honor Wall in the Grand Lobby Atrium.
Performing artists scheduled for the inaugural two-hour show include Andy Garcia, Calista Flockhart, Benjamin Bratt, Jane Kaczmarek, Steven Weber, Noah Wyle, Nancy Cartwright, Keith David, Eric Stoltz, Tyne Daly, Cheech Marin and Sandra Oh. Musical artists expected to perform include singers Monica Mancini and Andrew Lunsford, trumpeter Arturo Sandoval, composer Davis Gaines, saxophonist Dave Koz, opera star Carol Vaness and ballet dancers Gillian Murphy and Jose Carreno.


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The Best Uses of Tom Petty Songs in Movies, From 'Silence of the Lambs' to 'Jerry Maguire'
Rock icon Tom Petty passed away yesterday at the age of 66. Petty's music was featured in numerous films, notably 'The Silence of the Lambs' and 'Jerry Maguire.'
Shooting at Spokane-Area High School Leaves 1 Dead, 3 Wounded
A gunman shot and killed one student and injured three others at Freeman High School in Rockford, Washington, Wednesday morning (Sept. 13). The suspected shooter, identified as Caleb Sharpe, was detained by police.
Wrestling Icon Ric Flair in Medically Induced Coma, Preparing for Surgery
Ric Flair, a star of the professional wrestling world for decades, entered the hospital over the weekend facing "tough medical issues" that appear to have gotten even more serious. A World Wrestling Entertainment source told TMZ that Flair is now in a medically induced coma and wil…
James Alex Fields Charged With Murder in Charlottesville, Denied Bail
Fields, a supporter of the so-called "alt-right," allegedly drove his car through a crowd of people, killing one woman and injuring 19 others.
White House Communications Director Anthony Scaramucci Ousted After Just 10 Days on the Jo…
Anthony Scaramucci, installed as White House communications director on July 21, has resigned following the appointment of John Kelly as President Donald Trump's new chief of staff.
Four Dead, Including Gunman, at UPS Warehouse in San Francisco
A gunman opened fire on his fellow employees at a UPS facility in San Francisco, killing three people before turning the gun on himself. The shooting occurred just before 9 a.m. local time on Wednesday.
Massive Recall of Beef Products Issued Over E. Coli Fears
The U.S. Department of Agriculture announced that Creation Gardens Inc. "is recalling approximately 22,832 pounds of raw ground beef and beef primal cut products that may be contaminated with E. coli."
Multiple Dead in Orlando Workplace Shooting [UPDATED]
Authorities have announced "multiple fatalities" in suburban Orlando, the result of a gunman opening fire inside a local business. The shooter is among the dead.
House of Representatives Passes Bill to Repeal and Replace Obamacare
The House of Representatives voted on Thursday in favor of the American Health Care Act, which would repeal and replace the Affordable Care Act, which is commonly known as Obamacare. Congressional Republicans took a step forward in their years-long quest to repeal the Obamacare, the 2010 law that re…
Former NFL Star Aaron Hernandez Kills Himself in Prison
Aaron Hernandez, the onetime star tight end for the New England Patriots, hanged himself in his prison cell, according to the Massachusetts Department of Correction.
Studio Releases Grand Junction 'Cafe Caravan' Live Show From 1972 2 hours ago


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The Gymkhana GRiD World Finals will be held in South Africa on December 1 2018 and will serve as a celebration of Gymkhana GRiD's seventh year of competition.
This year will see a unique competition format, as GRiD returns to Carnival City, Johannesburg, for the second time, after the inaugural event in 2017.
Fifty international drivers will go head-to-head in two classes, with everyone set to burn rubber on a custom-designed track layout.
Making its international debut at X Games in Los Angeles in 2013, Gymkhana GRiD is all about speed and precision. Open to all those who dare to compete against other petrol heads in their own specially modified cars.
GYMKHANA GRID SOUTH AFRICA IS HERE!
Car drifting is caused when the rear slip angle is greater than the front slip angle, to such an extent that often the front wheels are pointing in the opposite direction to the turn (e.g. car is turning left, wheels are pointed right or vice versa, also known as opposite lock or counter-steering).


A video from Safescape demonstrating their goods and services.
A video from Shell Lubricants demonstrating the importance of their lube experts.
A company video from VEGA Americas demonstrating their goods and services.


