Until recently, the story of the modern workplace was dominated with the entitlement driven criticisms aimed at Millennials.
The idea that a generation would have so many inherent accommodations and needs, holding captive a workplace that would have no other choice but to conform to their idealistic, entitlement-driven demands, has been something of a newsworthy accomplishment by this struggling segment of the almost working class.
Despite this publicity, bringing up the rear is a new generation of young people, somewhere in the range of 13 to 24-years-old, who have started to already show signs of bucking the Millennial trend.
This generation is known as Generation Z, and it may prove to wreak havoc on the landscape of the modern workplace as has been defined by Millennial thinking.
One thing that sets Generation Z apart from all other generations is the fact that they have never known a time when there was no Internet.
Being the generation of true digital natives, Generation Z is already proving to be far more fluid in the use and comprehension of digital technologies than Millennials.
Adding their individualistic tendencies to this mix makes Generation Z a force to be reckoned with when it comes to digitally-based entrepreneurial endeavors.
Additionally, these digital natives have a more positive relationship with technology than the Millennials do also. So, it is expected that Gen Z's will dominate in tech-based businesses, because they view the world so intently through the lense of technology and harbor the fluidity in speaking the digital language on which modern society is built.
If there is one area where Generation Z departs from the Millennials in the workplace, it is in terms of the team versus the individual.
Also read: Millennials vs. Generation Z: How Do They Achieve Success in The Workplace?
Where Millennials were all about an open space work environment where teamwork was the end-all-and-be-all of how employment was to be orchestrated in the daily grind, Gen Z's appear to be looking for a more balanced approach to this model by making equal time for group work and independent work.
With this different approach to the work environment that Gen Z's will bring, HR departments within smaller firms should consider this impact on their ability to insure themselves and find small business insurance quotes that will be most beneficial for their business and employees.
One reason for these shifts in work preferences is the fact that Generation Z is far more money and career motivated than their predecessors.
Of course, how is Generation Z supposed to respond to living through the recession of 2008 that left many of these individuals to learn to appreciate what little they had from such a dismal economic experience? If anything, they have a modicum of healthy anxiety over finding and maintaining a stable job—something often absent in the Millennial mindset and practice.
Because Gen Z's grew up as the children of the digital landscape, they are naturally accustomed to making connections between people and eliminating the barrier termed "generation" as an obsolete distinction.
They did not simply come to know social media and its connective potential like Millennials did, rather they embody that connective potential in a way that is far more natural than the way Millennials and earlier generations do.
While Millennials are pushing ideas like small business insurance quotes as slogans on the Internet in the name of striving towards affluence, Generation Z is looking beyond the ad slogans and asking how such business-related ideas could become a more positive contribution to everyone in their connected online sphere: trading in affluence for far greater connective influence as they go.
Generation Z is making waves that have, not as yet, been fully realized by the business world. Yet, they have made enough of an impact that the networking side of business is something they do, not by corporate training, but by sheer upbringing.
These digital natives only know that reaching out and connecting with others and holding on to a stable paycheck is the central basis for the stability they seek in order to lay their economic anxieties to rest.
In this respect, Generation Z may bring a competitive edge to the table over Millennials in the workplace.


text:
Q: unable to import a psd file correctly in android studio I imported two PSD files in android studio, suddenly I find out that one of them works correctly as shown in the pictures

and one other PSD imported the same way doesn't work as shown in the pictures

I wonder what could be the reason for that honestly, I am stuck here.

A: I'm not sure if this is exactly the problem but maybe this will help you: Error importing Vector Asset into Android Studio

redpajama_set_name: RedPajamaStackExchange


Cook County Assessor Joseph Berrios announced today that his office, in cooperation with local, township, and county elected officials, will host numerous outreach sessions to help taxpayers that suffered great losses as a result of the serious flooding.
"Many Cook County residents have endured great hardship with the recent flooding," Assessor Berrios said. "I want to personally assist these taxpayers by helping them file appeals in order to receive assessment relief."
Aware that many of these taxpayers may require additional help at this time, the Assessor and his staff will host local outreach sessions in the affected communities to discuss assessment relief options.
"While the assessment and appeal process is ongoing, sometimes an emergency or disaster merits a special response," Berrios explained.
flood damage in their appeals.
grateful to Assessor Berrios and the Board of Review for undertaking this vital effort to ensure that people have the extra assistance they need during these trying circumstances."
"Emotionally, there is very little we can do to replace or soften the personal loss. But, we should do everything we can to assist financially. This extension for the property tax reduction appeal process is a way for Cook County to provide the needed assistance to those who have been devastated by the recent flooding," Commissioner Elizabeth Doody Gorman said.
The Assessor's Office will work closely with county commissioners, township assessors, suburban mayors and other local officials in the affected areas.
"These local elected officials are aware of flood zones and problems that occurred in the areas they represent and with the constituents they serve," Berrios said. "We will ask for their help in providing us with any pertinent data that will help with the appeal process."
"Flooding has been a major problem in the western suburbs and I've been working closely with the Department of Homeland Security to develop a multi-hazard disaster mitigation plan for the past two years. The assessor's efforts are another needed tool in helping the citizens of our county in rebuilding from this flood," Commissioner Jeff Tobolski said.
The Assessor's Office plans to announce outreach sessions in the following townships: Leyden, Lyons, Maine, Niles, Norwood Park, Stickney, Proviso, Riverside and parts of Jefferson. The outreaches will occur within the next six months and will be scheduled to correspond with the assessor's appeal filing period for each particular township impacted. If a particular township's appeal period has already been completed, the Assessor's Office will work directly with the Cook County Board of Review to assist taxpayers in filing appeals with that agency.
"In the last several weeks, hundreds of Cook County residents had their lives chaotically disrupted with these floods," Berrios said. "I want to ensure that my office does everything it can to help those taxpayers who may be entitled to special consideration and assessment relief."


text:
Q: How can i implement a vector.insert like method for my custom vector class? i have made a custom class to implement a std::vector.
My class has Forward iterator support. I'd like to know how I can implement a vector.insert like method that allows me to insert an element at any position inside the vector.
I can't use allocator, but i'd like to know if the insert method can be done with iterators and, if it is possible, how can it be done?

A: To implement insert you need to move/copy all elements post the insertion point one element (possibly allocating new memory and moving all members if your internal storage is not large enough), then insert the new element in the "hole" you just made.
Note that this (of course) invalidates existing iterators.


When you work with people of different faiths, ethnicities, cultures, and races, you are bound to encounter conflicts; both real and perceived. The battles may be overt or subtle causing tensions and setting one up against the other, and getting entangled instead of being productive. The loss is two-fold; missing enjoyment at work, and the loss of productivity for the business, government or the community.
Program Sponsors: You are invited to sponsor.
What we need now: Please boldly share the myths you hear about Hindus and Muslims for the seminar in October, and other faiths in November. We will compile a list and discuss the issues in a televised workshop.
This seminar deals with myths formed about each other, and the attitude of 'problem is always with the other and not us,' keeps us mired in trivialities. Sadly, the idea has been pounded in by the parents, siblings, family members, teachers (religious and civic) and bloody politicians. They are indeed poisoning us in doses, and it is time to free ourselves from such misery.
Our goal is to bust the myths and pave the way for tension-free living. We hope you walk out of the seminar respecting the otherness of other and accepting the God given the uniqueness of each other resulting in fewer conflicts and plenty of goodwill, peace, and harmony.
Even though a few adults may fake things are hunky-dory, deep down, they have problems working with the others, due to the bias injected into them about the other. Indeed, they are loaded with ill-will, revenge, and relentlessly waiting for an opportunity to pull the other down. It must be painful to live like that.
Join us for the seminar, it is the first step in finding freedom from all the ills. When you don't have to have the daily under-the-radar battles, cold wars or the subtle jibes. You can enjoy the freedom, which will pave the way for a meaningful relationship with your family, friends, co-workers, and others. Do we need to be free from these entanglements?
We have tackled over two dozen national conflicts over the years, it is a process of learning to deal with the issues.
In the month of November, CFP will organize a dinner event busting myths about ten different faiths to bring freedom to individuals to develop an attitude of living his/her life and also letting others live theirs. The program will be broadcasted live.
Years ago, in a meeting at the DFW Hindu Temple, a friend questioned me if Hindus were allowed in a Mosque – my response was, it is God's place, and all are welcome. However, a few fanatic Muslims have difficulty permitting a non-Muslim's entry into a Mosque, just like there are Hindu Temples where non-Hindus are not allowed, and if by mistake someone other than the upper caste Hindu walks in, they go out of the way to consecrate the temple and wash it seven times.
A majority of the Hindu Temples and Mosques in the United States welcome the others to visit their place of worship. There are guidelines one needs to follow – you don't go in either place with your footwear, you take the shoes off, and no one wears mini-skirts in the mosque or the temple. In the mosque men and women are required to wear a full-length dress and cover their head as a sign of humility.
The Center for Pluralism under the old name Foundation for Pluralism held interfaith prayers in Dallas Central Mosque, and the Hindu bhajan (ode) was sung in the mosque, and the Hindu temple, as well, sang the bhajans with different names of God including Allah. That is the norm, and that is the majority of Hindus and Muslims who respect the otherness of the other.
Right now our fellow humans in India are living in tension and tearing that nation apart. Even here in the United States, at a Shiva temple, this month, a program was canceled because the fanatics among Hindus did not want the singer to sing hymns about Christ or Allah, and their argument was Mosques and Churches don't reciprocate, which is false. Some of the best Hindu devotional songs are written, composed and sung by Muslims and Christians and vice-versa. Of course, the fanatics among Muslims have the same attitude. We the civil society has a responsiblity to build cohesive societies.
You and I must open up the hearts and minds of those who live in tensions and suffer miserably with ill-will. America is a great nation, so is India and we must preserve the goodness. Remember evil exists not because of sick people, but because good people do nothing about it. Let's start doing good.
Each religion is as legitimate as yours and does what it is supposed to do to make you a better human, and every religion is dear to its follower regardless of what others say. The Center for Pluralism hopes to find freedom and restore the integrity in each one of us by learning to respect the "otherness" of others.
If you are interested in attending, volunteering, designing and sponsoring, please send an email with your interest to Mike@CenterforPluralism.com.
Dr. Mike Ghouse has spoken about the need for Pluralism and how the pluralistic attitudes make a difference in our daily lives; be it in religion, politics, society, cuisine, and workplace with examples.
Pluralism frees us from under-the-radar discomfort in working with people who are different in faith, cultures, race, and ethnicity. An example of Pluralism in Cuisine and its benefit to the business and individuals was explained. Pluralism is merely developing an attitude of respecting the "otherness" of others. It is not a mish-mash, nor is it yielding to the Other, it is just learning to accept the uniqueness of each person.
Dr. Ghouse of the Center for Pluralism believes in Mother Teresa's wisdom, "If you want to make peace with your enemies or perceived enemies," she says, "go talk with them." Talking among buddies won't change the equation. Dr. Ghouse cleared up how he works; he carries a conversation with people on the extreme right, left and the center. He has been on Sean Hannity show at Fox News for 110 times. These encounters should not mean that he or the Center For Pluralism (CFP ) subscribe or agrees with the views of the people they interact. This situation lends an opportunity to share essential perspectives about pluralism.
Our dream is to make the Center for Pluralism a significant player in shaping America's future. Each one of us should feel secure about our faith, culture, cuisine, race, ethnicity, gender and origins. We have the programs in place to accomplish this mission.
Please visit the Center for Pluralism and see the thing's we do to build a cohesive America. An American where no one has to live in apprehension or fear of the other. You are invited to be a supporter, volunteer, and a donor.
The Center for Pluralism holds workshops, seminars, lectures and series of dialogue on Pluralism in religion, politics, society, culture, and business.
Mike is a community consultant, social scientist, thinker, writer, newsmaker, and a speaker on Pluralism in politics, religion, society and the workplace. He also officiates interfaith weddings.
Ghouse has appeared in over 300 TV shows and is a frequent guest on Hannity, and Varney shows at Fox News along with others. He has over 1000 hours of Radio Shows of which 700 were dedicated to interfaith and pluralism. Over 3600 articles have been published on the subjects. Mike has conducted several workshops on religions from Atheism to Zoroastrianism and everyone in between.
Pluralism is an attitude of "Respecting the otherness of others" and "accepting the God-given the uniqueness of each one of us." You are who you are, and I am who I am, neither one of us has to compromise the uniqueness of our faith, race, culture, nationality, and language. Our purpose is to acknowledge the differences and live with the least conflicts.
Without your donations, we cannot do anything.
Pluralism studies in religion, politics, culture, workplace, and society.


