text:
Q: Buscar valores de ListView customizado Tenho o seguinte ListView que foi gerado com um adapter customizado:

Gostaria de saber como buscar os valores (data, hora, historico, id, etc) do item com o setOnItemLongClickListener, pois preciso desses valores (ou ao menos o valor do id do item) para pesquisar no SQLite e abrir em outra tela para edição.
Até o momento testei da seguinte forma, mas só me trás a posição do item na lista:
this.ltvRegistros.setOnItemLongClickListener(new AdapterView.OnItemLongClickListener() {
            @Override
            public boolean onItemLongClick(final AdapterView<?> parent, final View view, final int position, long id) {
                AlertDialog.Builder dialog = new AlertDialog.Builder(Main.this);
                dialog.setTitle("Editar");
                dialog.setMessage("Deseja editar o item ?");
                dialog.setPositiveButton("Sim", new DialogInterface.OnClickListener() {
                    @Override
                    public void onClick(DialogInterface dialog, int which) {
                        CRegistros item = (CRegistros) ltvRegistros.getAdapter().getItem(position);
                        Toast.makeText(Main.this, "Registro " + item.get_Id().toString() + " apagado !", Toast.LENGTH_SHORT).show();
                        DBController ct = new DBController(getBaseContext());
                        ct.buscaRegistro(id);
                    }
                });
                dialog.setNegativeButton("Não", null);
                dialog.show();
                return true;
            }
        });

A: Resolvido. Falha minha.
Estou puxando o item.get_Id() mas a activity que eu estava puxando não tem o campo associando id.
Fiz a associação e deu certo.
As vezes só de repassarmos os passos para descrever em uma pergunta, acabamos descobrindo por si só.
Irei deixar a pergunta como arquivo caso ajude um próximo.
Me desculpem.

redpajama_set_name: RedPajamaStackExchange


← "Finding Allison" now live!
I counted up my rejections that I've been tracking since 2001. Yeah, 263. That's a big number. I finally feel like I'm making some headway, though, and my newer work is also my best. Looking forward to a productive 2008.


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moody preteen | Yay! More Gray!
Please Universe, Send Me Some Acceptance!
So I've been doing a lot of digging around the Interwebs looking for writing submission and freelance writing sites. I've been responding to a lot of ads. My traffic here on WordPress is increasing, because my website traffic is increasing and they're all coming here. I'm getting more followers. It seems that should be good enough to prove that people want to read what I write. But I guess it's that no one seems to think that what I write is good enough to want to pay me for.
And it's not just in my writing where I'm feeling rejected, it's with Peanut too. She barely seems to want to have anything to do with me lately unless it involves spending my money or driving her somewhere. Where did my sweet girl go who loved me and wanted to be with me just because?
I was thinking why do I keep trying to write a book and get freelance jobs to leave the 9-5? Why do I keep trying to be pleasant in the face of the hormone monster who just wants to bite my head off without reason? I started another post about rejection and then got discouraged and deleted it thinking no one would care. It's just all too much lately. I just need one thing to show me it's worth it, that my dreams will come true.
Wow, great timing Universe! I put that in the "sticky note" app on my phone so I will be motivated to keep trying. Just one more time….


Ahh…lunch is always good. Last time I covered what I do in the morning .
My afternoon starts with cooking. I used to cook more but now I either eat lightly or some leftover food. This saves me time and enables me to take nap.
I eat usually in front of the computer unless I am eating lunch with someone. This is bad. In fact, there is a famous book about networking called Never Eat Alone. Basically, you should always use your chances to network. But as a PhD student doing lot of research that will be on the to-do list.
I don't eat a lot at lunch because I become sleepy and that is not good for productivity. After I eat, I walk a bit or do some house choirs so I don't fall asleep. I then make coffee!! It is so exciting to grind the beans and waiting to inhale the dark research fuel.
I enjoy the coffee by either reading a book or reading things online. This lasts about 10-20 minutes. Ah, my golden time.
After coffee, it is back to work. It is hard to concentrate because you sort of relax after lunch so I usually do some data cleaning or light reading on stuff related to my research.
By now an hour has passed and my brain is ready for round 2. I am not as productive in the morning but I push through. I try to do anything that requires some thinking because at night I know my productivity is quite low. So I work hard for 2-4 hours.
If I am too tired, I take a quick nap. If I am too stressed or can't concentrate, I go to the gym.
It is my hope that I get at least 80% of all the work done by the end of the afternoon but that rarely happens. Well, it may be bad planning but I think because research always gives you more questions then answers.
For instance, after I run a regression. I have question about other control variables and whether I should divide the sample and see how things go in subsamples. So I go on an interesting research expedition, which usually educates me but does not push the research forward that much. But hey, that is the fun of research. Seeing things that are new and not seen by others.
Also, writing takes way more time than what I think. haha…oh boy.