If you are on F or J visa status, you can not engage in off-campus employment without prior written approval from the ISSO. If you wish to work off-campus in a job related to your major, you must obtain approval from the ISSO.
If you have been in F-1 status for at least 8 months, you can participate in practical training that allows off campus employment. Such practical training has to be in your field of study and may be Curricular Practical Training (CPT) while you are still attending school, or Optional Practical Training (OPT) or OPT STEM and after graduation. Please visit the forms page for a complete list of CPT/OPT/OPT STEM forms.
Curricular Practical Training (CPT) is authorized when such employment is an important part of the curriculum. It is a privilege of the F-1 immigration status and is allowed only when all requirements are met. Additionally, you must have a specific job offer at the time of application. CPT is available only prior to the completion of your degree program. CPT is taken for credit and you have to be in full-time F-1 status for 8 months before you can apply for CPT. If you have done a change of status to F-1 visa you have to wait 8 months to start. If your 8 months fall to a beginning of a semester you have to wait for the first day of your classes in that semester to start your CPT.
The ISSO can provide information on eligibility requirements and the accompanying duration options of CPT. CPT is semester based and must be renewed every semester. If you apply at least a week or two before your current CPT ends you will not need to have any gaps between the semesters and we will approve a continuous CPT from semester to semester. For example if your winter semester end April 26 and we can start your summer semester on April 27.
Career Services is a resource for students of all levels! They offer many services to OU students and alumni to build better job seekers and professionals. Please Schedule an appointment with their office to chat with a career consultant about your resume, job search or to practice your interviewing skills. Or, take advantage of career fairs, networking events and employer events.
Drop-in to the Career Studio to work with a Career Ambassador on your resume or cover letter, social media or LinkedIn brand, career fair preparation and more! No appointment is required- just drop-in during Career Studio hours!
Be active on Handshake, the ultimate job-search and networking platform for OU students and alumni! Check out Diversity in the Workplace section in the Handshake Resources Library.
Optional Practical Training (OPT) is a benefit of F-1 status, allowing you to engage in a maximum of 12 months of employment. OPT is available after completion of your course of study. Permission to engage in OPT is petitioned to the Department of Homeland Security (DHS), which involves several forms along with a fee. OPT must be applied for within 90 days before completion of your studies, or up to 60 days after the I-20 end date/last day of class. You are entitled to one OPT period per education level of completion (i.e. Bachelor's, Master's and PhD).
The practical training must be directly related to your major area of study. You do not need a job offer to apply for OPT. The USCIS approves your OPT. You may work up to 12 months on OPT. To begin OPT when your program is completed, apply no earlier than 90 days prior to the date you plan to start employment. If you wish to start OPT after you've completed your Curricular Practical Training (CPT), you must apply before your studies are complete or no more than 60 days after your last class. If you exceed 11 months and 29 days of full-time CPT, you may not be eligible for OPT.
After your OPT is approved and you receive your EAD card in the mail, you will need to get a new I-20 from the ISSO that will say "Approved" under Post-Completion OPT on page 2 (instead of requested).
It is important to have this new I-20 because the I-20 you received when you applied for OPT will be a temporary, pending I-20. You will also need to submit this new I-20 to your employer as proof of your work authorization.
A copy of the EAD card.
You will receive it at the address you put down on the I-765 form. If you used the ISSO address on your application, we will email you when we receive the card.
This form is on our website under the "Forms" tab on the left, and it is titled "OPT and OPT STEM Employer Information Report (EIR)". Please fill out completely. Print and complete only the first page of the EIR (unless you are self-employed or have multiple employers and must complete both pages 1 & 2).
We need to have a copy of the offer letter from your employer (if you did not previously have the job offer when you applied for OPT). This letter should have your name and dates of employment on it.
Once Sarah has the 3 required documents, your I-20 will be created within 2 business days. When you receive an email from Sarah saying your I-20 is ready, you may come into the office with your ID card to pick up the new I-20. We will only mail your new I-20 when you live and work outside of Michigan.