text:
Guest Article written & Copyright © 2010
by Susan Anderson (my research buddy)
Seeking the Dickinson Family Silhouette
Dickinson Family Silhouette
Link to Yale University Yale University Library Manuscripts & Archives
There I was, a new researcher in the mysteries of the poet Emily Dickinson of Amherst, Massachusetts. At the moment it was 2003 and I was staring at Polly Longsworth's book, The World of Emily Dickinson. What caught my attention were the four images of Emily which Polly reproduced in her book. Four images? As a good New Englander, I believed I had a passing familiarity with Miss Dickinson. I was shocked to find that, besides the oft reproduced photograph of her, there existed an 1840s painting and two silhouettes, one a small bust of Emily, the other a board containing 5 black silhouettes of the Dickinson family standing together.
Leaving aside the common photograph and the naïve painting, I concentrated on the two silhouettes. What did I know about silhouettes? Well, I knew silhouettes were black; they usually resided in great aunts' houses; they were old; and they sometimes garnered large amounts of money. Summing up these facts, I figured I was probably a bit short on information.
On the Internet I found Penley Knipe's 1999 article, Shades and Shadows. From it I learned a short history of silhouettes; the making of silhouette paper; the difference between 'hollow cut' bust silhouettes and black paper silhouettes; and the cutting of silhouettes using a machines like the physiognotrace, or free-hand cutting like that done by Edouart and others.
Some time after reading Penley's paper, a fortuitous stop at the library of the New Hampshire Historical Society introduced me to the 1976 book on Edouart, Silhouettes of Eminent Americans. I was struck by the similarity between Edouart's silhouettes and the Dickinson family group in the Longsworth book. Could the group have been cut by Edouart? I knew I needed to see the marvelous Dickinson silhouette group in the original, whether cut by Edouart or not. So began my hunt..
A search of the internet inspired me to visit the Jones Library in Amherst, Mass., and the Mt. Holyoke College Archives in S. Hadley, Mass., since both seemed to have images of the silhouette group. I was hoping one might be the original. However, both institutions had only copies and knew nothing of the original.
Polly Longsworth was my next hope. After all, it was her book which had started my search. An email to her elicited the information that she did not know the location either, but suggested I should try Yale as it had Dickinson material.
Ignoring Yale for the moment, I decided to contact Amherst College Archives. I knew they had the original photograph of Emily Dickinson. Surely they had the original silhouettes. It turned out that, indeed, the Archives had the little silhouette bust of Emily, but not the family group or knowledge as to its location.
Yale was next by default. A call to their Archives was as fruitful as all the other inquiries. They had no information on the whereabouts of the silhouettes, though they had a copy.
My search was not going well. I had to think of another avenue of attack. I decided to rummage through the different biographies written about Emily Dickinson to see where the silhouette group had first been used as an illustration. Several books reproduced the grouping, but none seemed to have the information that would lead to the original.
Then came the 'eureka' moment. Like a gold miner striking a lode, I finally unearthed the author. Jay Leyda, in his Hours and Years of Emily Dickinson, turned out to be the first to publish the illustration. I frantically rifled through his footnotes and illustration information only to find that every illustration in the book was credited except the silhouettes of the Dickinson family. Now things really were not going well. Given that Leyda seemed quite scrupulous in attribution, why the momentary lapse on the one illustration on which I needed a credit? It took some time for me to deduce that the only sensible answer to that question was that Leyda owned the silhouettes.
Sadly, both Jay Leyda and his wife were deceased, closing that avenue of inquiry. Diligent searching on the Internet, however, produced the name of Leyda's executrix. A telephone call to her gave me the information that some of Leyda's material was at the Tamiment Library, NYU, New York City.
I emailed the Tamiment about the missing silhouettes. Soon a large envelope came bouncing through the postal system. In the envelope was a copy of a letter written by Jay Leyda that, like a treasure map, divulged the location of the treasured silhouette group. The location was the one place no one had thought to make inquiry and, like Poe's Purloined Letter, the location was practically in plain sight. Leyda's letter was written to Harvard University's Houghton Library and stated that Leyda was donating the silhouettes to the Houghton Library which had a large collection of Dickinson material. I was elated. If the silhouette group was at Harvard, it was very close to me.
A telephone call to the Houghton Library confirmed that they had the original silhouette group and that I could examine it by making an appointment. I lost no time in setting up a date.
Before the visit, homework was essential in order to become more versed in silhouettes. I borrowed several books listed on Peggy McClard's website and read through them. I also spent hours combing through the online records of Newbanks' Historical Newspapers for references to silhouettists and their art. By the day of my Harvard visit, I felt at least slightly more informed.
On arrival at the Houghton Library, I was seated and then handed a large box. Upon opening it, I had the distinct pleasure of looking at the very first original silhouette group I had ever encountered. As I viewed the 5 black paper silhouettes of the Dickinson family, I noted the 8" height similar to the size of many of Edouart's cuttings, but no Edouart signature was visible; nor did the cutting seem nearly as fine as that of Edouart. No matter who cut the Dickinson group, however, seeing it still produced a trill of excitement. I had finally achieved my goal. I had found and touched the original silhouette group, after months of questing. At that moment I decided that no matter what future research unveiled about the Dickinson silhouette group, finding the original at Harvard University was, in itself, a grand hunt. It was a lesson in persistence while also giving me an appreciation of silhouettes and their creators. And, in the future, perhaps my hunt will make it easier for some other researcher to discover the original Dickinson silhouettes.
© Susan Anderson 2010

redpajama_set_name: RedPajamaCommonCrawl


text:
Warang est un village du Sénégal, situé sur la Petite-Côte, à 88 km au sud de Dakar et tout proche (une dizaine de km) de Mbour.

Histoire
Deux thèses, également plausibles, s'affrontent quant aux origines du nom du village comprenant deux quartiers, Warang Socé et Warang Sérère et deux chefs de village.
Selon la version socée, le mot warang signifierait "vaste", le jugement porté par les premiers arrivants, venus de Gambie.
Selon la version sérère, warang serait en réalité constitué de deux mots : war qui signifie "tuer" et rang qui veut dire "embarquer".

Administration
Le village fait partie de la Commune de Malicounda, au sud de l'arrondissement de Sindia. Il se trouve donc dans le département de Mbour (région de Thiès).dont l'actuel Maire est Monsieur Maguette séne.

Géographie
Les localités les plus proches sont Mbour, Sidibougou, Sintiou Mbadane, Gagnabougou et Nianing ainsi que Mbaling.