Centre for International and Inter-governmental Studies of the University of Baghdad Thursday, 31st of January 2008.
A round table discussion centred on the issue of terrorism in Iraq and possible solutions to this problem.
Participants of the Symposium ranged from university professors including, Dr. Aziz Jabar Shayal, Dr. Samir Alshweely and Dr. Rasheed Saleh, professors of Political Studies from the University of Baghdad. The Symposium was also attended by many governmental and non-governmental representatives from a wide range of ministries and NGOs, including representatives from Iraq's Ministries of Defence, Human Rights and Security.
Massoud Khodabandeh from the Centre de recherches sur le terrorisme depuis le 11 septembre 2001 (Paris), who was in Baghdad for meetings concerning the fate of the remaining individuals following dismantlement of Camp Ashraf which houses the disarmed Iranian terrorist organisation Mojahedin Khalq Organisation, was invited to participate in the discussion.
The Symposium ended with a full report on the issues discussed and Dr. Aziz Jabar Shayal delivered the end resolution in which one paragraph emphasized the necessity for the dismantlement and deportation of the foreign terrorist Mojahedin Khalq organisation and encouragement and facilitation by the government and others to help the remaining individuals find a safe palace outside Iraq and return to normal life.
Alaraghia television, Iraq's main TV network, reported the Symposium and broadcast a brief interview with Massoud Khodabandeh.
In the interview, Massoud Khodabandeh emphasised above all the right of the Iraqi people to enjoy security and have justice served against the perpetrators of violent acts in their country, in particular the criminal heads of the terrorist Mojahedin-e Khalq organisation which was involved in the massacre of the Kurdish and Shiite uprisings against Saddam Hussein in March 1991. Mr Khodabandeh said that in his belief and according to all the studies of the Centre de Recherches sur le Terrorisme, the phenomenon of terrorism cannot have a single solution and needs inter governmental cooperation as well as the involvement of NGOs to protect the human rights of the who have been inveigled by terrorist leaders into this path, and to give them a second chance of integration back into their societies.
Thanking the organisers of the Symposium Mr Khodabandeh emphasised the cult culture of terrorist organisations and the methods they use to brainwash their followers. He also gave examples of foreign support by some influential groups and parties who facilitate the flow of finance for terrorism. Not the least the relationship between the remainders of Saddam Hussein in Iraq, London, Washington and other countries with the Mojahedin Khalq Organisation, and the way this relationship is becoming clear in the escalation of violence in Diyali province as well as the streets of London and other European countries.
A full report and media coverage will be published shortly.


text:
Op Wimbledon 2022 speelden de rolstoelvrouwen de wedstrijden in het dubbelspel op vrijdag 8 en zondag 10 juli 2022 in de Londense wijk Wimbledon.

Toernooisamenvatting
Van de titelhoudsters Yui Kamiji en Jordanne Whiley had de laatste haar actieve loopbaan beëindigd. Kamiji speelde samen met de Amerikaanse Dana Mathewson.

Het Nederlandse koppel Diede de Groot en Aniek van Koot vormde het eerste reekshoofd. Zij bereikten de finale, waar zij hun meerdere moesten erkennen in Kamiji en Mathewson. Voor de Amerikaanse was het de eerste grandslamtitel in haar loopbaan. De Japanse won al 17 eerdere dubbelspeltitels op de grandslamtoernooien.

De derde Nederlandse, Jiske Griffioen, speelde samen met Momoko Ohtani uit Japan – in de eerste ronde verloren zij van De Groot en Van Koot.

Geplaatste teams

Toernooischema

 Ranglijstpositie dubbelspel tussen haakjes.