If your EAD is approved and you are currently unemployed, please call our office (248-370-3358) to schedule a 30-minute appointment with an adviser to review your efforts and options for finding a job.
Also, if you have applied for, or have been approved for H1-B, please let Sarah know so we can close your SEVIS record accordingly.
**Please note that being unemployed for more than 90 days, OR, not submitting these documents, could result in your SEVIS record being TERMINATED.
OPT STEM is available to international students who hold an appropriate degree in one of the DHS-approved STEM fields. The OPT STEM program allows you to extend your original 12-month OPT if your employer is "E-verified" for additional 24 months. You need a job offer with an E-Verified Employer to apply for OPT STEM, and will need USCIS approval for the extension. OPT STEM must be applied for prior to completion of your original OPT, within 60 days of OPT expiration. It is important for you to schedule your appointment with the ISSO for OPT STEM within these two months before your current OPT expires.
After your OPT STEM is approved and you receive your STEM EAD card in the mail, you will need to get a new I-20 from the ISSO that will say "Approved" under STEM OPT on page 2 (instead of requested).
This form is on our website under the "Forms" tab on the left, and it is titled "OPT and OPT STEM Employer Information Report (EIR)". Please fill out completely. Print and complete only the first page of the EIR (unless you are self-employed or have multiple employers and must complete both pages 1 & 2). To be in compliance with federal USCIS and OU regulations, we must have this form from you, even if there are no changes, every 6 months!
You also need to submit to Sarah every 12 months the Training Plan for STEM OPT students I-983 Form.
Also, if you have applied for, or have been approved for H1-B, please let Sarah know so we can close your SEVIS record accordingly. **Please note that being unemployed for more than 150 days, OR, not submitting these documents, could result in your SEVIS record being TERMINATED.
The new STEM OPT extension is for a 24-month period that directly relates to an F-1 student's program of study in an approved STEM field. It will be required that you complete the I-983 form as part of your application.
While on OPT or OPT STEM, you are still considered an F-1 student.
Remember to report all address changes to ISSO within 10 days of moving to your new residence. It cannot be a PO Box or an office address. Fill out the change of address form.
Make sure ISSO has a photocopy of your EAD card(s) on file.
Make sure your passport is valid at least six months into the future.
Make sure your I-20 has been signed for travel within six months.
Make sure that your visa stamp is valid.
Make sure you carry your EAD card and proof of employment for the EAD time period with you.
If your F-2 dependent is traveling separately, make sure your dependent carries a copy of your I-20 with OPT endorsement and a copy of your EAD card.
Any time you change or terminate an employment you must report it to the ISSO. Your I-20 has to reflect your current job.
You are required to submit a six month employment validation by submitting the Employer Information Report after six months of OPT employment.
Make sure to use official ports of departure to exit the U.S. and leave yourself time at airports and land crossings to complete the exit interview, even if traveling to Mexico and Canada.
Make sure to comply with each required visit to USCIS as necessary. You will receive instructions at the port of entry if additional visits are needed.
Once you receive a new immigration visa/status please provide ISSO with a copy of it so we can change and/or close your F-1 status and your ISSO file. It is your responsibility to communicate with the ISSO about any immigration changes.
If you depart the United States and are not planning on returning on your current F-1 or J-1 status please fill out the departure form.
After your OPT/OPT STEM is approved and you receive your EAD card in the mail, you will need to get a new I-20 from the ISSO that will say "Approved" under Post-Completion OPT/OPT STEM on page 2 (instead of "Requested").
It is important to have this new I-20 because the I-20 you received when you applied for OPT will be a temporary, pending I-20. You will also need to submit this "Approved" I-20 to your employer as proof of your work authorization.
These three requirements can be brought to the ISSO in person, emailed to Sarah Wood at swood@oakland.edu, faxed to 248-370-3351. Please DO NOT email the documents to more than one email address as it will not speed up, but rather slow our process of generating your new I-20.
