This article was published in the Chamber of Tax Consultants' Journal – January 2014.
Since the opening up of the economy almost two decades back, many non-residents have found favour with investments in India. This article aims at discussing the various provisions and issues related to taxation of capital gains earned by non-residents in India.
Taxability in India of capital gains earned by Non-residents.
Computation of taxable capital gains.
Applicable Tax Rates for capital gains under the Act.
Taxability of capital gains under the DTAAs.
Special provisions for gains earned by Non-resident Indians.
Taxability of gains earned by FIIs.
Taxability of gains on transfer of bonds and GDRs.
Taxability of gains earned by QFIs.
Taxability of gains earned by FVCIs.
Taxability of gains earned by Offshore Funds.
"Indirect transfers" – taxability and issues.
Section 5 of the Income-tax Act ("the Act") provides for the scope of income taxable in India for non-residents. Section 5(2) of the Act provides that income which is received; accrues or arises; or is deemed to accrue or arise to a non-resident in India is taxable under the Act.
Section 45 of the Act provides that any profits or gains arising from the transfer of a capital asset effected in the previous year shall be chargeable to tax under the head "Capital gains" and shall be deemed to be income of the previous year in which the transfer took place.
A cumulative reading of the above provisions results in capital gains arising in the hands of a non-resident in India if the transfer of the capital assets happens in India.
For example, take a case where an Indian house property is transferred by one non-resident to another non-resident outside India, i.e., the contract for sale is executed outside India and full price is paid outside India. As per Section 5, tax on gain would not be chargeable to tax in India as transfer happens outside India. However, as per Section 9 as the property is situated in India, the gain is deemed to arise in India.
from capital assets situated within India.
taxability in India of overseas transfers. Now an indirect transfer is taxable in India if it satisfies the conditions laid down in section 9. A detailed discussion on 'indirect transfers' is made in Para 11.
India has entered into Double Tax Avoidance Agreements (DTAA) with several countries. As per Section 90(2), taxability for non-residents is determined as per the provisions of the Act or the applicable DTAA, whichever are more beneficial. Capital gains under the DTAA are generally taxed in a different manner than other incomes. The provisions are discussed in Para 4.
A substantial benefit available to both residents and non-residents is exemption from income-tax under Section 10(38). Long-term capital gains earned on transfer of equity shares or units of an equity-oriented fund on which securities transaction tax (STT) is paid at the time of sale, are exempt. This provides a major relaxation in the taxation of capital gains in the hands of non- residents. Quite a few older provisions providing reduced rates of tax for long-term capital gains have been rendered largely ineffective due to this exemption.
Once the gains are determined to be taxable in India, as per the Act or the DTAA, computation of such gains would be determined as per the provisions of the Act. Computation mechanism for capital gains is not provided under the DTAAs. Section 48 provides the mechanism to compute capital gains earned in India.
As per Section 48, the full value of consideration received on transfer is to be reduced by the expenditure on transfer and the cost of acquisition or improvement. However, this computation is to subject to certain adjustments as required by the provisos to Section 48.
purchased out of foreign currency.
In such a case, capital gains shall be computed by converting the amount of sale consideration into the same foreign currency as was used at the time of purchase. Thus the proviso, in essence, prescribes computation of capital gain in foreign currency. Such conversion neutralises the impact of any fluctuation in the value of rupee.
Rs. 15,000 in Rupee terms on sale of the securities. However, in USD terms, he would not have earned any gain.
As per this provision, taxable gains would be computed in the same currency as was utilised at the time of purchase. Hence, the non-resident's capital gains would be converted into USD. This would result in nil taxable gain for the non-resident.
Does the tax payer have an option to choose applicability of this provision?
The objective to introduce this provision was to provide protection to non-residents from devaluation of the rupee. However, it applies also when the rupee appreciates in value.
Therefore, on application of the first proviso to Section 48, the non-resident stands to pay tax on foreign exchange gain earned on appreciation in value of Rupee.
One view is that this provision is a relief giving provision. Hence if there is an increase in the taxable gains, the provision does not apply.
The Central Board of Direct Taxes (CBDT) has issued a circular at the time of enactment of this provision3. It states that – "The non-resident Indians who invest in shares and debentures of Indian companies have been representing that due to the fall in the value of the Indian rupee vis-a-vis the foreign currency in which the investment is made by them, they are adversely affected when they sell such shares or debentures. In order to overcome this situation, sub-section (1) of section 48 of the Income-tax Act has been amended …". The intention may have been to give relief only in case of fall in the rupee value. On rupee appreciation, no adjustment may be required.