Externe links
 Toernooischema Wimbledon
 Actueel toernooischema Wimbledon

Wimbledon
ITF-toernooi in 2022

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FOREIGN INCOME & TAXPAYERS
Cross-border M&As post-TCJA: Three things advisers should know
By Cory Perry, CPA, Washington, D.C., and Eileen Leyhane, CPA, Chicago
C Corporation Income Taxation
NOL & Other Tax Attributes
Foreign Subsidiaries
Editor: Greg A. Fairbanks, J.D., LL.M.
Understanding and identifying tax consequences of complex mergers-and-acquisition (M&A) transactions has never been easy and has become even more fraught following the enactment of the law known as the Tax Cuts and Jobs Act (TCJA), P.L.115-97. The challenges confronting taxpayers entering into M&A transactions are further exacerbated when the transaction encompasses cross-border elements.
Many aspects of the TCJA supplant old paradigms for taxpayers planning or entering into cross-border transactions. Common tools like Sec. 338 elections have not changed in and of themselves, but the ramifications have. Beyond changes to the M&A toolbox, questions also linger following the law changes. The TCJA also added a few new traps that taxpayers must circumvent when navigating M&A transactions. These hazards can significantly affect the structuring of cross-border transactions.
Tax is a critical component of M&A. Beyond risk assessment, tax implications can influence valuation and return on investment. This item highlights three key considerations for a cross-border M&A transaction. It does not provide an exhaustive overview of all considerations but rather provides commentary on these three often overlooked or misunderstood factors potentially disrupting international transactions following the TCJA.
New twists to old Sec. 338(g) elections
A Sec. 338(g) election permits a purchasing corporation to treat a qualified stock purchase as an asset purchase, which allows the buyer to obtain a step-up in basis of the target's assets in what is otherwise treated as a sale of corporate stock. This potentially subjects the seller to two levels of tax. The seller recognizes gain or loss on the sale of target stock, and the target itself recognizes gain or loss on the deemed sale of its assets. For obvious reasons, the election and its two levels of tax have limited utility in the context of domestic entity acquisitions. However, the election is common when the acquisition is a foreign target where taxation at the foreign corporate level may not result in incremental U.S. tax (particularly, although not exclusively, when the seller is also a foreign person).
When a purchaser makes a Sec. 338(g) election, the target entity (Old Foreign Target) is treated as selling all of its assets at the close of the acquisition date. Old Foreign Target is then deemed to be a new corporation (New Foreign Target) that purchases all of Old Foreign Target's assets as of the beginning of the day after the acquisition date. This deemed sale of assets results in a corporate-level gain and corresponding corporate-level tax. Unlike a Sec. 338(h)(10) election, the Sec. 338(g) election is made unilaterally by the buyer and does not require the sellers' consent. An illustration of this deemed fiction is shown in the chart "Sec. 338(g) Elections."
A purchaser making a Sec. 338(g) election obtains numerous benefits in the international context. For federal income tax purposes, a Sec. 338(g) election made on a foreign target results in a step-up in the target's assets' bases, eliminates historic earnings and profits (E&P), and ends the target's tax year. The election also allows a buyer to obtain the benefits of an asset purchase for federal income tax purposes while respecting the form of the transaction as a stock sale for business, legal, and certain non-U.S. tax purposes. This produces several benefits unattainable in a true asset sale, such as the potential preservation of foreign tax attributes.
There are also several consequences. For example, in the case of a controlled foreign corporation (CFC), the election can result in Subpart F and/or global intangible low-taxed income (GILTI) inclusions to a U.S. seller.
The TCJA left the provisions governing the Sec. 338(g) election itself unchanged. However, the TCJA significantly overhauled the international tax system that dictates the outcome of such an election. As a result, taxpayers need to rethink where and when to use the election.
For example, if the seller is a U.S. shareholder in a target that is a CFC, U.S. shareholder-level consequences can result from the deemed asset sale occurring at the foreign target level. Prior to the TCJA, the main concern of a U.S. seller in a CFC was Subpart F income resulting from the deemed asset sale. However, following the TCJA, U.S. sellers are still potentially subject to Subpart F income, but now the election may also generate tested income. The excess of a U.S. shareholder's aggregated net tested income from CFCs over a routine return on certain qualified tangible assets is taxable as GILTI.
Whether a GILTI inclusion has negative or positive effects on the sale of stock depends on several factors. Inclusions under GILTI generally benefit from Sec. 250 deductions, thus often subjecting them to an effective tax rate of 10.5% (any tax liability could be further reduced by foreign tax credits). A GILTI inclusion also creates tax basis that potentially reduces the capital gain on the sale of New Foreign Target stock, which would in turn reduce the capital gain subject to tax at 21%. Any remaining untaxed E&P generated by the deemed sale of assets may be recharacterized as a dividend under Sec. 1248 and may be eligible for a 100% Sec. 245A dividends-received deduction (DRD), reducing the tax on the gain even further.
Still, U.S. sellers should proceed with caution. The outcome may not always be favorable. In instances when Old Foreign Target's inside asset basis is low, the incremental U.S. tax resulting from a GILTI inclusion could outweigh the potential benefit of any reduced capital gain. As a result, U.S. sellers must carefully model the outcome before agreeing to allow the buyer to make the Sec. 338(g) election.
Another aspect of the Sec. 338(g) election that must be considered post-TCJA is how the U.S. buyer intends to exit the investment in the foreign target. Pre-TCJA, the additional amortization and depreciation deduction afforded by the step-up in asset basis was nearly always positive. In particular, additional amortization and depreciation reduced E&P that could be subject to U.S. tax when distributed. However, post-TCJA, reducing E&P and tested income does not always produce the best outcome.
For example, if the election is not made and the foreign target is in a country with a tax rate high enough to eliminate any incremental tax from GILTI inclusions by virtue of foreign tax credits, then the amortization and depreciation deductions could ultimately do more harm than good. This is because without the election, the current-year earnings could be includible in U.S. tax under GILTI and offset by a foreign tax credit. The inclusion creates U.S. tax basis under Sec. 961 (subject to several other issues discussed further below). This tax basis will reduce any future capital gain when exiting the investment. Now, contrast that result with a situation where the election is made, and the GILTI inclusion may be reduced or eliminated. Thus, any potential basis increases under Sec. 961 would in turn also be reduced or eliminated. Further, any potential untaxed E&P that may be recharacterized as a dividend under Sec. 1248 and eligible for a 100% Sec. 245A DRD would also be reduced. This can result in a higher capital gain upon exiting the investment in Foreign Target.
Beyond the items highlighted above, post-TCJA, a number of other pros and cons for either a U.S. buyer or seller with respect to the Sec. 338(g) election must be considered. Many of these are summarized in the table "Pros and Cons of the Sec. 338(g) Election."
The absent basis quandary
Sec. 961 provides general rules for adjusting the basis of a U.S. shareholder's stock in a CFC and the basis of property by which a U.S. shareholder is considered under Sec. 958(a)(2) as owning stock in a CFC (e.g., the basis of a foreign partnership interest through which a CFC is held). Following the TCJA, the rules for adjusting the basis of a U.S. shareholder's stock in a CFC have become even more complicated and murky.