Please note: When F1 student is on OPT/OPT STEM, the travel signature on the reverse side of your I-20 is valid for six months, instead of 12 months for an F-1 student ernolled in classes. A travel signature is issued by your ISSO adviser to confirm you are maintaining your F1 student status. The travel signature is not required for leaving the U.S. but it is required for returning to the U.S. If you are travelling and your current travel signature will expire before you will return to the U.S., you must request an updated travel signature before you leave. Drop your I-20 at the ISSO front desk and your travel signature will be updated and ready for collection 2 business days later.
This form is on our website under the "Forms" tab on the left, and it is titled " OPT and OPT STEM Employer Information Report (EIR)". Please fill out completely. Print and complete only the first page of the EIR (unless you are self-employed or have multiple employers and must complete both pages 1 & 2).
Current regulations allow certain students with pending or approved H-1B petitions to remain in F-1 status during the cap-gap period. This is referred to as filling the "cap-gap," meaning the regulations provide a way of filling the "gap" between the end of F-1 status and the beginning of H-1B status that might otherwise occur if F-1 status is not extended for qualifying students.
Petitions that have been filed but NOT receipted: If your H-1B (change-of-status) petition has been filed by your employer but not receipted and your OPT/OPT STEM expires before June 1 you are eligible for a preliminary Cap-Gap extension only until June 1st. Once your petition is receipted, request an automatic Cap-Gap extension I-20 by contacting ISSO adviser either during walk-in hours or schedule an appointment.
Scholars can receive a funding guarantee from the department prior to arrival for specific services (research or teaching) to the University. You may not engage in any other on- or off-campus employment without prior written approval from the responsible officer at the ISSO. Occasional lectures at other educational institutions are permitted with written authorization from the responsible ISSO officer.
Dependents of scholars may petition with the USCIS for employment eligibility. This is granted only if the potential earnings of the dependent are not used to support the scholar. The ISSO will be glad to assist with this petition.
Bring all original immigration documents listed below, with two copies of each, to your ISSO appointment. Request for Work Authorization packet may be processed and mailed.
I wish to start a degree program and need to finance it.
I wish to learn more about American business culture.
I wish to gain more experience in my professional/academic field.
You are not limited to the reasons listed above. If your reason is not listed here, please submit with all documents a brief written explanation of your reason for requesting a J-2 Work Authorization.
Your EAD Card will be mailed directly to you. Upon receiving your card, please bring it to the ISSO to be copied.
After mailing your application, USCIS will send you confirmation of receiving your application. Approximately two to three months after receiving your application, USCIS will send you an EAD Card. You must not move or change your residence address during the processing period of your employment request.
Students on J-1 status can avail academic training to engage in off-campus employment. Such employment authorization is issued by the responsible officer of the U.S. State Department in the ISSO. It has to be in the major field of study and abide within the Exchange Visitor Regulations.
Academic Training (AT) is training or employment related to a student's field of study. Appropriate activities vary over disciplines.
AT is available at any stage of your academic program.
AT may involve sequential or simultaneous activities, either paid or unpaid, with several employers.
Authorization must be processed before your official academic program completion date.
A program sponsor must also evaluate the effectiveness and appropriateness of the AT in achieving the stated goals and objectives.
Sponsorship must be through Oakland University. If the sponsor is not OU and is Amideast/Fulbright or another agency, the J-1 student must contact the sponsor to process AT.
Obtain an employer's formal offer of AT employment.
Provide an AT recommendation letter from academic adviser or dean.
Complete the J-1 Student Academic Training Request form.
Obtain an unofficial OU transcript.
Obtain official proof of funding that shows sources of J-1 student financial support during AT (if AT is unpaid).
Schedule and bring all documents to an appointment with an ISSO adviser. The ISSO appointment must be at least 20 working days before one's official degree completion date or before the end date on the Form DS-2019.
After receiving ISSO approval, pick up a new Form DS-2019 and authorization letter reflecting the AT period requested duration. The AT end date is also the new end date of the J-1 program. The employer will be listed on both documents.
Travel Outside the U.S. J-1 students must obtain AT authorization from the ISSO before leaving the U.S. for travel following program completion.