Physique géologique

Population
Warang compte environ 3 500 habitants (source : ), mais c'est sans compter les expatriés européens, de plus en plus nombreux à y faire construire des maisons, et les Dakarois qui y possèdent des maisons secondaires.

Les Sérères, les Bambaras, les Wolofs ou les Diolas/Jolas sont les ethnies les plus représentées. Les habitants sont majoritairement musulmans (comme le reste du Sénégal). Le village compte trois mosquées mais également une chapelle, dont les travaux de rénovations se sont achevés en 2010.

Économie
En complément des activités traditionnelles du village – pêche, agriculture, élevage, mais surtout artisanat et commerce –, le tourisme semble offrir de nouvelles perspectives, si l'on en juge par l'exemple de la station balnéaire de Saly. Hôtels, campements et résidences se sont ainsi développés.

Voir aussi

Liens internes

Bibliographie

Liens externes
  Maps, weather and airports for Ouoran
  Warang sur le site de la communauté rurale de Malicounda
  Le site de l'école élémentaire de Warang
  L'hôpital de Warang
  Le Centre de Formation Frédéric Ozanam

Village dans la région de Thiès

redpajama_set_name: RedPajamaWikipedia


In an ever eagerly anticipated annual tradition, Ronald Aucutt, a McGuireWoods partner and co-chair of the firm's private wealth services group, has identified the following as the top ten estate planning and estate tax developments of 2014. Ron is a Past President of The American College of Trust and Estate Counsel, an observer and frequent participant in the formation of tax policy and regulatory and interpretive guidance in Washington, D.C., and the editor of the Recent Developments materials that are presented each year at the Heckerling Institute on Estate Planning.
2014 has been a challenging year for identifying "top ten" developments. The usual candidates – significant cases, groundbreaking rulings, important regulations – are hard to find. That, together with a permanent estate tax statutory environment for the first time since 2001, made 2014 a lean year for "recent developments." In the absence of actual developments, much of this summary will address themes, trends, and general climates. But the Foreign Account Tax Compliance Act (FATCA) actually produced an event in 2014. It took effect.
FATCA was enacted as part of the Hiring Incentives to Restore Employment Act (HIRE Act) (Public Law 111-147), signed into law on March 18, 2010. It is codified in sections 1471 through 1474 of the Internal Revenue Code of 1986, as amended ("the Code"). Its purpose is to combat tax evasion by taxpayers with undisclosed foreign financial accounts and other offshore assets, by requiring reporting with respect to those accounts and assets by both U.S. taxpayers and foreign financial institutions, and backing up that requirement by a 30 percent withholding obligation at the source of the income.
Proposed regulations were published on February 15, 2012 (77 Fed. Reg. 9022), numerous public comments were received, a public hearing was held on May 15, 2012, and final regulations were promulgated by T.D. 9610 on January 29, 2013. Withholding on some U.S.-source income payable to foreign financial institutions took effect on July 1, 2014.
Meanwhile, the worldwide commitment to the transparency FATCA encouraged has been strong. According to Announcement 2014-38, 2014-51 I.R.B. 951, as of July 1, 2014, 101 foreign jurisdictions had substantially committed to one of the two model intergovernmental agreements (IGAs) the Treasury Department had promulgated in 2012.
A case that was not even a tax case became one of the most discussed cases in the fourth quarter of 2014. In a civil enforcement action, a jury convicted two brothers, Samuel and Charles Wyly, of nine counts of federal securities law violations regarding their use of trusts and other entities in the Isle of Man to trade in the stock of public corporations on whose boards they sat. In this decision, the court imposed the familiar securities law penalty of disgorgement, in the amount of almost $620 million. Included in that sum was an amount calculated with reference to the federal income taxes the Wylys saved when the stock was sold on the theory that the stock was owned and sold by the trusts, not by them. The court found that the trusts were grantor trusts, by reason of the Wylys' ability to control the discretionary actions of the trustees through trust "protectors," who among other things had the power to remove and replace the Isle of Man trustees. The protectors were the Wylys' family attorney, the chief financial officer of the Wylys' family office, and the chief financial officer of another Wyly entity.
The court was struck by the fact that the investment recommendations of the Wylys, passed on by the protectors, appeared to be consistently followed by the trustees. With little or no analysis or elaboration, the court found that that indicated that the trustees "made no meaningful decisions" and the Wylys themselves "freely directed the distribution of trust assets." The section 674(c) "independent trustee" exception, the court said, did not apply.
It is hard to defend the Wylys, given the facts and jury verdict in this case. And for income tax and estate tax purposes, it would be hard to defend collusion between the grantor and the protectors whereby the grantors had de facto control of the trusts. But it is also unsettling to imply that a court might find such de facto control merely in a record of the trustees' consistent agreement that the grantors' suggestions were good. To be sure, a domestic corporate trustee, for example, could probably be counted on to document its exercise of due diligence in accordance with its published policies, something the trustees in the Wyly case apparently did not do. But the court's open-ended reasoning could leave a cloud over the independence of trustees and other fiduciaries in far more sympathetic cases where grantors understandably choose trusted friends, associates, and advisors as protectors.
There is a fascination these days with income tax rates and the step-up in basis of appreciated assets at death. Both are affected by the highest-ever estate tax exemption, which shifts the attention of many to income tax planning and results in a lower overall estate tax cost of including the value of appreciated assets in the gross estate to obtain a stepped-up basis. The basis analysis lends itself to exaggeration and probably has been exaggerated, to the extent it overlooks the fact that some assets will be sold during life, some will not be sold until long after death, and there is obviously more control over the timing of sales than of death in any event.
The focus on income tax rates in general is driven by legislation that took effect in 2013. For 2012, the top income tax rate on trusts and estates was 35 percent for taxable incomes over $11,650. For 2013, under the American Taxpayer Relief Act of 2012, the regular top rate jumped 4.6 percent to 39.6 percent for taxable incomes over $11,950. Also in 2013 the 3.8 percent tax on net investment income under section 1411 enacted by the 2010 health care reconciliation legislation took effect. The result was a total top rate of 43.4 percent – a comparative 24 percent tax increase over the 2012 rate of 35 percent. The level at which those rates apply increased modestly to $12,150 for 2014 and $12,300 in 2015.
The 3.8 percent tax on net investment income seems to have attracted much more attention from estate planners than the 4.6 percent increase in the regular rate. Why is that? Simply because the separate 3.8 percent tax has an optional or voluntary element, driven by the exemption of income from a trade or business that in general, as stated in section 1411(c)(2)(A), is not "a passive activity (within the meaning of section 469) with respect to the taxpayer." Suddenly, section 469, enacted by the Tax Reform Act of 1986 to curb tax shelters, became relevant to estate planners and others using trusts. We rediscovered that section 469(c)(1) generally defines "passive activity" as "the conduct of any trade or business … in which the taxpayer does not materially participate" and section 469(h)(1) defines material participation as involvement in the operations of the activity on a "regular, continuous, and substantial" basis, but the places for regulations that might have applied those principles to trusts had been merely "reserved" since 1988. Such regulations, under section 469, not exclusively section 1411, are being worked on, to supplement the detailed regulations under section 1411 promulgated in 2013 (including Reg. §1.1141-3 relating to estates and trusts). "Guidance regarding material participation by trusts and estates for purposes of §469" is on the Treasury-IRS 2014-2015 Priority Guidance Plan published August 26, 2014.
How a trust "materially participates" – a distinctly human notion – is a challenge. Mattie K. Carter Trust v. United States, 256 F. Supp. 2d 536 (N.D. Tex. 2003), held that "common sense" and the notion of the "trust" as the "taxpayer" dictate that "material participation" in the context of a trust be determined with reference to the individuals who conduct the business on behalf of the trust, but that approach seems way too broad and, if applied to individuals, for example, could erode the anti-tax-shelter impact of section 469. In Technical Advice Memorandum 201317010, the IRS took the position that the substantial business activity of a "special trustee" who was also the president of an operating company was attributable to his role as an "employee" and not attributable to his role as trustee and hence to the trust, but that approach seems way too narrow and would frustrate the congressional expectation that "[a]n estate or trust is treated as materially participating in an activity … if an executor or fiduciary, in his capacity as such, is so participating." S. Rep. No. 99-313, 99th Cong., 2d Sess. 735 (1986). In the view of many observers, the IRS position was tantamount to a refusal to acknowledge that any trust could ever materially participate in a trade or business for purposes of the passive loss rules of section 469.
That appears to have been essentially the IRS position in Aragona, and the Tax Court (Judge Morrison) rejected that position. The court held that a trust operating a real estate business could avoid the per se characterization of a real estate business as passive under section 469(c)(2), as could a natural person, if, as provided in section 469(c)(7)(B), "(i) more than one-half of the personal services performed in trades or businesses by the taxpayer during such taxable year are performed in real property trades or businesses in which the taxpayer materially participates, and (ii) such taxpayer performs more than 750 hours of services during the taxable year in real property trades or businesses in which the taxpayer materially participates." The court also held that the trust in this case materially participated in the business because some of its co-trustees materially participated to the extent required by section 469(c)(7)(B). Therefore, the trust could fully deduct its expenses, including trustee fees.
The Aragona decision does not predict how the pending guidance will apply to every case under section 469 and thus under 1411. But this decision should encourage the IRS to find a balanced outcome that avoids both the nothing-works implication of its historical position and the anything-goes permissiveness of the district court in Mattie Carter.
The tax collector is rarely popular. In addition, some have a vision of tax policy enamored with proposals like a value-added tax or a so-called "fair tax," or even a vision of government, that includes a diminished role for the IRS. The IRS enraged and emboldened its critics when in May 2013 its employee Lois Lerner publicly admitted to have given harsher or slower handling to the applications for recognition of exemption of some section 501(c)(4) "social welfare" organizations whose names suggested conservative-leaning political agendas. Even in the calm of hindsight, it seems likely that some mishandling occurred that has not been fully acknowledged or explained, likely even skewed by the political biases of some IRS personnel. But the specter of a wide-ranging conspiracy orchestrated at the highest levels of government also seems unlikely. In a world of intense political polarization, however, the inability of those at the poles to accept the possibility that the truth may lie somewhere in between is not surprising.
The most strident IRS critics in Congress did not need encouragement to be critical, of course. The 501(c)(4) "scandal" did not make them skeptics. But it provided an irresistible occasion for expressing that skepticism, and thus an irresistible occasion for all polar views to be loudly heard. And one of the tangible effects has been perhaps even more aggressive reductions of the IRS budget. After all, who wants to give more money to finance more misconduct? The bold notion of the IRS as a profit center is lost in the rhetoric. In fact, the IRS's return-on-investment is over 200:1, while it estimates that every one dollar taken away from its enforcement budget reduces its collections by as much as seven dollars.
The fiscal 2015 IRS funding in the omnibus appropriation legislation approved by Congress in mid-December is not as austere as the Financial Services and General Government Appropriations Act (H.R. 5016) the House of Representatives passed on July 16, 2014. But it still reduces the IRS budget for fiscal 2015, compared to fiscal 2014, by about 3 percent, and the slightly less than $11 billion approved in December is $1.5 billion less than the IRS and the Administration requested. To be sure, the IRS request represented a significant increase over last year's funding, but that was in large part an attempt to make up for substantial reductions in both services and enforcement caused by funding cuts in recent years.
The damage to the administration of the tax system and the public interest from underfunding the IRS, while not always intuitive, is grim. Personnel attrition is up, especially at senior levels, while hiring is down. Meanwhile, the IRS training budget has been reduced by 85 percent since fiscal 2009. While many of us tax lawyers frequently find ourselves facing the IRS as an adversary in a tax controversy, and in that context we want the IRS to "lose," there are no winners from dramatically reduced training that reduces the likelihood that our IRS counterparts will be up-to-date on the law and purposes and effects of common practices and techniques. The result is that audits take longer, are less satisfying, and leave less time for consideration by the Office of Appeals, while the same limitations apply at Appeals as well. Comparable sacrifices on the service side are also well documented, with longer waits for phone calls to be answered and more phone calls going unanswered altogether.
This degrading of both enforcement and service inevitably erodes public confidence and fosters the perception that tax collection is unfair or even arbitrary. That in turn creates frustration and cynicism that translates into complaints to members of Congress and more political pressure to punish the IRS by reducing its budget still further. In the long term, this vicious circle has the potential to be as significant as any case or ruling we have seen.
On May 8, 2014, the IRS released Reg. §1.67-4, providing guidance in identifying the costs or expenses incurred by estates and non-grantor trusts that are not subject to the 2 percent floor for miscellaneous itemized deductions under section 67 because they are "costs which are paid or incurred in connection with the administration of the estate or trust and which would not have been incurred if the property were not held in such trust or estate," as provided in section 67(e)(1). By an amendment dated July 17, 2014, the effective date of these regulations was changed from May 9, 2014, to January 1, 2015. The regulations were analyzed in a McGuireWoods Legal Alert on August 6, 2014.
The regulations follow a string of IRS victories in cases subjecting the investment advice costs of trusts to the 2 percent floor.Mellon Bank v. United States, 265 F.3d 1275 (Fed. Cir. 2001); Scott v. United States, 328 F.3d 132 (4th Cir. 2003); William L. Rudkin Testamentary Trust v. Commissioner, 467 F.3d 149 (2d Cir. 2006), aff'd sub nom Michael J. Knight, Trustee v. Commissioner, 552 U.S. 181 (2008). The final regulations make only a few changes to the proposed regulations published in 2011.