Sec. 961(a) provides for an increase to a U.S. shareholder's basis in stock or property to the extent an amount was included in the shareholder's gross income under Sec. 951(a). A subsequent distribution of previously taxed income would then reduce the shareholder's basis under Sec. 961(b). To the extent an amount distributed exceeds the shareholder's basis in the foreign corporation, the amount received in excess of stock basis would generally be treated as capital gain. Sec. 961(c) provides similar basis adjustments as provided in Secs. 961(a) and (b) with respect to the basis that an upper-tier CFC has in a lower-tier CFC, but only for purposes of determining the amount to be included in a U.S. shareholder's gross income under Sec. 951. No regulations are in effect under Sec. 961(c).
Following the enactment of the TCJA, the transition tax under Sec. 965, as well as the GILTI provisions, have made the determination of a U.S. shareholder's basis in its investments in CFCs more problematic. Both the transition tax and GILTI provisions include coordinating rules that generally provide for the application of the basis-adjustment rules under Secs. 961(a) and (b), but many questions and complications remain.
Current regulations under Sec. 965 provide special rules for adjusting basis following a Sec. 965 inclusion. Under Regs. Sec. 1.965-2(e), a U.S. shareholder's tax basis in a deferred foreign income corporation (DFIC) is increased by income inclusions under Sec. 965(a). The regulations indicate that no basis adjustments are made to account for the reduction to the Sec. 965(a) inclusion due to allocations of deficits under Sec. 965(b) to a DFIC.
However, an election is available that allows the tax basis to be increased in the DFIC if a corresponding reduction of the tax basis of the E&P deficit corporation is made. If this election is made, a U.S. shareholder is allowed basis adjustments only with respect to E&P offset by deficits to the extent of downward basis adjustments made with respect to the stock of an E&P deficit foreign corporation. Absent an action by the taxpayer, no basis adjustments are allowed. Additionally, the basis-shifting election only operates to move basis from first-tier E&P deficit foreign corporations to first-tier DFICs and does not apply down a chain of foreign corporations under Sec. 961(c).
As there are no lower-tier basis adjustments, U.S. sellers must proceed with caution when contemplating transactions within tiered structures. The lack of basis adjustments can present surprising gains when disposing of lower-tier CFCs. The lack of lower-tier basis adjustments also presents risks when contemplating pre- or post-acquisition distributions from lower-tier to upper-tier entities. These distributions could generate unexpected capital gains, which may be includible in the U.S. shareholder's income under Subpart F.
Similar challenges arise with respect to GILTI inclusions. As Sec. 961(c) provides adjustments "only for the purposes of determining the amount included under [Sec.] 951," a sale of a lower-tier subsidiary presents the risk of increased gain recognition treated as tested income, thus potentially causing double taxation. Sec. 961(c) generally operates to prevent double taxation that could result from Subpart F. But it does not indicate that it should operate with respect to GILTI inclusions, leaving taxpayers uncertain when contemplating lower-tier transactions.
For example, if a lower-tier CFC has a Subpart F inclusion, the amount is included in the U.S. shareholder's taxable income. Upon subsequent disposition of the stock, the basis has been increased under Sec. 961(c), thereby reducing the gain by the amount already subject to U.S. tax. However, there currently does not seem to be a similar mechanic for GILTI. How
If the tested income of the lower-tier CFC is included in income of the U.S. shareholder and subjected to U.S. tax, then, absent an adjustment to the upper-tier CFC's basis in the lower-tier CFC stock, the disposition of the stock could create tested income (despite the fact that some of the appreciated value has already been subject to U.S. tax).
The IRS acknowledged this issue in the preamble to the final GILTI regulations (T.D. 9866). But the IRS said it was concerned that by providing for basis adjustments under Sec. 961(c) for GILTI inclusions, such adjustments could inappropriately provide for additional untaxed E&P at the first-tier foreign corporation, which could in turn make any future gain on the upper-tier CFC eligible for a DRD under Sec. 245A. Example 1 illustrates these issues:
Example 1: USP owns CFC1 (fair market value: $100; basis: $0). CFC1 owns CFC2 (fair market value: $100; basis: $0). In year 1, CFC2 earns $100 of tested income, taxable to USP under Sec. 951A. In year 2, CFC1 sells CFC2 for $100. Assume no other income, foreign tax credits, qualified business asset investment, or other attributes, and a full Sec. 250 deduction is permitted to USP.
In year 1, the tested income of CFC2 gives rise to $100 of Sec. 961(c) basis step-up for Sec. 951(a) purposes as a result of the taxable GILTI inclusion. In year 2, CFC1's gain for purposes of computing Subpart F on the sale of CFC2 is reduced by the additional basis provided under Sec. 961(c). However, absent further guidance, there appears to be no similar basis adjustment for purposes of computing tested income of CFC1 in year 2. This implication for the sale of CFC2 is computed as shown in the table "Effects of Sale of CFC2."
Conversely, if a Sec. 961(c) basis adjustment were allowed for purposes of computing tested income, there would be no gain under Sec. 951(a) or Sec. 951A, but the $100 of proceeds would still give rise to an additional $100 of E&P that is untaxed (as there is no basis step-up for E&P purposes, and the earnings were not subject to tax under either the Subpart F or GILTI regime in the year). If, assuming a Sec. 961(c) basis adjustment were allowed for purposes of computing tested income, the implication for the sale of CFC2 is computed as shown in the table "Sale of CFC2 With Sec. 961(c) Basis Adjustment."
Under the first scenario, CFC1 does not incur a gain on the disposition of CFC2 for purposes of computing Subpart F but does incur $100 of gain on the disposition for purpose of computing tested income. Thus, total tax over the two years would be $21 ($100 of tested income of CFC2 subjected to GILTI in year 1 + $100 of tested income of CFC1 generated on the sale of CFC2 in year 2). However, in the second scenario, if a Sec. 961(c) basis adjustment is permitted for purposes of computing tested income, there would be no gain for Subpart F or GILTI purposes in year 2, and the proceeds would give rise to $100 of untaxed E&P. This untaxed E&P would then be eligible for a DRD deduction when ultimately distributed or in the event CFC1 is sold by USP. Therefore, the total tax over the two years would be $10.50 ($100 of tested income of CFC2 subjected to GILTI in year 1). The additional $100 of untaxed E&P would also potentially be eligible for a Sec. 245A DRD either on a future sale of CFC1 stock under Sec. 1248 or on a future dividend distribution out of the untaxed earnings.
However, this raises the question of whether the gain is gross income taken into account under Subpart F first and then reduced by basis adjustments under Sec. 961(c) so that it is excluded under Sec. 951A(c)(2)(A)(i)(II), which provides that any gross income taken into account in determining the Subpart F income of a corporation is excluded from the definition of tested income. This purported theory provides that, as the gain on the sale of stock may be Subpart F income, it may qualify for the exclusion from tested income. However, this theory is subject to debate, is untested, and lacks the certainty that many taxpayers look for when contemplating M&A sales transactions.
While it is expected that this issue will be addressed in forthcoming regulations, as it currently stands, taxpayers are left with little guidance on how to treat lower-tier distributions or sales of lower-tier stock as they pertain to GILTI.