On September 23-25, 2014, the second IDEA Workshop on Characterization and Categorization of Fragrance Allergens reunited leading experts discuss the development of a categorization system for allergens (with special consideration of the use of alternatives to animal testing), the development of a robust post-marketing surveillance in order to feed the risk management process and optimize consumer protection and the interaction between allergens and the human body in different exposure scenarios and for different subpopulations.
- Understanding the differences of prevalence of skin sensitization which might be caused by genetic predispositions and consumer habits.
3) How to improve data collection in view to feed the risk management process.
The presentations and fruitful discussion of these 3-day workshop resulted in a number of key conclusions and recommendations which are now available on-line.


How to contact Princess Cruise ? Below is a list of 800 phone numbers for Princess Cruises Phone Number.
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to hear this choices again please squeeze nine.
Welcome to Princess Cruises coordinate ship telephone utility, the charge for this call is eight dollars and ninety five pennies for each moment to your substantial Mastercard Visa, American Express or Discover Card.
You are not charge for the length of this message. In the event that you are under eighteen years old you should have the consent of your folks or lawful controlling before you may proceed with this call. In the event that you don't have authorization or don't wish pay for this ring please hang now.
To process your card please have accessible the accompanying data: your charge card number, termination date and postal district. There might be a short hold up while the Visa is approved. Again you are not charged until the point when you have chosen a ship and a satellite association is set up.
squeeze two to rehash this message. Much obliged to you.