While the provision would have been brought into law with the above intention, the language does not support any option for the tax payer. It merely states that capital gain is to be calculated in foreign currency. It does not mention that the conversion is to be done only in case of devaluation of rupee.
This may also be right as practically any non-resident would calculate the gains in his home country's currency, and not in Indian rupees. The provision in that manner neither benefits him, nor puts him at any disadvantageous position when computed in foreign currency. In my view, this is a mandatory provision.
Is this benefit available to shares or debentures gifted or inherited?
Assume a case where shares or debentures purchased out of foreign currency are acquired by the non-resident seller on account of gift or inheritance. In such a case, the seller has not himself purchased the assets out of his own foreign currency. Can the benefit be denied in such a case?
The proviso does not lay down any condition for purchase of the shares or debentures, except for the fact that it should be out of utilisation of foreign currency. If the shares or debentures are purchased out of foreign currency by the original owner, in my view, capital gains earned by a non-resident would be covered within the provision for foreign exchange fluctuation adjustment.
Whether adjustment is from date of investment or date of remittance?
Whether the non-resident seller can claim adjustment for the devaluation of Rs. 5,000 incurred between the date of remittance and date of purchase?
The provision states that conversion has to be done for the cost of acquisition. As per the Rules4, the prescribed date for conversion of cost is the date of purchase. Therefore, protection against devaluation between date of remittance and date of purchase may not be available to the non-resident.
How does one apply this condition? What is the meaning of reinvestment thereafter? What should be the rate of foreign exchange for converting the cost of shares? Should we take the rate as on the date of re-investment, or should we take the original rate when funds were first invested?
For example, the non-resident investor has reinvested the sale proceeds of Rs. 60,000 from the example above in 2013. The cost of such shares was Rs. 45,000 when purchased in 2011.
In the above example, the amount of reinvestment is Rs. 60,000. However, the amount which had been invested out of foreign currency is only Rs. 45,000. Does the computation as per this provision apply to reinvestment of the original amount of Rs.. 45,000, or the sale proceeds of Rs. 60,000? The excess over Rs. 45,000 (i.e., 15,000) comprises of rupee funds earned in India. There is no foreign currency utilisation at all.
In my view, one may take a logical view. The objective is that for non-residents, the gain should be computed in foreign currency. In case the initial remittance was from foreign currency, adjustment can be done for the subsequent reinvestment out of the initial investment. Therefore one should convert the whole amount of reinvestment for such adjustment; and the rate to be applied should be the rate of foreign currency as on the date of reinvestment.
The second proviso to Section 48 provides protection from inflation in India. This enables the assessee to compute gains after increasing the costs by prescribed indexation factors. The loss on account of inflation is offset to a limited extent in this manner.
Provisions of 'indexation benefit' and 'foreign exchange fluctuation adjustment' are mutually exclusive. Therefore, indexation benefit applies to non-residents only for capital assets other than those for which foreign exchange fluctuation adjustment applies (for example, for house properties, etc.). CBDT5 has been clear in its view that as protection is already provided for forex fluctuation under the first proviso to Section 48, which takes into account inflation, further relief under the second proviso will not be available.Indexation benefit is available for both residents and non-residents. However, unlike the first proviso, the benefit is restricted only to long-term capital gains, and not short-term capital gains.
Tax liability in the hands of non-residents on capital gains is determined by Section 111A, Section 112 and the 'rates in force' as prescribed under the Finance Act. Surcharge and education cess, as applicable, are added to these rates.
It should be noted that under Section 111A, marginal relief is not available for non-resident individuals or HUFs. Further, beneficial slab rates applicable for senior citizens or very senior citizens as per the 'rates in force' are not available for non-residents.
Section 112(1)(c) read with proviso to Section 112(1) and Section 10(38) provide the tax rates applicable for long-term gains earned by a non-resident.
20% tax after availing 'indexation' benefit.
Marginal relief available for resident individuals and HUFs is not available for non-residents.
Lower rate of tax available for "foreign currency" securities?
Proviso to Section 112(1) states that where long-term gains are earned on sale of listed securities or units, the tax rate applicable would be restricted to 10%. This lower rate of tax is applicable on gains computed "before giving effect to the provisions of the second proviso to Section 48", i.e., on gains earned before taking indexation benefit.