New trap under Sec. 245A
In 2019, the IRS released temporary regulations (T.D. 9865) under Secs. 245A and 954(c)(6) that limit certain planning strategies the Service said used the DRD provisions contrary to legislative intent. The rules are complex but are targeted and limit the Sec. 245A deduction (or the application of Sec. 954(c)(6)) only in a relatively narrow set of circumstances. The regulations provide that for any tax year, an otherwise qualifying taxpayer may not claim a Sec. 245A deduction to the extent the dividend is an "ineligible amount." The ineligible amount comprises 50% of the portion of the dividend attributable to "extraordinary disposition" amounts and 100% of amounts attributable to "extraordinary reduction" amounts.
The extraordinary-disposition rules target transactions that occurred during a short period following the enactment of the TCJA. During this period, GILTI was not yet effective for some taxpayers, while the Sec. 245A benefit was, creating a mismatch of old and new systems. This incentivized certain transactions that the IRS believed were not consistent with the intent of Sec. 245A. However, this window has since closed. Although these rules are important to understand and identify during due-diligence exercises, their temporal limitation reduces their impact on future M&A transactions.
However, the "extraordinary reduction" rules may have ongoing significant consequences. U.S. sellers should be aware of these rules when disposing of stock in a foreign corporation. An extraordinary-reduction amount occurs if either: (1) the controlling U.S. shareholder sells more than 10% of the stock of the CFC, or (2) there is a greater-than-10% change in the controlling Sec. 245A shareholder's overall ownership of the CFC. In these instances, the extraordinary-reduction account is increased by the E&P representing the amount of dividends paid by the corporation that is attributable to Subpart F income or tested income. But this occurs only to the extent such income would have been taken into account by the Sec. 245A shareholder had the reduction not occurred and the income would not otherwise have been taken into account by a domestic corporation or a citizen or resident of the United States.
These provisions are largely designed to combat planning based on Sec. 951(a)(2)(B) and the repeal of Sec. 958(b)(4). Both provisions, absent this rule, allow taxpayers to avoid subjecting income to the Subpart F and GILTI regimes in a way that allows the use of Sec. 245A to contravene congressional intent.
The temporary regulations also deny the Sec. 954(c)(6) lookthrough treatment for dividends paid by lower-tier CFCs to upper-tier CFCs, thereby causing a U.S. shareholder's Subpart F inclusion to increase by the amount not eligible for lookthrough treatment. Sec. 954(c)(6) provides an exception to the foreign personal holding income rule under Subpart F allowing a lookthrough exception for dividends paid from lower-tier to upper-tier CFCs that are not Subpart F or effectively connected income. The IRS expressed concern that the exception may cause dividends from one CFC to another to result in tax consequences similar to, but not dependent upon, those presented in a first-tier extraordinary-reduction or extraordinary-disposition transaction. Under the temporary regulations, dividends paid from a lower-tier CFC to an upper-tier CFC are eligible to apply the Sec. 954(c)(6) exception to only 50% of the amount that would constitute an extraordinary-disposition amount of the CFC.
These rules present new challenges for taxpayers and can create adverse tax consequences when they enter into M&A transactions. Example 2 illustrates this point:
Example 2: At the beginning of CFC's tax year ending on Dec. 31, US1 owns 100% of CFC. As of the end of the year, CFC has $160 of tested income and no other income. CFC has $160 of E&P for the year. On Oct. 19, US1 sells all of its CFC stock to US2 for $100 in a transaction in which US1 recognizes $90 of gain.
Under Sec. 1248(a), the entire $90 of gain is included in US1's gross income as a dividend, and, pursuant to Sec. 1248(j), the $90 is treated as a dividend for purposes of applying Sec. 245A. However, at the end of year 2, under Sec. 951A, US2 takes into account $70x of tested income, calculated as $160 (100% of the $160 of tested income) less $90x, the amount of dividend deemed received by US1 described in Sec. 951(a)(2)(B).
Sec. 951(a)(2)(B) was intended to prevent double taxation, but, post-TCJA, the above example illustrates that it can now produce double nontaxation. This is a result of the interaction of the DRD, which eliminates taxation of the presale distribution, and Sec. 951(a)(2)(B), which reduces the post-sale tested income or Subpart F inclusion by the amount of the dividend. To prevent this double-nontaxation result, the deemed dividend in the above transaction would qualify as an extraordinary-reduction amount under the temporary regulations. Therefore, with respect to the dividend received of $90 by US1, no portion is eligible for the DRD allowed under Sec. 245A(a). Additionally, no foreign tax credits are allowed with respect to the deemed distribution under Sec. 1248. This subjects the entire $90 dividend to U.S. tax at the 21% rate without the benefit of a foreign tax credit.
This potentially punitive outcome can be avoided in certain situations. The rules include a de minimis exception that provides that no amount is considered an extraordinary-reduction amount if the sum of the CFC's Subpart F income and tested income for the tax year does not exceed the lesser of $50 million or 5% of the CFC's total income for the year. An extraordinary reduction also does not include a transaction that results in the close of a CFC's tax year where the controlling Sec. 245A shareholder includes its pro rata share of Subpart F and tested income. This can occur in a few situations. If a buyer makes a Sec. 338(g) election, for example, the tax year would close, and the seller would include its pro rata share of Subpart F and tested income.
The regulations also include an election that may be made by the CFC's controlling Sec. 245A shareholders. When this election is made, each controlling Sec. 245A shareholder avoids the application of the extraordinary-reduction rules by having the CFC close its tax year on the date of the extraordinary reduction. This election causes the controlling Sec. 245A shareholder to include in its income its pro rata share of the CFC's Subpart F income and tested income as of the date of the extraordinary reduction. The election may allow corporate U.S. shareholders to take advantage of the Sec. 250 deduction and foreign tax credits. If the election to close the year is made, foreign tax credits are allocated between the two U.S. tax years under the same rules that apply upon Sec. 338(g) elections.
Making this election can have significant benefits. Returning to Example 2, under Sec. 951A(a), US1 takes into account 100% of CFC1's tested income for the tax year beginning Jan. 1 and ending Oct. 19, and US2 takes into account 100% of CFC1's tested income for the tax year beginning Oct. 20 and ending Dec. 31. No amount is considered an extraordinary-reduction amount with respect to US1. Given that GILTI may be reduced by a Sec. 250 deduction, among other things, and the resulting tax can be reduced by foreign tax credits, this election can reduce or even eliminate the 21% tax that would be incurred absent such an election.
Opportunities and next steps
Although the TCJA created new traps and complications, well-informed taxpayers should be able to traverse the new landscape efficiently. Some questions remain, but proactive modeling and analysis allow taxpayers to make informed decisions, even in fast-shifting economic environments. Additionally, in some cases, the changes in tax law may allow a savvy taxpayer to reduce or eliminate taxation on certain transactions, but only if the taxpayer is prepared for the new, post-TCJA M&A paradigm.
Greg Fairbanks, J.D., LL.M., is a tax managing director with Grant Thornton LLP in Washington.
For additional information about these items, contact Mr. Fairbanks at 202-521-1503 or greg.fairbanks@us.gt.com.
Contributors are members of or associated with Grant Thornton LLP.