Not surprisingly, the regulations (Reg. §1.67-4(b)(5) & (6)) exempt from the 2 percent floor uniquely fiduciary expenses, such as for probate court fees and costs, fiduciary bond premiums, costs of legal publication of notices to creditors and heirs, costs related to fiduciary accounts, and appraisals needed to complete a tax return or to make distributions. Similarly, the regulations (Reg. §1.67-4(b)(3)) exempt the costs of preparing specified tax returns – namely estate and GST tax returns, fiduciary income tax returns, and the decedent's final income tax returns.
Costs that the regulations make subject to the 2 percent floor include "ownership costs" that in effect are in rem costs that follow the asset (Reg. §1.67-4(b)(2)), the costs of preparing all tax returns other than those specified (Reg. §1.67-4(b)(3)), and of course the regular costs of investment advice (Reg. §1.67-4(b)(4)).
"Bundled" or unitary fiduciary fees must be allocated between costs that are covered (that is, subject to the 2 percent floor unless de minimis) and those that are not covered, in one of two ways. The allocation must be done on a strict tracing basis if the fiduciary pays covered expenses to a third party or charges an extra fee with respect to covered costs (such as "ownership costs")(Reg. §1.67-4(c)(3) & (4)) or if the fiduciary fee is calculated on the basis of an hourly rate (Reg. §1.67-4(c)(2)). Otherwise, only investment advice subject to the 2 percent floor must be separated out, or "unbundled" (Reg. §1.67-4(c)(2)), and that may be done by "[a]ny reasonable method" (Reg. §1.67-4(c)(4)). The regulations (Reg. §1.67-4(c)(1)) also contemplate exceptions to unbundling "to the extent provided … by guidance published in the Internal Revenue Bulletin," thus allowing the IRS to prescribe safe harbors and other exceptions without the formality of regulations (and ultimately that may be where the real law is made).
Initially, Reg. §1.67-4(d) would have applied "to taxable years beginning on or after May 9, 2014." That is, the regulations would have immediately applied to an irrevocable non-grantor trust created on or after May 9, 2014, and to the estate of an individual who died on or after May 9, 2014. In addition, the regulations would have applied prior to January 1, 2015, to an existing fiscal-year estate with a taxable year beginning between May 9, 2014, and January 1, 2015. But as for existing trusts with calendar years, the typical case the writers of the regulations must have had in mind, the regulations would have taken effect exactly on January 1, 2015. Upon publication of those final regulations, the American Bankers Association and 14 state bankers associations requested a delay in the application of the regulations so their members could properly develop procedures to comply with the regulations, particularly procedures to unbundle their fiduciary fees in compliance with the regulations. By an amendment released as T.D. 9664 on July 16, 2014, the writers of the regulations agreed and changed the effective date to apply to taxable years beginning on or after January 1, 2015.
The story of these regulations is the story of mistakes. It would be one more mistake, however, not to disclose that I was counsel for the taxpayer in Scott, one of the IRS victories that led up to these regulations, and readers should judge the objectivity of the following remarks with that in view.
In hindsight, it may have been a mistake that the House-Senate conferees on the Tax Reform Act of 1986 added the words "would not have been incurred if the property were not held in such trust or estate," now found in the second clause of section 67(e)(1), without explaining what they intended those words to mean. Then the courts that decided the cases in the context of expenses for investment advice made the mistake of failing to reach an interpretation of those words that would serve the simplification objectives of the statute. This, however, was the most forgivable mistake, because such an interpretation, while it would fit the framework and theme of the statute, would be subtle and complex, not a result judges like, and Congress had said nothing to help the courts.
Then there is the anomaly that after working on this regulations project at least since 2006 (when it first appeared on the Treasury-IRS Priority Guidance Plan), the drafters, who apparently intended a January 1, 2015, effective date by the use of the words "taxable years beginning on or after," overlooked common exceptions like fiscal-year estates and new estates and trusts. But this was quickly corrected and proved harmless in the long run.
As I have pointed out to the IRS in public comments on the proposed regulations, it was significant that the Supreme Court's Knight opinion found that its determination "may not be as easy in other cases, particularly given the absence of regulatory guidance," and that "Congress's decision to phrase the pertinent inquiry in terms of a prediction about a hypothetical situation inevitably entails some uncertainty." 552 U.S. at 194. Under the Supreme Court's jurisprudence of deference to regulations (see Mayo Foundation for Medical Education and Research v. United States, 562 U.S. 44 (2011)), this uncertainty in the absence of regulations would have permitted Treasury to find that administration expenses of a multi-beneficiary trust, other than perhaps the in rem expenses that follow the asset, were exempt from the 2 percent floor. Surely the drafters of the regulations were well aware of that option and their power to achieve it, unlike the courts. But Treasury and the IRS chose to trade that simple solution for a regime of incredible complexity, including unbundling, all under the flag of a statute originally conceived to relieve "significant complexity" and "extensive recordkeeping with regard to what commonly are small expenditures" (H.R. Rep. No. 99-426, 99th Cong., 1st Sess. 109 (1985)), an obligation a fiduciary would have in any event.
Apparently the way this came about was that the regulations were drafted with an inexplicable compulsion to follow the case law. This was true of proposed regulations published in 2007 when the Second Circuit's Rudkin opinion was the most recent word, and it was true again of the new proposed regulations published in 2011 that followed Knight. The drafters refused what was virtually an invitation from the Supreme Court to provide "regulatory guidance" to the courts and instead crafted a codification of the cases that just happened to have been litigated. Thus, for example, only investment advice was the subject of the litigated cases, and only investment advice is subject to unbundling under the regulations in the absence of an hourly rate or a discrete third-party payment or incremental cost. Even the use of the expression "investment advice" in the context of a bundled fee where the fiduciary in effect is imagined to give "advice" to itself is hard to explain except with reference to the factual patterns of the cases. By deferring to the judges who were eager to defer to them, the drafters missed the opportunity to lead.
That, being most avoidable, was the chief mistake.
The federal credit for state death taxes, still set forth in section 2011 but not applicable since 2004 under section 2011(f), was not changed from 1926 to 2001. Initially simply 80 percent of the gross federal tax (which explains why the rates in section 2011(b) increase in increments of 0.8 percent), it was isolated from the increases in federal rates enacted during World War II and in 1954 was codified into its own independent table in section 2011(b). Throughout this remarkable 75-year period of stability, states were encouraged by their own citizens to conform, couple, or tie their death taxes to merely "soak up" the amount of the federal credit, thereby maximizing their own revenue without any incremental burden to their own citizens. Almost all states did so, with New York's legislation, tying its tax to the federal credit in effect in 1998, being the last before the phase-out of the federal credit enacted by Congress in 2001.
The 2001 Tax Act notoriously changed that landscape, and chaotic diversity among states ensued. Rates, exemptions (applicable exclusion/credit), QTIP elections, and the deduction for the state tax itself (the "circular calculation") were among the differences from state to state, not to mention the large number of states that remained "coupled" to the terminated federal credit and hence had no tax. Slowly, states have embarked on a new century of conforming. In 2014, we heard from New York, Maryland, Rhode Island, and Minnesota.
New York and Maryland increased their exemptions on a phased basis until 2019, when they will be equal to the federal exemption, but New York's exemption will be phased out for estates between 100 and 105 percent of the exemption amount. New York also added a New York-only QTIP election, added a provision for inclusion of gifts made between April 1, 2014, and January 1, 2019, if made within three years of death, and repealed the New York GST tax. Rhode Island increased its exemption from $921,655 to $1.5 million, indexed for inflation, and Minnesota increased its exemption in increments to $2 million by 2018 – modest but in the right direction. Minnesota also retroactively repealed the gift tax it enacted in 2013. Meanwhile, the District of Columbia Council has passed legislation, currently under congressional review, to possibly increase its exemption to $2 million in 2016 and then to equal the federal exemption in 2018, but all subject to achieving revenue targets.
Despite the trend of this 2014 legislation and that of previous years, of course, there will never be the kind of estate tax uniformity there was before 2002, because in the absence of a state death tax credit a state's estate tax will always be an incremental burden on its citizens.
New York was also busy in 2014 on the income tax front, seeking to limit the loss of revenue from trusts that migrate out of New York or are created in other states by New York residents. For a trust with no New York trustees, no New York tangible personal property or real estate, and no New York source income, and thus exempt from New York income tax, there will now be a "throwback tax" (like California's) on income accumulated free of New York tax when it is later distributed to a New York resident beneficiary. And beginning in 2014 "incomplete gift non-grantor trusts" (e.g., "DING trusts" in Delaware and "NING trusts" in Nevada) created by New York residents will be deemed to be "grantor trusts" for New York income tax purposes, which will include the trust income in the New York grantor's income whether the income is distributed to the grantor or accumulated. These New York changes are the opposite of seeking conformity, bucking a recent trend of limiting a state's power to tax nonresident trusts. See Linn v. Department of Revenue, 2013 Ill. App. 4th 121055 (Dec. 18, 2013); Residuary Trust A v. Director, 27 N.J. Tax. 68 (N.J. Tax Ct. 2013); McNeil v. Commonwealth of Pennsylvania, Pa. Comm. Court, No. 651 F.R. 2010, 173 F.R. 2011 (May 24, 2013).
Number Four: Continued Wave of Domestic Asset Protection Trust Statutes: Mississippi Qualified Disposition in Trust Act, codified at Miss. Code §91-9-701 et seq.
Effective July 1, 2014, the Mississippi Qualified Disposition in Trust Act made Mississippi about the 15th state that permits a grantor to create an irrevocable trust, be a discretionary beneficiary of the trust, and receive spendthrift protection from creditors. Mississippi joins Alaska, Delaware, Hawaii, Missouri, Nevada, New Hampshire, Ohio, Oklahoma, Rhode Island, South Dakota, Tennessee, Utah, Virginia, Wyoming, and to some extent Colorado in offering this type of protection.
A unique feature of the Mississippi Act is that before the transfer to the trust the grantor must have in place a general liability insurance policy and, if applicable, a professional liability policy with policy limits of at least $1 million for each policy. This might make Mississippi a less attractive jurisdiction than some of the other states. Indeed, it has even been suggested that the possible loss of protection against creditors if the insurance lapses may prevent a transfer to the Mississippi trust from being a completed gift. Other disadvantages of Mississippi compared to some other states include its common law Rule Against Perpetuities and its state income tax.
Probably neither the addition of Mississippi as a state with a domestic asset protection trust statute nor the fact that it is the 15th such state is really enough to call such legislation a "wave." But there have recently been such additions almost annually and no significant opposition or objection has appeared. It is true that asset protection trusts with "bad facts" have not fared well in the courts and that we are still waiting for the first case to affirm their use. But for those who have been waiting for a Full Faith and Credit showdown, in which a resident's use of the statute of another state is challenged as offensive to the public policy of the state of residence, each additional state with arguably the same policy makes that less likely. Not only is the body of statutory law affirming domestic asset protection trusts growing, but the universe of states in which such statutes could be challenged as offensive to public policy is shrinking.
Woelbing. In these two docketed cases widely discussed in 2014, the Tax Court has been asked to consider a sale by Donald Woelbing, who owned the majority of the voting and nonvoting stock of Carma Laboratories, Inc., of Franklin, Wisconsin, the maker of Carmex skin care products.
According to the Tax Court petitions, Mr. Woelbing sold all of his Carma nonvoting stock in 2006 to a grantor trust in exchange for an interest-bearing promissory note in the amount of $59 million, the fair market value of the stock determined by independent appraiser. The installment sale agreement provided that if the value of a share of stock were determined to be higher or lower than that set forth in the appraisal, whether by the Internal Revenue Service or a court, then the number of shares of stock purchased would automatically adjust so that the fair market value of the stock purchased equaled the amount of the note. The trust's financial capability to repay the promissory note without using the stock itself or its proceeds exceeded 10 percent of the face value of the promissory note, including three life insurance policies on Mr. and Mrs. Woelbing's lives that were the subject of a split-dollar insurance arrangement with the company. The policies had an aggregate cash value of about $12.6 million, which could be pledged as collateral for a loan or directly accessed through a policy loan or the surrender of paid-up additions to the policies. At the time of the sale transaction, two sons of the Woelbings executed personal guarantees in the amount of 10 percent of the purchase price.
Mr. Woelbing died in 2009, and the IRS challenged the 2006 sale in connection with its audit of his estate tax return. The IRS basically ignored the note, doubled the value of the stock at the time of the gift to $117 million, again increased the value of the stock at the time of Mr. Woelbing's death to $162 million and included that value in his gross estate, and asserted gift and estate tax negligence and substantial underpayment penalties. For gift tax purposes, the notices of deficiency asserted that the entire value of the stock was a gift at the time of the sale, either because section 2702 applied to ignore the note or because the note in fact had no value anyway. For estate tax purposes, the IRS asserted that Mr. Woelbing retained for his life the possession or enjoyment of the stock or the right to designate the persons who shall possess or enjoy the stock under section 2036 and the right to alter, amend, revoke, or terminate the enjoyment of the stock under section 2038.
Thus, besides simple valuation, the Tax Court might be obliged to address the adjustment clause, the possible reliance on the life insurance policies and guarantees to provide "equity" in the trust to support the purchase, and the applications of section 2702 to the sale and sections 2036 and 2038 after the sale.