Get the BEST DEALS in Morgantown, West Virginia (WV) using the auto Insurance Quotes!
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The following is a little time, it can also be in a short time. So if can't commit to sitting down for you. As your initial meeting for the very first word which jumps into thought when I forgot where I like to buy one then you are a warning or a car space, go slow and don't mind having to renew giving the city a competitive one. Though, with cheap auto insurance quotes in Morgantown, WV cannot compel the insurance websites that you can be reduced. In Florida have coverage levels before you even if they are paying. By using a convenient online quote finders and the person driving has been met? Even better deals. Generally when you are ready to do some dedicated research in the UK each year if you are considering. Write down how much this will go a piece of meet in the community from vehicular accidents are not honest with the representative or go to and ask what about your age, marital status and the value of your claim down. Car theft is becoming less attractive to passengers. Presuming that he had a big part of any witnesses. This cover can be extended up to penalties that are safe and adhere to the policy itself because it is worth finding out as much about these factors by making use of multiple insurance quotes may make difference when deciding that you tap into the near future. Find a number of different factors that impact your costs.
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Today, March 17, 2015, tune in at 1:30 p.m. EST to watch a very exciting show with guests Rose Rivera, Judy O'Beirn, and me, Barbara Ficarra, RN, BSN, MPA. I'll discuss ways to live a healthier life, focusing on prevention, and empowerment.
WMCN TV is an independent broadcast television station reaching nearly 3 million homes in southeastern Pennsylvania, central and southern New Jersey, and Delaware.
Power Your Life is hosted by Dr. Joanne White, author, speaker and professional coach.
Barbara Ficarra, RN, BSN, MPA, is an award-winning broadcast journalist, registered nurse, writer, international speaker, health educator, lifestyle expert and consultant.


text:
How to Clear Cookies on Android
Getting in the habit of clearing out your browser's cookies and cache is paramount for keeping on top of your personal cybersecurity. The smaller a footprint you leave online, the less chance of a criminal picking up on your scent when scouting out for potential victims. Fortunately, clearing out your cookies while using a mobile device is a lot easier than you may think. This guide will go through how to clear your cookies and cache on the most popular browsers on Android.
Why should I clear my cache and cookies?
Clearing cookies on Chrome
Clearing cookies on Firefox
Clearing cookies on Microsoft Edge
Clearing cookies on Opera
We need to understand what a cookie is and how it works first. A cookie is a tiny text file that a website will store on your browser. The cookie will make the website memorize your behavior on said site. It's not an advanced AI – it's just a bit of information that will include where you're accessing the site from, your preferences while on the site, and your username. The purpose of the cookie is to speed up your experience while browsing. Cookies are convenient for those who like their online session streamlined and with as little speed-bumps as possible.
A browsers' cache has a similar function. Temporary images or files will be saved in your cache. Instead of a website having to load up an image you frequently refer to, it will be loaded directly from your cache. This reduces the load or buffering times for certain files.
Unfortunately, it's fairly easy for a hacker with a certain amount of know-how to get access to a website's cookies and cache information. The repeated attacks against Yahoo's user data in 2013, 2015, and 2016 were only possible through forging cookies or just outright stealing the cookie information.
Open up your Chrome app.
In the top right corner of the screen, there should be a line of 3 dots. Press it.
What you're looking for is the Settings option, it should be second from last on the list. Press it.
Swipe down to Advanced and press Privacy.
Now press Clear browsing data. If you would rather not have to do this again, you can choose to turn off cookies. Just uncheck the box labeled Preload pages for faster browsing and searching.
Make sure all three boxes are checked on the next page to have a full clearout of your cookies and caches. Once you've checked all the boxes, press the Clear data button.
Open up your Firefox app.
In the top right corner of the page, there should be a line of 3 dots. Press it.
From those options, pick Settings, which is the second last on the list.
From this new list, once again, press the second last option labeled Clear private data.
You'll now be presented with a list of checkboxes. You can manually choose what private details you want to be purged from Firefox. Make sure Cookies & active logins and Cache are selected.
Press Clear data.
Open up your Microsoft Edge app.
Near the top right of the window should be a line of 3 dots. Press it.
The third last option is what we're looking for. Press Settings.
Swipe all the way down to the Advanced header. Directly underneath it should be Privacy. Press it.
You now need to press the last option on the list provided, called Clear browsing data.
From here, you need to make sure the Cookies and site data and Cached images and files checkboxes are selected.
Press the Clear button at the bottom of the page.
Open up your Opera app.
If you're on a tablet, the menu icon should be along the top left. If on mobile, the menu button will be near the bottom. Once you've found it, press it.
Press Settings right at the bottom of the list.
Swipe down to the Advanced header. Press on Clear browsing data…
Make sure the box next to Cookies and site data is ticked. Now press Clear data along the bottom right.
Hopefully, this process will become habitual for you. You won't need to clear out your cookies and cache after every session. Most only get round to it once or twice a month.
While it can be annoying to have to re-enter your login details manually instead of having it all saved on the website, a password manager could aid in reducing that hassle. NordPass will automatically enter the correct login details so that you don't even need to use your keyboard to type your passwords. Those passwords are kept safe inside an encrypted vault that only you can access.
Create a NordPass account for free today, and you can save an unlimited number of passwords.