The proviso to Section 112(1) has led to a controversy with regard to sale of listed securities or units purchased in foreign currency. As discussed in Para 2.3 above, in case of shares purchased out of foreign currency, adjustment for foreign exchange6 is applicable and not the indexation adjustment7.
restricted to 10%. In this manner, benefit of both the lower rate of tax, as well as the forex fluctuation adjustment, is obtained.
The tax department's view is that the lower rate of 10% applies only for capital gains where indexation benefit is applicable and can be obtained. If indexation benefit is not available, such long-term gains would be taxable at 20%, and not at a lower rate of 10%.
The above differing stands have led to litigation. Taxation at the lower rate of 10% after foreign exchange fluctuation adjustment has been upheld in quite a few decisions8 of the Authority for Advance Ruling (AAR) as well as the Income Tax Appellate Tribunal (ITAT).
the lower rate of tax, it could have done so by explicitly stipulating the same in the Act. Certain inconsistencies in this interpretation were also held not to be a ground for reading Section 112 differently.
This decision has reversed the ruling of the AAR10 in the same case, wherein it was held that the words "before giving effect to" used in proviso the Section 112 can come into play only if the assets sold are first qualified for indexation benefit. Thus, the beneficial rate of 10% tax is not applicable for foreign currency securities to which the indexation benefit is not available. This view was also supported in a decision of the ITAT11.
While the High Court has laid down the favourable position for the taxpayer, one should be careful while obtaining benefit under both provisions. Such an interpretation can lead to litigation.
Capital Gain is discussed in Article 13 of the OECD & UN Models12. The Models provide that gains from alienation of assets are taxable in the Country of Residence (COR), i.e., where the seller is a resident. For some assets, Country of Source (COS) is also given the right to tax, i.e., where the asset is situated (situs of asset). Generally, the country, which has the right to tax the income from the asset, is given the right to tax gains from the sale of such assets.
full / partial / or no rights to tax13.
In very few DTAAs (e.g., India-UK & India- USA), it is provided that each country can tax capital gains according to its own domestic law.
If the DTAA permits India to tax the capital gains, India can tax it as per its domestic law. The computation, disallowance, exemption, rate of tax, etc., apply as per domestic law. India may tax the gain as capital gain or any other income.
The taxation of Capital Gains is based on the kind of asset sold. The details are discussed with reference to the UN model.
Basic rule as per Article 13(1) - Capital Gain earned by a resident of a Foreign Country on sale of immovable property (situated in India), can be taxed in India. The Foreign Country can also tax the Capital Gain.
It is immaterial whether property is residential or commercial. It is also immaterial whether immovable property is a capital asset, or stock- in-trade. The COS can levy tax.
As per Article 13(4), if a non-resident earns gains from sale of shares of the capital stock of a company, or an interest in a partnership, trust or estate; and the property of such a company, partnership, trust or estate consists, directly or indirectly, principally of immovable property situated in COS, the COS can tax the gains. COR can also tax the gains.
It is not necessary that company, partnership, trust or estate should be in India. What is relevant is the situation of property. If the property is in India, and is owned by an Indian entity or a foreign entity; then on sale of shares or interest in the entity, India can tax the income.
India did not tax gains if the shares or interest were outside India as there was no such system in India. However, with effect from A.Y. 2013- 14, if immovable property is held through a foreign company, and the value of the share is substantially derived from the value of immovable property, then the shares will be deemed to be located in India. [Explanation 5 to section 9(1)(i)]. Tax will be levied according to the tax payable on sale of shares.
Capital Gains earned by a resident, arising from sale of movable property, which is a part of the business property of a permanent establishment (PE) or a fixed base (FB) in India, can be taxed in India. It can also be taxed in the COR. The property would usually be equipments, computers, furniture and other assets used in the business. Most of the assets would form a part of "block of assets" under the Act. Gain would be taxable as short-term gain under section 50 of the Act.
movable property pertaining to the operation of such ships, aircraft or boats.
the same can be taxed ONLY in the Contracting State in which the place of effective management of the enterprise is situated. India CANNOT tax the Capital Gain. This is in line with the taxation of income earned from operating ships and aircraft in international traffic which are taxed only where effective management is situated.
However, immovable property pertaining to operation of ships or aircraft (e.g. office premises in source country), can be taxed under Article 13(1) in COS.