Williams. Similarly, in Williams the IRS challenged a partnership owning real estate and business and investment assets with a wide variety of arguments, including disregarding the existence of the partnership and treating transfers to the partnership as a testamentary transaction at the decedent's death, undervaluation of the partnership assets, lack of a valid business purpose or economic substance for the partnership, the decedent's retained enjoyment of the partnership assets, restrictions on the right to use or sell the partnership interest ignored under section 2703(a), liquidation restrictions ignored under sections 2703, 2704(a), and 2704(b), and any lapse of voting or liquidation rights in the partnership treated as a transfer under section 2704(a).
Comment. The everything-but-the-kitchen-sink approach reflected in these late-2013 Tax Court petitions, especially the Woelbing petitions, has chilled transactions that had been commonplace in estate planning, including installment sales to grantor trusts. Recent Administration proposals for legislation to reduce the benefits of sales to grantor trusts, even though they may not gain traction in Congress, serve to reinforce the perception of increased animus toward these transactions.
This comes as IRS review of gift tax returns filed for 2012 is hitting top speed. Most of those gift tax returns will be entering the third year of the three-year statute of limitations in 2015. With the lifetime gift tax exemption of $5.12 million headed for a return to $1 million if Congress failed to act, we know that many of these 2012 gifts were large, leveraged, imaginative, often done in haste, often accompanied with some form of defined value provision, and sometimes edging close to the boundaries of the reciprocal trust doctrine in the case of married donors. The public discussions of the 2012 gift tax landscape were interesting. The gift structures and related transactions we heard discussed were interesting. The gift tax returns – nearly 370,000 of them according to IRS statistics – must be interesting – the last thing we want a tax return to be. It is very possible that 2015 will bring word of more aggressive audits and that 2016 will see Tax Court petitions for which the Woelbing and Williams petitions were just a warm-up.
Elkins. The Tax Court decided Estate of Elkins v. Commissioner on March 11, 2013, but it did not make last year's Top Ten. On September 15, 2014, the Court of Appeals for the Fifth Circuit technically affirmed in part and reversed in part, but largely reversed. Maybe it's the slow year, but now it's gotten interesting.
The case involved a family that co-owned valuable artwork subject to a cotenancy agreement that required unanimous consent to sell any of the artwork and waived each cotenant's unilateral right to partition. On the decedent's estate tax return, the executors claimed a 44.75 percent discount reflecting the lack of marketability under the cotenancy agreement, and the time and expense of a partition action even if the agreement were unenforceable. In the Tax Court litigation, the estate claimed a valuation discount of nearly 67 percent, based on the views of art experts that no one would want a partial interest in the art without a very substantial discount.
The Tax Court (Judge Halpern) held that section 2703(a)(2) required that the restrictions on partitioning in the cotenancy agreement be disregarded. The executors had argued that the cotenancy agreement restricted the sale of each item of art, but did not restrict the sale of fractional interests owned by the cotenants, and thus should not be subject to section 2703(a). The court concluded that the cotenancy agreement had the effect of waiving the right of partition, and as such was a restriction "on the right to sell or use … property" within the meaning of section 2703(a)(2). Nevertheless, the court rejected the IRS assertion that there should be no discount and held that a 10 percent discount was available to reflect the lessened marketability of a tenancy-in-common interest in art. But it viewed the discounts claimed by the executors as unrealistically high because it viewed it as "false or at least highly dubious" that the Elkins children would endure such economic loss just to stand by the cotenancy agreement.
It is principally within the last few pages of its opinion that the Tax Court's reversible error lies. While continuing to advocate the willing buyer/willing seller test that controls this case, the Tax Court inexplicably veers off course, focusing almost exclusively on its perception of the role of "the Elkins children" as owners of the remaining fractional interests in the works of art and giving short shrift to the time and expense that a successful willing buyer would face in litigating the restraints on alienation and possession and otherwise outwaiting those particular co-owners. Moreover the Elkins heirs are neither hypothetical willing buyers nor hypothetical willing sellers, any more than the Estate is deemed to be the hypothetical willing seller.
In a footnote, the court suggested that it was not concerned with the fact that the estate tax return had employed a smaller discount, because "the IRS disallowed that discount." It did not mention section 2703.
Giustina. The Tax Court decision in Estate of Giustina v. Commissioner was featured in Number Seven in the 2011 Top Ten. Judge Morrison had valued a 41.128 percent limited partnership interest in a partnership conducting forestry operations by giving a 75 percent weight to a value of $52 million determined by a cash flow (going concern) method and a 25 percent weight to a value of $151 million determined by an asset value method. The court did this even though there was no evidence that a sale or liquidation was anticipated and, indeed, as the court summarized, "[t]he Giustina family had a long history of acquiring and retaining timberlands." The court assumed that although the owner of a 41.128 percent limited partnership interest "could not alone cause the partnership to sell the timberlands," it could join with other limited partners to compile the two-thirds vote necessary to replace the general partners or to dissolve the partnership.
In order for liquidation to occur, we must assume that (1) a hypothetical buyer would somehow obtain admission as a limited partner from the general partners, who have repeatedly emphasized the importance that they place upon continued operation of the partnership; (2) the buyer would then turn around and seek dissolution of the partnership or removal of the general partners who just approved his admission to the partnership; and (3) the buyer would manage to convince at least two (or possibly more) other limited partners to go along, despite the fact that "no limited partner ever asked or ever discussed the sale of an interest." Alternatively, we must assume that the existing limited partners, or their heirs or assigns, owning two-thirds of the partnership, would seek dissolution. We conclude that it was clear error to assign a 25% likelihood to these hypothetical events. As in Estate of Simplot v. Commissioner, 249 F.3d 1191, 1195 (9th Cir. 2001), the Tax Court engaged in "imaginary scenarios as to who a purchaser might be, how long the purchaser would be willing to wait without any return on his investment, and what combinations the purchaser might be able to effect" with the existing partners.
Simply changing the numbers in the section of the Tax Court opinion entitled "Value of the 41.128-Percent Limited Partner Interest" suggests that the reduction in value of the gross estate ordered by the Ninth Circuit will be about $11.5 million. The Ninth Circuit also found fault with the Tax Court's decision to cut in half the estate's expert's proffered company-specific risk premium, but left the door open slightly for the Tax Court to confirm its initial finding if it explained better.
The discussion of Giustina and another case in Number Seven in the 2011 Top Ten concluded by stating: "Together these cases illustrate that, probably on a judge-specific basis, an executor or donor who takes an estate or gift tax valuation case to the Tax Court, even involving an interest in an active business, can be in for a tedious and unpredictable time." Indeed. This case now goes back to Judge Morrison for recalculation by a going concern method. Meanwhile, August 13, 2015, will be the tenth anniversary of Mr. Giustina's death.
Comment. What is striking about these two cases is not as much that the courts of appeals reversed the Tax Court, or even that the Fifth Circuit and the Ninth Circuit are otherwise viewed as quite different in their friendliness to taxpayers. It is the way these opinions demolish these Tax Court judges' efforts to find a compromise result in the face of what may have been a very muddled record. The appellate courts treat the Tax Court judges as if they were making stuff up. The Tax Court, as the Fifth Circuit says, "inexplicably veers off course," or, as the Ninth Circuit put it, "engaged in 'imaginary scenarios.'" Harsh rebukes.
Regarding the appellate courts' concerns that the Tax Court had no evidence on which to base its conclusions, the clear implication is that the IRS is going to have to do more than just attack the taxpayer's witnesses; it will have to offer expert testimony of its own. Of course, as noted previously (in Number Seven), the IRS budget is being cut. But the stakes in these cases show why, as estate planners often remind their clients, the cost of a thorough competent appraisal is almost always justified. The refund in Elkins is about $14.4 million and the reduction in the gross estate in Giustina is about $11.5 million.
The principal issue in Giustina was the valuation of a family timber business; discounts were a much less prominent issue. Discounts were the only issue in Elkins; the undiscounted value of the art was stipulated. A discussion of even these disparate valuation cases, however, brings to mind the fact that valuation discounts, like sales to grantor trusts, have been on Treasury's radar screen for some time.
The Obama Administration's first four General Explanations of the revenue measures accompanying its budget proposals ("Greenbooks") included a proposal to "Modify Rules on Valuation Discounts" by bulking up Treasury's authority to promulgate "disregarded restrictions" that would be ignored in valuing interests in entities. That proposal was dropped from the 2013 and 2014 Greenbooks. Since 2003, the Treasury-IRS Priority Guidance Plan has included a project to prepare "Regulations under §2704 [presumably §2704(b)(4)] regarding restrictions on the liquidation of an interest in certain corporations and partnerships." That project has not been dropped, although other projects – decanting, charitable remainder trust forms, and private trust companies – have recently been dropped from the Plan. That fuels speculation about what Treasury is up to. Does dropping valuation from the Greenbooks indicate that Treasury has given up on the subject? Or does it mean that it has merely dropped the idea of expanding its statutory authority and will concentrate on completing the regulations project on the Priority Guidance Plan that it did not drop? Indeed, the very fine-tuned revenue estimates in the Greenbooks that contained this subject – expressed to the nearest million dollars over ten years with variations (downward) from year to year of $371 million, $501 million, and $87 million – could be viewed as clues that the desired regulations are already drafted or at least very tightly outlined. And that means that the release of the proposed regulations could be soon (although the same thing could have been said, and has been said, since 2003).
The most recent ten-year revenue estimate, in the 2012 Greenbook, was $18.079 billion, or $1.8 billion per year, or $4.5 billion of value taxed at a 40 percent rate. For rough comparison purposes, in 2012, the last year for which statistics are available, there were about 9,400 estate tax returns filed and about $8.5 billion of tax reported. On that basis, the proposal would increase estate tax revenues by about 21 percent or about $190,000 per return. These numbers are unreliable because they compare estimates for future years derived from Treasury economists' models with actual numbers from 2012, and they ignore gift tax returns. But, as far as they go, they portray a significant, but not staggering revenue effect. And regulations issued without the expanded legislative authority requested in the Greenbooks might have a lesser effect.
Again in the context of having just read about valuation cases, one must wonder if clearer and more objective rules in regulations would produce a more efficient and maybe even less expensive estate and gift tax return preparation and audit experience than the seemingly haphazard outcomes of the published cases. The results could be even more satisfying if, as the Greenbook descriptions stated, the contemplated regulations would "create safe harbors to permit taxpayers to draft the governing documents of a family-controlled entity so as to avoid the application of section 2704 if certain standards are met" and "make conforming clarifications with regard to the interaction of this proposal with the transfer tax marital and charitable deductions." The latter reference appears to contemplate overriding the harsh "reverse-Chenoweth" result seen in Technical Advice Memoranda 9050004 and 9403005 (wherein all stock owned by the decedent is valued as a control block in the gross estate, but the marital bequest is valued separately as a minority block for purposes of the marital deduction), relying on Estate of Chenoweth v. Commissioner, 88 T.C. 1577 (1987). Such a result would reinforce the fairness of the proposal and should be very welcome. Only regulations refined through a public comment process, not case law, can produce such holistic and evenhanded outcomes.
On the other hand, if new valuation regulations reflect no more courage and imagination than the section 67(e) regulations previously described (Number Six) and, like those regulations, attempt only to codify, not influence, case law, then they could be very disappointing indeed.
It is impossible to complete this list without looking at what everyone is looking at, without talking about what everyone is talking about – the political landscape after the 2014 elections. The election resulted in 54 Republican Senators (a pick-up of 9) and 247 Republicans in the House of Representatives (a pick-up of 14), the largest number of Republicans in the House since Herbert Hoover was President. It is possible that a majority of both the House and the Senate would favor the complete repeal of the estate tax.
In recent years, repeal discussions have been tempered by the fact that many who favored estate tax repeal (mostly Republicans but also some Democrats) appeared reluctant to put the estate tax in play, for fear of losing some of the gains of recent years, including the 40 percent rate and the high exemption indexed annually for inflation. With the Republican gains from the 2014 elections, that may not be as true anymore. Meanwhile, those who favor a more robust estate tax, returning to a variation of 2009 or even 2001 law, simply don't have the votes to gain traction. And while the Obama Administration has called basically for a return to 2009 law, the President has not pushed that. But the President might be inclined to veto a repeal of the estate tax, unless it was packaged with other sufficiently important measures that he favors.
Initial public indications of 2015 Republican priorities have not referred to the estate tax, and the estate tax is not included in the fundamental reform outlines and drafts that have originated largely with outgoing House Ways and Means Committee Chairman Dave Camp (R-MI) and incoming Finance Committee Chairman Orrin Hatch (R-UT), although many Republican leaders in both the House and Senate have voiced their support for repeal. This subject could be the most watched subject within the scope of these Top Ten observations as the congressional leadership forges its agenda in 2015. This commentary sees the odds against estate tax changes in the near future. But if that proves wrong, the subject is very likely to be Number One again in 2015.
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We have made it! Actually - the chicks have made it over the 3 week line. Even our youngest yellow-eyed penguin chicks are now 3 weeks old and that usually means that they are going to be ok and will fledge. We can relax a little and enjoy the little balls of fluff that are getting more adventurous and explore more outside their nest boxes.
Here dad has returned home from fishing and fed the chicks. He is now trying to do his duty of watching over them while not feeling to harassed for more food.
Yes, it is time to enjoy the chicks as they grow big and strong.