redpajama_set_name: RedPajamaCommonCrawl


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Humanitarian Corps Begins Recruiting Drive
October 12, 2011 at 9:19 am by Rilla Peng
The UCSB Global Brigades is recruiting student volunteers interested in undertaking projects providing vital services in underprivileged countries.
The campus group is collaborating with its international division and mobilizing undergraduates for annual trips to supply medical treatment, create waterways and build schools in Honduras and Ghana. The organization advocates for human rights through charity work and has various branches including medical, public health, water and architecture.
According to Public Health Brigade President Amanda Beaudry, a fourth-year biological psychology major, the humanitarian group helps address the root causes of medical issues in foreign countries.
"Doctors saw in the clinics a lot of the same problems so they went to the village homes to see what was happening," Beaudry said. "It's important to address the immediate problems but it's just as important to ask, 'What can we do to prevent them from happening again?' In this way, our work is very sustainable."
The organization's Water Brigade sector improves access to clean water to prevent the development of potentially fatal diseases, according to Water Brigade President Beau Williams.
"[Water] really boils down to a form of preventative medicine. If you can nip certain illnesses in the bud before they happen, it helps other clubs like the Medical Brigade by not having them treat those illnesses down the line," Williams said. "[We] leave a lasting footprint and create a huge impact from the start."
The brigades host local fundraisers year-round to cover the costs of lodging, food and project supplies for student volunteers. Additionally, the group enlists translators and doctors in the region as additional members.
Medical Brigade President Jamie Miller, a fourth-year biological science major, said the group has also received financial support from undergraduates through Associated Students.
"We fundraise at local restaurants and do many other things such as grant writing, but we've also gotten help from the Associated Students Finance Board," Miller said. "It's always been amazing to get [help] through the school because it shows that they support what we do."
The associations collaborate to make significant improvements in the countries they visit, Williams said.
"The sum is greater than the parts. We're all cogs in the wheel and we play a different role for the same goal — to increase the quality of people's lives," Williams said. "Each of our missions addresses a different need that interties so well."
Establishment Chair Kristen Skinner, a fourth-year microbiology major, said performing charity work in developing countries is a personally rewarding experience.
"I joined the Medical Brigades initially because I wanted to contribute to something that was bigger than myself," Skinner said. "You go down there and you expect to help these people so much but what you come away with is amazing and rewarding as well."