Basic rule – If a resident of Country A sells share of an Indian company, and the shares exceed a certain minimum percentage of investee's capital, then India can tax the gains. Country A can also tax the gains.
The above clause is present in U.N. Model 2001 and most of the DTAAs signed by India. U.N. Model 2011 has a slightly different clause. Please see example below.
This clause is not there in some of the DTAAs entered into by India. Therefore if shares of a company are sold, the COS cannot levy any tax under this clause.
A resident of, say, Country A owns shares equal to 20% of the Indian company's shares. The shareholding prescribed in the DTAA with Country A is say 10%.
If he sells shares equal to 5%, will the same be taxed in source country? The words used are "Gains …. representing a participation of 10% ….". Shares being sold, represent only 5% (less than 10%). Therefore can the source country tax the capital gains? The DTAA or the Commentary does not provide an answer. The purpose appears to be that if there is substantial holding, then source country gets the rights to tax, whatever may be the number of shares sold.
If he sells shares equal to 15%, will the same be taxed in source country? The answer is yes.
The UN Model of 2011 states that if "at any time during the 12 month period preceding such alienation, if the alienator directly or indirectly held at least ____% of the shares", then the same will be taxable in India.
alienation. Also, the shares can be held "directly or indirectly". The previous UN model did contain these tests of 12 months and direct and indirect holding.
Some DTAAs have a slightly modified clause. As per the India-Netherlands DTAA, "alienation of shares…which form part of at least a 10 per cent interest in the capital stock of that company, may be taxed in that other state if the alienation takes place to a resident of that other State." Therefore, when a sale takes place of even one share of an Indian company, which forms part of at least a 10% holding, India can also tax such transfer. However, such gain is taxable in India only if sale is to a resident of India.
Basic rule – If a resident of a foreign country sells any property other than those mentioned in the above paras, it is taxable only in that foreign country. India cannot tax the same. This is the residuary clause. Some assets which can fall under the residuary clause are know-how, units of a mutual fund, bullion, etc. Sale of these assets will not be taxable in India.
This residuary clause in Mauritius, Singapore and some other DTAAs has been used to claim relief from taxation on Capital Gain in India on sale of shares, as shares in general fall under the residuary clause in these DTAAs.
the new ones (including the India-Malaysia DTAA of 2001), provide that if the income arises in COS, then income can be taxed in COS. Whether income is considered to arise in COS, depends on domestic law of the COS. For example, if the asset is situated in India, India will be able to tax such gain.
India's DTAA with Mauritius has led to several controversies. As per Article 13(4) of the DTAA, the right to tax capital gains derived by a resident of Mauritius is only with Mauritius. India does not have a right to tax such gains. Further, capital gains are not taxable in Mauritius as per its domestic tax laws and thus, a Mauritius tax resident earning capital gains in India does not have to pay tax in either country. For example, shares of an Indian company sold by a Maurtian tax resident would not suffer any tax in either country. Therefore, Mauritius has been a preferred tax jurisdiction for inbound investments.
There has been considerable litigation on this benefit of double non-taxation enjoyed under this DTAA. The tax authorities have alleged that investors using the India-Mauritius DTAA are indulging in treaty shopping as they lack commercial substance in Mauritius. The CBDT in its Circular No. 789 stated that wherever a Tax Residency Certificate is issued by the Mauritian Revenue Authorities, it will be sufficient evidence for residence and beneficial ownership for applying the provisions of the DTAA. The Supreme Court in Azadi Bachao Andolan14 upheld the validity of this circular.
income accruing thereon. The Court further held that both the circular and the Supreme Court decision in Azadi Bachao Andolan are not applicable to the facts of the case as the gains may not have arisen to a Mauritius taxpayer.
Therefore, the issues under the Mauritius DTAA stay alive and clarity may come only once the DTAA is revised.
Singapore DTAA has a favourable clause for gain on sale of shares. If a resident of Singapore sells shares of an Indian company, the gain is not taxable in India16. I understand that it was brought about at the request of Singapore Government as Mauritius DTAA has a similar benefit.
Clause (2) of the LOB clause provides that a shell/conduit company which claims to be a resident of Singapore, will not be entitled to the benefits of Capital Gain relief. It may be noted that this is an independent test, not related to the first test of "Affairs".
(3) and (4) of the LOB clause.