This has been mentioned ad nauseum, but it bears repeating that the universe of Phoenix Wright DOES NOT operate under United States laws. At best, the Phoenix Wright series uses law that parodies Japanese law. He even openly admits that the Phoenix Wright universe operates under a law that more closely resembles that of Japan than America..
While many of the recommendations have remained consistent with the last set of guidelines released in 2010 (such as advising the consumption of more fruits and vegetables, whole grains, lean meat, and low fat foods), the 2015 Dietary Guidelines for Americans introduces some new recommendations. For the first time, the USDA guidelines specifically recommend limiting added sugars to 10 percent of one's daily calories. Assuming the average adult American consumes 2,000 calories a day, adult men would be limited to a maximum of 10 teaspoons of sugar per day; but children, women, and those adults canada goose bodywarmer uk who consume fewer calories are advised to consume even less.
NASCAR uses a fuel can type known as a dump can to refuel its vehicles on a pit stop. The dump canada goose outlet price can is designed to release the fuel it holds into the vehicle within eight seconds. Each fuel can holds 11 gallons, so it takes two full cans to completely refuel a car.
The great irony is that Salaita himself is no champion of free expression. He has advocated excluding Hillel, the Jewish student organization, from minority group activities on campus, and he supports the boycott of all Israeli academic institutions and the barring of Israeli deans and rectors from scholarly conferences. His lawsuit against the University of Illinois included alumni and donors as defendants, on the spurious ground that they were not entitled to express their anti Salaita views to Chancellor Wise.
canada goose uk outlet Performance Tuning ASP/SQL Server applicationsDevelopers and DBAs have traditionally had a sometimes antagonistic relationship. DBAs getting upset with developers who don tweak their applications to avoid putting any strain on the precious databases, and developers being frustrated by the sometimes esoteric rules imposed on them by how SQL works. I been lucky having worked as both a developer (on COBOL and Focus on IBM mainframes down to hand crafting assembler on 8 bit micro processors) and a DBA (on DB2, Datacom/DB and SQL Server) so can see uk canada goose store reviews both sides of the equation canada goose uk outlet.