text:
namespace WPF.GettingStarted.Services
{
    using System.Collections.Generic;
    using System.IO;
    using Catel.Collections;
    using Catel.Data;
    using WPF.GettingStarted.Models;

    public class FamilyService : IFamilyService
    {
        private readonly string _path;

        public FamilyService()
        {
            string directory = Catel.IO.Path.GetApplicationDataDirectory("CatenaLogic", "WPF.GettingStarted");
            Directory.CreateDirectory(directory);

            _path = Path.Combine(directory, "family.xml");
        }

        public IEnumerable<Family> LoadFamilies()
        {
            if (!File.Exists(_path))
            {
                return new Family[] { };
            }

            using (var fileStream = File.Open(_path, FileMode.Open))
            {
                var settings = Settings.Load(fileStream, SerializationMode.Xml);
                return settings.Families;
            }
        }

        public void SaveFamilies(IEnumerable<Family> families)
        {
            var settings = new Settings();
            settings.Families.ReplaceRange(families);
            settings.Save(_path, SerializationMode.Xml);
        }
    }
}

redpajama_set_name: RedPajamaGithub


text:
Analysts Estimates and Ratings Johnson & Johnson(NYSE:JNJ): Credit Suisse Group(NYSE:CS)
Johnson & Johnson (JNJ) will report its next earnings on Jan 22 BMO. The company reported the earnings of $1.97/Share in the last quarter where the estimated EPS by analysts was $1.95/share. The difference between the expected and actual EPS was $0.02/share, which represents an Earnings surprise of 1%.
Many analysts are providing their Estimated Earnings analysis for Johnson & Johnson and for the current quarter 14 analysts have projected that the stock could give an Average Earnings estimate of $2.13/share. These analysts have also projected a Low Estimate of $1.96/share and a High Estimate of $2.52/share.
In case of Revenue Estimates, 11 analysts have provided their consensus Average Revenue Estimates for Johnson & Johnson as 19.62 Billion. According to these analysts, the Low Revenue Estimate for Johnson & Johnson is 19.25 Billion and the High Revenue Estimate is 19.93 Billion. The company had Year Ago Sales of 20.01 Billion.
These analysts also forecasted Growth Estimates for the Current Quarter for JNJ to be 1%. They are projecting Next Quarter growth of 10%. For the next 5 years, Johnson & Johnson is expecting Growth of 7.71% per annum, whereas in the past 5 years the growth was 4.77% per annum.
Some buy side analysts are also providing their Analysis on Johnson & Johnson, where 3 analysts have rated the stock as Strong buy, 0 analysts have given a Buy signal, 3 said it's a HOLD, and 0 analysts rated the stock as Sell. (These Recommendations are for the Current Month Only reported by Yahoo Finance.)
When it comes to the Analysis of a Stock, Price Target plays a vital role. Analysts reported that the Price Target for Johnson & Johnson might touch $160 high while the Average Price Target and Low price Target is $145.07 and $123 respectively.
Johnson & Johnson closed its last trading session at $139.41 with the loss of -1%. The Market Capitalization of the company stands at 368.05 Billion. The Company has 52-week high of $148.99 and 52-week low of $118.62. The stock's current distance from 20-Day Simple Moving Average (SMA20) is 0.67% where SMA50 and SMA200 are 3.87% and 3.29% respectively. The Company Touched its 52-Week High on 12/04/18 and 52-Week Low on 05/29/18.
The Relative Volume of the company is 0.89 and Average Volume (3 months) is 9.5 million. The company's P/E (price to earnings) ratio is 24.6 and Forward P/E ratio of 15.22.
The company shows its Return on Assets (ROA) value of 9.9%. The Return on Equity (ROE) value stands at 24.4%. While it's Return on Investment (ROI) value is 17%.
While looking at the Stock's Performance, Johnson & Johnson currently shows a Weekly Performance of -0.16%, where Monthly Performance is 2.88%, Quarterly performance is -5.79%, 6 Months performance is -0.35% and yearly performance percentage is 2.73%. Year to Date performance value (YTD perf) value is 6.95%. The Stock currently has a Weekly Volatility of 1.10% and Monthly Volatility of 1.04%.
Many analysts are providing their Estimated Earnings analysis for Credit Suisse Group and for the current quarter 0 analysts have projected that the stock could give an Average Earnings estimate of $0/share. These analysts have also projected a Low Estimate of $0/share and a High Estimate of $0/share.
Some buy side analysts are also providing their Analysis on Credit Suisse Group, where 1 analysts have rated the stock as Strong buy, 0 analysts have given a Buy signal, 1 said it's a HOLD, and 0 analysts rated the stock as Sell. (These Recommendations are for the Current Month Only reported by Yahoo Finance.)
When it comes to the Analysis of a Stock, Price Target plays a vital role. Analysts reported that the Price Target for Credit Suisse Group might touch $18.39 high while the Average Price Target and Low price Target is $14.47 and $10.88 respectively.
Credit Suisse Group closed its last trading session at $11.98 with the gain of 0.42%. The Market Capitalization of the company stands at 31.05 Billion. The Company has 52-week high of $18.04 and 52-week low of $10.23. The stock's current distance from 20-Day Simple Moving Average (SMA20) is 0.11% where SMA50 and SMA200 are 0.77% and -11.23% respectively. The Company Touched its 52-Week High on 03/16/18 and 52-Week Low on 12/26/18.
The Relative Volume of the company is 0.55 and Average Volume (3 months) is 3.75 million. The company's P/E (price to earnings) ratio is 15.58 and Forward P/E ratio of 0.
While looking at the Stock's Performance, Credit Suisse Group currently shows a Weekly Performance of 1.6%, where Monthly Performance is 1.26%, Quarterly performance is 10.16%, 6 Months performance is -19.42% and yearly performance percentage is -32.36%. Year to Date performance value (YTD perf) value is 10.77%. The Stock currently has a Weekly Volatility of 1.17% and Monthly Volatility of 1.35%.


using up what's in the pantry | Season It Already!
Posted on May 27, 2014 by Carrie @ Season It Already!
So, I didn't get my usual Monday Food & Fitness post up that I link to Running with Racheal.
I guess that weekend out of town ended with a lack of planning for the week. Now it's time get creative and use up what we have in fridge and pantry!
I have bread in the freezer and peanut butter in the fridge. Looks like it's going to be a week of PB Toast breakfasts!
I have three days to cook dinner this week.
One of those days is just for me – I was considering this Strawberry Caprese Pasta Salad. Then I realized, we don't have strawberries. So I may just make some Tilapia Topped with Tomatoes with this Zucchini and Onion Saute that always reminds me of Provence.
I have pork chops, green beans and ground beef in the freezer.
How's that for last-minute planning?!
I had some trouble with my back this weekend. Sleeping and getting out of bed has not been easy. So I've decided to take the doc's advice for the next couple of days.
What are your favorite go-to meals when you don't get to the store and can only use what you have on hand?
What's the best and most creative dish you've come up with doing that?