Clause (3) provides that the entity will be a shell company if its total annual expenditure on operations in Singapore is less than S$ 200,000 in Singapore. Thus if the company is to be considered as a bona fide company for this clause, it must spend at least S$ 2,00,000 per year on its operations in Singapore. The expenditure has to be incurred over a period of 2 blocks of 12 months immediately preceding the month in which the Capital gain arises.
the total annual expenditure on the operations is at least $ 2,00,000 in the immediately preceding 24 months from the date of sale.
The India-Cyprus DTAA also provides for similar benefits on capital gains as the India- Mauritius DTAA. Therefore, no tax is payable in India on sale of shares in an Indian company by a tax resident of Cyprus.
All parties to transactions with a person in Cyprus shall be treated as associated enterprises and the transfer pricing provisions will accordingly apply. Additional documentation as prescribed will be required to be maintained.
Any payment on which tax is deductible at source and made to a person located in Cyprus, will be liable for deduction of tax at source as per the rates under the Act or 30%, whichever is higher.
Jurisdictional Areas. However, it does not deny the benefits available under the DTAA. As mentioned earlier, capital gains earned in India will not be taxable in India as per the DTAA with Cyprus.
Therefore, the above provision for deduction of tax at source at higher rate will not apply to such capital gains. In my view, while this stand is correct, it should be noted that once these anti-tax avoidance provisions are enforced, the transactions will be scrutinised thoroughly. An Indian resident must obtain and maintain all required details for even tax exempt transactions.
The India-UAE DTAA had a beneficial clause for taxation of shares. If the UAE resident earned capital gain on sale of shares, it was not taxable in India. However in March 2007, the DTAA has been amended by a protocol. As per the protocol, capital gain earned on sale of shares will be taxable in India.
Overall, the DTAAs generally do not give any benefit for immovable properties situated in India, or for properties of PEs in India. However, significant benefits may be available for capital gains on sale of shares under certain DTAAs.
Impact of DTAAs on taxation of FIIs is dealt with in para 6.2 and their impact on taxation of 'indirect transfers' is discussed in detail in para 11.7.
Non-resident Indians (NRIs) have enjoyed a beneficial tax treatment in India as compared to other non-residents. While the general provisions explained above are equally applicable to NRIs, special provisions of Chapter XII-A – Sections 115C to Section 115-I – are applicable for taxation of certain incomes earned by NRIs.
As discussed in the preceding paragraphs, long-term capital gains earned on sale of listed securities where STT is paid are exempt from tax under Section 10(38). Long-term gains earned on transfer of unlisted securities are taxable at 10% as per Section 112. Further, benefits of slab rates are not available under both Section 115E and Section 112.
those earned on listed securities which are not exempted under Section 10(38), i.e., which are not traded on a stock exchange. As per Section 112(1)(c)(ii), such gains are taxable at 20% as compared to 10% under Section 115E.
There is an issue on whether specified assets being 'deposits with an Indian company' include deposits held with banking companies. Under Chapter XII-A deposits with companies other than 'private companies'20 are covered. Banks are companies, though regulated under the Banking Regulation Act. Further, most Indian banks are public companies. They are not private companies as per the definition under the Companies Act. Therefore, deposits with banking companies should be covered under Chapter XII-A. Judicial precedent21 in this matter also supports this view.
However, deposits with branches of foreign banks would not get covered under the above definition as these foreign branches are not 'Indian companies'.
'income' as per the Act, and hence would be covered under the definition of 'investment income'.
'Investment income' is to be considered as a phrase distinct from the definition of 'income' in the Act. While the 'income' definition covers capital gains, the same cannot be covered under the phrase 'investment income'.
If benefit was to be provided to short-term capital gains, the same would have been specified in the Act clearly as is done in other sections.
The exclusion of short-term gains from the benefits of Section 112 is with the specific purpose to restrict the outflow of hot money. The concessional tax rate is extended to traders or investors who are dedicated to the Indian market for a sufficiently long time thus deriving income like dividends, interest, or long-term capital gains.
"Income derived from any asset" should flow from the use of the asset, and not from capital realisation on sale of the asset. The legislature did not intend to give benefit to short-term capital gains although short-term capital gains for the purposes of the Act remains part of 'total income' within the meaning of Section 2(45).
In my view, the decision of the Mumbai Tribunal is correct. If benefit of lower rate of tax was to be provided to short-term capital gains too, it should have been specifically mentioned in the Section.