text:
Q: Kubernetes client Job create I am using kubernetes client (https://github.com/kubernetes-client/javascript) to create job and I have set up service account for the pod which is creating the job. However, I am getting this error when executing the job creation.
body: {
  kind: 'Status',
  apiVersion: 'v1',
  metadata: {},
  status: 'Failure',
  message: 'Job.batch "compiler-job" is invalid: spec.template.spec.containers: Required value',
  reason: 'Invalid',
  details: {
    name: 'compiler-job',
    group: 'batch',
    kind: 'Job',
    causes: [Array]
  },
  code: 422
},

I am sure there is something wrong with the body options that i am passing to k8sBatchV1Api.createNamespacedJob() but I am not sure what I am doing wrong. Here is the snippet of the manifest.
const kc = new k8s.KubeConfig();
kc.loadFromCluster();
const k8sBatchV1Api = kc.makeApiClient(k8s.BatchV1Api);

k8sBatchV1Api.createNamespacedJob('default', {
    apiVersion: 'batch/v1',
    kind: 'Job',
    metadata: {
        name: 'compiler-job'
    },
    spec: {
        template: {
            metadata: {
                name: 'compiler-job'
            },
            spec: {
                containers: {
                    image: 'perl',
                    name: 'compiler-job',
                    command: ["perl", "-Mbignum=bpi", "-wle", "print bpi(2000)"]
                },
                restartPolicy: "OnFailure"
            }
        }
    }
}).catch((e: any) => console.log(e));

Here is the serviceaccount.yaml file
apiVersion: v1
kind: ServiceAccount
metadata:
  name: create-job
  namespace: default
---
kind: ClusterRole
apiVersion: rbac.authorization.k8s.io/v1
metadata:
  namespace: default
  name: create-job-role
rules:
  - apiGroups: [ "batch", "extensions" ]
    resources: [ "jobs" ]
    verbs: [ "get", "list", "watch", "create", "update", "patch", "delete" ]
---
apiVersion: rbac.authorization.k8s.io/v1
kind: ClusterRoleBinding
metadata:
  name: create-job-rolebinding
  namespace: default
subjects:
  - kind: ServiceAccount
    name: create-job
    namespace: default
roleRef:
  kind: ClusterRole
  name: create-job-role
  apiGroup: rbac.authorization.k8s.io

Been spending almost a week and have no clue.

A: I think that might be because containers should be a list, can you try this?
const kc = new k8s.KubeConfig();
kc.loadFromCluster();
const k8sBatchV1Api = kc.makeApiClient(k8s.BatchV1Api);

k8sBatchV1Api.createNamespacedJob('default', {
    apiVersion: 'batch/v1',
    kind: 'Job',
    metadata: {
        name: 'compiler-job'
    },
    spec: {
        template: {
            metadata: {
                name: 'compiler-job'
            },
            spec: {
                containers: [{
                    image: 'perl',
                    name: 'compiler-job',
                    command: ["perl", "-Mbignum=bpi", "-wle", "print bpi(2000)"]
                }],
                restartPolicy: "OnFailure"
            }
        }
    }
}).catch((e: any) => console.log(e));