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Miles: Calm heads make diplomacy work towards peace
The Salt Pile
Danny Miles|January 22, 2016
In 2015 the United States and other nations struck a nuclear deal with Iran. The deal was one of the most discussed political events of the year: Some view it as a major achievement of diplomacy in our modern age of bombs and threats by others as a submission to the demands of aggressive Iranian leaders.
The agreement mandated that international sanctions on Iran would be lifted, in return for a 98 percent reduction of its stores of low-enriched uranium and for reducing its number of operating centrifuges—which are used to process that uranium—by two-thirds. It is believed that this greatly reduces Iran's potential for nuclear weaponry. If they decided to violate this agreement and rush a nuclear weapon, it could take up to a year, compared to the couple of months it would have taken before the logistic reductions. In effect, this agreement killed most of Iran's nuclear program, without a drop of blood shed, to the chagrin of war hawks across the U.S.
This year Iran seems to be making good on this deal, much to the shock of naysayers (and Republican presidential candidates) everywhere. On Jan. 16th, the International Atomic Energy Agency reported that Iran has made serious progress on deconstructing its nuclear systems. Over 8.5 tons of uranium have been moved to Russia, the country permanently decommissioned a nuclear reactor in Arak and disabled over 12,000 centrifuges. In all respects, Iranian President Hassan Rouhani has readily complied with the deal. Furthermore he is actively working to improve Iranian domestic affairs, as well as foreign relations. Although the nation remains hostile toward Israel, the situation in the Middle East is slowly healing.
This is a historical moment in the diplomatic relationship between two countries who have been hostile toward each other since the hostage crisis in the late 1970s, and it could not have occurred without the tireless efforts of our leaders, including President Barack Obama and Secretary of State John Kerry. They should be commended; level heads prevailed in discussions, even with our very own Congress seeking to undermine the deal at every turn.
Many conservatives, including those in Congress, believe that these negotiations will fall through. Some suggest directly bombing Iranian nuclear facilities; others say that tightening sanctions will force Iran to concede to unreasonable deals, such as a complete and total destruction of their nuclear systems. The commonality between these lines of thought is aggression. The Republican approach to a tense situation is aggression; swords will succeed where words have failed.
I'm not saying that this isn't a valid approach at times. There have been many occasions throughout history where only war could solve problems, but we should not resort to violence when we're not forced to.
The fact of the matter is that the deal has been successful. In but a few months, it led to a drastic reduction in Iran's nuclear potential, and the world is safer for it. Perhaps this event can serve as a reminder to a country bristling at the mere perception of hostility: Diplomacy has kept this world going round many times over in the past, and it's not about to stop working now. When calmer heads prevail, everyone wins.
Danny Miles is a second-year student.
Danny Miles, Copy Editor
Danny Miles is a fourth-year computer science major with a Japanese minor. Besides The Observer, he writes for The Athenian and spends his Saturdays playing...


Burgomaster (alternatively spelled burgomeister, literally master of the town, borough or master of the fortress) is the English form of various terms in or derived from Germanic languages for the chief magistrate or chairman of the executive council, usually of a sub-national level of administration such as a city or a similar entity. In some cases, Burgomaster was the title of the head of state and head of government of a sovereign (or partially or de facto sovereign) city-state, sometimes combined with other titles (as in Hamburg's First Mayor and President of the Senate). Contemporary titles are commonly translated into English as mayor.
Bürgermeister (literally: 'master of the citizens'), in German: in Germany, Austria, and formerly in Switzerland. In Switzerland, the title was abolished mid-19th century; various current titles for roughly equivalent offices include Gemeindepräsident, Stadtpräsident, Gemeindeamtmann, and Stadtamtmann.
Burgemeester in Dutch: Belgium a party-political post, though formally nominated by the regional government and answerable to it, the federal state and even the province. Mayor and president of the municipal council. In the Netherlands nominated by the municipal council but appointed by the crown. In theory above the parties, in practice a high profile party-political post.
↑ "Curriculum Vitae Klaus Wowereit". Land Berlin, Der Regierende Bürgermeister, Senatskanzlei. Retrieved 2010-04-07.
↑ cf. Article 56 sec. 2 of the "Constitution of the State of Berlin (part 4)". Land Berlin, Der Regierende Bürgermeister, Senatskanzlei. Retrieved 2010-04-07.
↑ cf. Article 74 sec. 2 of the "Constitution of the State of Berlin (part 6)". Land Berlin, Der Regierende Bürgermeister, Senatskanzlei. Retrieved 2010-04-07.


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Bennelong senior promotions reflect global focus
Bennelong Funds Management has announced the appointment of two senior promotions which will serve to strengthen the firm's global positioning and boost its client capabilities.
Ella Tassi has been promoted to the role of chief marketing officer, with Nicole Hammond taking on the newly-created head of client experience position. Both appointments - effective immediately - are internal promotions and demonstrate the firm's continuing focus to position itself globally.
Bennelong's chief executive officer, Craig Bingham, said the appointments recognise the ongoing commitment and contribution made by Ella and Nicole.
"Ella and Nicole both have an acute sense of Bennelong's customer and brand proposition, and where we want to be over the coming few years in terms of growth and success of the funds," he said.
Ella's promotion to chief marketing officer is intended to foster growth by creating demand and reaching scale, as well as driving the development of Bennelong's brands and customer focus.
"Ella has overseen the growth trajectory of the Bennelong brand and its 11 boutique partners for over a decade.
"As we continue to grow the business globally, her role has extended to more formally support activities in the UK and US, as well as here in Australia," said Craig.
Ella was previously Bennelong's head of marketing, and has also held in-house marketing roles with IOOF, National Australia Bank and AXA Australia. She holds a Bachelor of Arts (Media and Sociology) from Swinburne University of Technology and a Graduate Diploma (Marketing) from RMIT University.
Nicole's appointment to head of client experience acknowledges the changing shape, nature and expectation of Bennelong's customers, and the business's commitment to understand and meet their needs.
"Given Nicole's existing knowledge of the business and our client base, I'm confident she will elevate our client experience to be one that's considered market-leading," said Craig.
Prior to commencing with Bennelong Funds Management - which has included roles in operations and fund accounting ? Nicole worked for Mercer and Aviva. She holds a Bachelor of Applied Science from RMIT University and is a Chartered Accountant.
"Both Ella and Nicole embody the characteristics needed for their roles, and are capable in both the soft and technical skills required. I'm thrilled to see their careers progress, and am confident they'll both continue to lead Bennelong's growth," said Craig.


A dynamic photo exhibition in 4K by Oregon photographers Susan and Steve Dimock.
A brief history of the people and the landscape of the Dosch Estate and the legacy of stewardship that ties them. Created through the DIY Documentary workshop series.
A visual tour of the Oregon Coast.
Jason Fitzgibbon, set out with cinematographer Octave Zangs to sample some of the state's most rugged coastlines, its finest trails, and its wildest rivers, in an effort to enjoy and share some of the ecological resources, recreational opportunities, and priceless experiences that can be found in our threatened federal lands.
Dave Lacey and the Native Fish Society's staff embarked on a three year campaign that ultimately sought to stop not one, but three proposed strip mines before they could irreversibly damage some of the wildest country, cleanest water, and healthiest wild salmon rivers on the west coast.
Behind the Emerald Curtain exposes the harmful practices occurring on Oregon's private timberlands under the Oregon Forest Practices Act.
David Fortney, an Emmy Award winning cinematographer, captures the beauty of the land using a variety of techniques including motion control time lapse and POV to allow the sensation of traveling through the scene.
A documentary about Oregon's Beach Bill that allow public access to Oregon's beaches. Produced as a project of NW Documentary Explorers Camp.
Sanctuary. There are two primary definitions. One meaning a place of refuge or safety. The other more specifically defined as a protected natural space. Ninety-five year old World War II veteran Frank Moore knows that the two definitions are not mutually exclusive, that sanctuary as a protected natural space is also a place of refuge, safety, and even healing.
Tina is a retired US veteran who suffers from PTSD and now spends her time helping homeless veterans.
Created entirely with infrared converted cameras, Invisible Oregon is a study of light across time and space. As the sun rises over the State of Oregon infrared light travels across the earth revealing the subtleties of new growth and the dramatic intersection of sky and earth. Witness for the first time this diverse and interconnected landscape rendered from light we can't see with our own eyes.
'Clearly Coastal' is a short film that explores Oregon's rugged and diverse coastline from a unique viewpoint – the air! There is something truly magical about this state's coastline – each part of it is different in its own way. Its foggy mountain ranges, historic lighthouses, and towering sea stacks have an allure like no other.
Nearly thirty years ago, the small town of Oakridge, Oregon lost its last sawmill. Now, some thirty years later, swaths of clear-cut have begun to slowly recover, and ribbons of mouth-watering singletrack run through them. The scenery is beautiful and the trails are flowy, and people have begun to take notice.
A time-lapse film taken in the fall season.


Investors and owner occupiers should inspect this property as the owners will either vacate the property or lease it back for a very long time.
Situated on 1025 sqm block of land in a nice quiet area of Stratford is this affordable home offers three surprisingly large bedrooms all with built in robes and ceiling fans, a good sized living room with both wood and electric heating and air conditioning, a functional kitchen has a new stove and new cupboard doors, a separate dining area opens onto a rear deck, fully equipped bathroom, separate laundry and toilet.
A double carport plus a 6m x 6m lock up shed has a concrete floor, power and light and two garden sheds will take care of all of your storage needs.
Offering excellent value for money we suggest you inspect early to avoid disappointment.