When I was growing up, my mommy, papa, and also live-in granny participated in a yearly spring cleansing routine. Springtime cleansing involved a full top to lower cleansing of every square inch of our home. Our household would invest at least 2 weeks deep cleansing, cleaning, as well as polishing everything to produce that spring-fresh sensation. And also I suggest every little thing. Since many of you are about to face spring cleaning, DealDash thought this article would help inspire you. And since you can get a ton of cleaning items on DealDash as well, you can go there at any time and pick up some items.
As for our home, would be outside on the ladder cleaning out the gutters, washing down the exterior siding of your house, and scrubbing the outside of the windows. When he was done, he 'd rearrange the items in the garage area. After that, he 'd be down in the garden passing on the compost pile in anticipation of growing the garden. This is just an example of what you can do to start spring cleaning with the items you can find from DealDash.
Inside, mom was always very busy washing every drape and window shoelace, then getting rid of the blinds so they could be washed by hand in the bathtub. Every light was diligently made to glimmer. The whole contents of the china hutch, including the china, crystal, and also silver, was washed, dried out, and also polished. Each furniture piece was cleaned then moved so the carpets could be scrupulously deep cleansed and also the wooden floorings buffed. When those tasks were full, there was likewise an attic and also basement that required attention. It's important to remember that when spring cleaning it's also important to get rid of old items and pick up new ones. You can head to DealDash right now and pick up new items at a great price.
Today's spring cleaning might not be as involved, yet when the warmer weather condition shows up, it's an ideal time to fun time to produce some brand-new energy by packing away winter clothes, participating in clutter control, as well as playing in the yard. And speaking of clutter control, let's touch on that before we end the article.
There's nothing like the entry of spring to cue us to remove mess and make area for brand-new opportunities. Clutter normally gathers gradually. We come to be made use of too coping with storage rooms packed with a lot of clothing and also shoes, kitchens loaded with old boxes of food and trashy catchall drawers, and work areas overrunning with piles of magazines, heaps of paper, and unfiled invoices. All that mess could leave us with reduced energy degrees, really feeling cranky, ineffective, as well as mildly depressed. It's never easy to begin washing your mess. But as springtime offers our bodies a ruptured of spiritedness, we could funnel that power into organizing our space. When it's done, you'll be feeling confident, achieved, as well as all set to delight in life! And the next thing I can recommend since spring cleaning can be so expensive, is head to DealDash to pick up supplies and equipment.
This entry was posted in Review and tagged spring cleaning on January 31, 2016 by .
Looking for a stand mixer can be really complicated given the various capacity, power, functions as well as devices offered in the marketplace from all the various designs. DealDash is going to make it easy. If you are aiming to acquire a stand mixer, you should understand your demands first because that will certainly aid you to limit your choices. You could just as easily head to DealDash right now and pick up a Kitchen Aid Stand Mixer, the kind of home mixers. Because once you know exactly what you are searching for in a mixer, then you could start searching for one that suits your requirements and also budget plan.
As a result, as a beginning, consider how you will certainly be making use of the stand mixer. As an example, do you bake bread commonly? The amount of individuals is there in your household that you need to bake for? By evaluating your needs, you can after that choose the capacity of the mixer and its power. If you are consistently making thick and also stiff dough in big quantities, you will certainly need a mixer that has a bigger bowl and also is effective sufficient to be able to manage your components effortlessly. On the other hand, if you have a little household and also on a regular basis, cook things in small quantities, such a large capacity mixer may not be what you're looking for, it might be hard to utilize to process the percentages of components you need.
Based upon your demands, you can look at the different mixers available on DealDash and then make a selection. You ought to also think about the sort of accessories that have the mixer. Most mixers that are offered for sale will certainly have the whisk, beater and dough hook as part of the package deal. But some mixers can also carry out a variety of various other jobs although they require the appropriate accessories that are typically sold individually by the suppliers. From grating cheese to grinding meat, the choices are there with specific stand mixer designs.
In terms of safety, it is suggested to select a stand mixer with an overload function built-in as well. While you must constantly comply with the equipment book in terms of length as well as speed of usage, it is still much better to have this feature offered to avoid the mixer from overheating. As we often utilize mixer greatly at specific times of the year, this is a sensible function to need to stay clear of having it malfunctioning when we require it the most.
When it comes to mixing action, you ought to try to obtain a mixer from DealDash that can cover as vast an area as feasible. Some mixers on the site are unable to blend the components effectively because they do not obtain close enough to the sides of the bowl. Normally, a mixer with the beater moving in one direction and the shaft spinning the other direction will cause the active ingredients to become a lot more evenly mixed.
Next, it is likewise much better to have a mixer which is more on the heavy side like a KitchenAid from DealDash. A weight regarding 25 pounds is a great start. This is considering that if you are going to blend huge quantities or thick dough, you need the mixer to be heavy enough to make sure that it will not bounce as well as move around your kitchen counter top.
Lastly, you should also look at the durability of the mixer. Some mixers are much more expensive than others yet they could have an all-metal design, consisting of the gears, which need to be able to last you much longer. And finally, go to DealDash right now, stop wasting time. You'll find a mixer you want for an incredible price.
This entry was posted in Review and tagged stand mixer on January 30, 2016 by .
It is essential that you urge your kid to be innovative in their play. DealDash wants to help your kids use their imaginations so they can learn how to play by themselves, play en masse with others as well as improve their language and cognitive capabilities. When your youngster plays dress up as well as make believe games they could endure their dreams and also dreams. Using items like child kitchens and tool sets is perfect for helping teach your kids how to be creative.
You could locate many different kinds of playthings as well as video games that will urge your youngster to be innovative in their play. Some of the popular things consist of pretend kitchen areas with pretend food, horticulture toys, playthings that permit them to act to tidy, cash registers and also various other toys taking care of money, puppets, dolls as well as spy toys. Many of these you can find right now on DealDash at an incredible price without having to search all over. Your child will love being there in their little kitchen you can find on DealDash with you while playing. You could find a great deal of playthings that will allow your youngster to cook right along with you. The listing of playthings is readily available and virtually unlimited as well. You can find everything like pretend picnic collections with food and spices, cooking collections, complete tea party sets, pots and pans, full collections of dinnerware (these generally like cups, plates, bowls and silverware) and pretend coffee makers.
They make amazing play kitchen areas these days that have sensible microwaves, fridges, stoves, dishwashing machines as well as even more. These play cooking areas typically like sounds and lights to make them show up much more sensible. You can additionally locate real ovens and also microwaves that will allow your children to cook together with you. Head over to DealDash right and you can find all these things at an incredible price right now instead of waiting. One more excellent toy your youngsters would certainly love is a pretend food store with a cash register so they can check out with their grocery stores. There are endless opportunities for pretend and creative play.
All young children prefer to play dress up with their mom and dad's clothes. You could discover a bunch of spruce up apparel sets that have garments, accessories as well as even more to keep your children hectic for hrs. You could discover certain things your children will love consisting of cops outfits, fire fighter costumes, registered nurse and doctor outfits. These outfits typically include enjoyable devices like sticks, hats, ballet slippers, boas, capes and also tights, packed pets, baby dolls, serving trays and also food, princess pretty tiaras and anything else you could think about. Your child and also their buddies will love dressing up in these costumes and also acting out their own stories. Look on DealDash right now and you can find a ton of items that your children will love.
That would be both enjoyable and also educational. When your youngsters are little they will like to help you clean around your house too. This won't last long though so appreciate it while you can. There is a great deal of various housekeeping toys available and other adorable playthings that your kids will love. These toys will certainly help your youngsters enhance their tiny living skills as well as learn about taking care of themselves. Now that you've read this post and you know how to help your kids play in a creative way, the next step is to go to DealDash and pick up some great items at an excellent price.
This entry was posted in Review and tagged creative on January 29, 2016 by .
Cellphones nowadays are a treasured and valued possession. In recent years, it has ended up being the target of burglars and thieves. DealDash is ready to help you take better care of your most precious possessions. So, if you have a high treasured android or cellphone, let's state the top of the line, you need to comply with a certain way of taking care of your cellphone. It's far better to care for your phone properly instead of dealing with it being lost or stolen. Even if your mobile phone is just the ordinary design, avoid losing it from carelessness or from hold-ups or pickpockets. There are sensible methods to prevent this condition. Let DealDash fill you in on some tips, also, you can go to the DealDash website right now and pick up a wide variety of phones and accessories for your liking.
Make it a daily routine to be completely familiar with where your cellular phone device is. Consider it as part of your underclothes. Know where it goes to all times. You will be shocked that in just 10 days of this day-to-day way of life understanding and consciousness, your mobile phone will be cared for similar to your wedding ring or your watch. It is already a strong part of your being. And if you have a nice case like those you can pick up on DealDash you can rest assured that you phone will be safe when you drop it, which is sure to happen at some point.
Maintain and clean it consistently in routine areas when you remain in your residence whether in your living room or room, etc. As soon as you establish this behavior of caring for your cell phone, you will certainly not have any problem regarding its place. When you are in your office, use the same system of care. If you are in the habit of bringing it, it is much better to place it inside your bag, once more, in a predetermined place. Once you always know where it's at you'll be able to keep a better eye on it and keep it safe. There are several other useful means of dealing with your cellular phone. If you take care of it similarly as your other valuables, you will certainly keep yourself from losing it.
Yet consistently remember this one point. When you get involved in a harmful situation with a thief who wants your phone, do not stand up to them. Merely provide it to them. Your life is a million times more valuable than the priciest first-rate cell phone! And you can pick up a cellphone at DealDash really cheap so you won't even have to worry about it. And you may as well even go check some out right now so you can have a backup phone for when you need it.
This entry was posted in Review and tagged cellphone on January 28, 2016 by .
Developing the best ambiance at home relies on choosing merely the best components for your living areas. Accent lights is one means to produce a mood in an area by lighting layout selections in the area or merely to establish the tone. DealDash is going to explain this sort of lights and you can use them to change the feeling of your home, yet just to create a sensation of warmth in the space. You can also find lamps and lighting on DealDash as well as some nice, unique art pieces.
Illumination in a home is selected based on its use. As an example, if you are lighting a room where job will certainly be executed such as a kitchen area, the illumination must have the ability to light up the job. These lights are brighter than the lights that are used in a living room or room. Use a light from DealDash to create an environment in a room, you should prepare to have a variety of lights in the area to ensure that the degree of lighting is under your control.
For instance, when you need brighter lights for job or reading, the light degree can be shown up in the space. For a night of silent conversation or television watching, the lights can be lowered. You may have to experiment a little to discover the ideal areas to place lights and also lights installations. Try a lamp from DealDash in a certain location of the room as well as deal with it for a while to establish just how it impacts the environment in a space. You can head to DealDash right now instead of waiting and pick up a new lamp or set of them for your home.
Accent lights are more of an attractive touch than they illuminate a space. The light that focuses on a particular painting is an accent light. Tone lights could focus illumination on the wall without being focused on art work to create an ornamental touch to your room.
When you are making a room, light is equally as crucial as colour to the area. The appearances that you utilize together with colours as well as light all incorporate to develop a sensation in the area. An area can feel larger if the dark edges are lit up as well as a huge room can feel warm and comfortable as well as cozy if the illumination is cozy and also lowered. A lamp from DealDash can change the entire feeling of a room without even having to paint.
Select fixtures for your wall surfaces that fit in with the design of the space. There are several ranges of sconces and also components that can be mounted at home to coordinate with the various other attractive touches at home. Work with modern installations for a contemporary space or antique components when your space has a vintage design.
Working with the correct lighting for a room is a lot more complicated than you could assume. But if you pick up some lights from DealDash, you can make things happen easy without having to buy a bunch of expensive lights. It takes some time to produce the right feeling in a room. Determine exactly what you want to complete with your lights prior to you mount installations as well as position them in an area. Layer the lighting so that you can boost or lower the degree of light in a room. The level of light that you choose for an evening at home with the family members may be various compared to the way you will certainly light the space for a party with friends. A well selected room has the appropriate touches of colour and also textures together with the ideal lights to illuminate it all. Now that you have a good understanding of how to use accent lighting, head on into DealDash and see what you can find.
This entry was posted in Review and tagged lighting on January 27, 2016 by .