Foreign Institutional Investors (FIIs) have had a chequered past with the Income-tax authorities in India. While the Income-tax Act has provided for streamlined provisions for taxation of FIIs, there have been several attempts to bring to tax the incomes earned by FIIs to tax at higher rates. There has been a "tug-of-war" between the FIIs and the tax department.
Under the Income-tax Act, taxation of FIIs is governed by Section 115AD. Sub-accounts of FIIs would also get covered under Section 115AD.
The major difference in the above tax rates is for short-term gains on which STT is not paid. While for foreign companies the tax rate for such gains would be 40%, FIIs are taxable only at 30%.
It should be noted that as per Section 115AD(3), the computation of capital gains has to be done without taking into effect the first and second provisos to Section 48.
Singapore and Cyprus, the Capital Gain will be taxable only in those countries as COR. As these countries have no tax on Capital Gains under their respective domestic tax laws, the gains can be earned tax free.
If the income is considered as Business Income, then in absence of a PE in India, India cannot tax the income. It is an accepted fact that if one conducts the transactions in a manner whereby it amounts to trading, then the income will be considered as business income.
Different FIIs have taken different stands – Capital Gains or Business income – and succeeded to have tax free incomes under both claims.
earned by FIIs. Therefore, for incomes covered under Section 196D, deduction of tax at source will not be determined as per Section 195.
Section 196D provides that no tax is required to be deducted at source from capital gains earned by FIIs. Therefore, short-term capital gains or long-term capital gains, which may otherwise be taxable in India, can be paid to an FII without deduction of tax at source.
However, it should be noted that FIIs are still responsible for paying any tax on such incomes in their own capacity by filing their tax returns.
The major issue that arises in taxation of incomes earned by FIIs is whether the income is in the nature of capital gains or business income. As tax rates applicable can be quite different for business incomes as compared to capital gains, there is litigation on this issue.
Whether the activities are regular and allied; or occasional and incidental?
Whether the number of transactions is substantial?
Whether the intention to invest is to earn dividends or profits on sale?
Whether the treatment in books is as investments or stock-in-trade?
Whether own funds are utilised or borrowed funds?
It should be noted that there can be a number of other factors; and that this issue needs to be decided based on a cumulative reading of all the factors and not any one of them.
The decisions which have dealt with this issue in relation to FIIs have brought out additional factors that can determine the nature of income earned.
In the case of Fidelity Advisors,28and XYZ/ ABC Equity Fund29, the Authority ruled that the transactions by the FIIs amounted to business income. Article 7 of the relevant DTAA will apply. In absence of a PE in India, the income cannot be taxed in India. Similar view was adopted in a few other decisions,30.
However subsequently in the advance ruling of Fidelity North Star Fund31, it has been held that the income on sale of securities will be considered as Capital Gain. The reason was that the under SEBI32 Regulations, an FII can only 'invest' and not do 'business'. Hence, FIIs can only earn dividend and capital gain. One cannot presume that FIIs took approvals with an intention to violate the laws by trading in securities.
In L.G. Asian Plus Ltd. vs. ACIT33, the Mumbai ITAT has provided the same reasoning as in Fidelity North Star Fund to hold that income earned by FIIs on transfer of securities would be taxable as capital gains under Section 115AD. However, it has proceeded further to state that in a hypothetical case where an FII does earn 'business income' it would be taxable under the general provisions only if such income was earned on transfer of assets other than 'securities'. Therefore, as per the ITAT, in case of transfer of securities held as stock-in-trade or investments, income would be taxable as capital gains under provisions of Section 115AD.
In my humble view, with respect, tax laws and regulatory laws have different objectives. Approval obtained under regulatory laws does not impact taxation of income. One has to ultimately look at the facts. If the transactions are conducted in a manner which amounts to trading, it is immaterial as to what kind of approval was obtained. The income should be considered as business income.
However in case of Fidelity North Star Fund, it was the department's stand that the income of the FIIs is Capital Gain in nature. Even in the proposed Direct Tax Code, it has been provided that the sale of shares by FIIs will amount to Capital Gain. Thus it appears that the revenue department wants to consider the income of FIIs as Capital Gain.
While the above paragraph dealt with income earned on sale of capital assets like shares and units; taxation of income on transfer of derivatives has brought out a slightly different issue. Trading in derivatives was covered under 'speculative transaction' as per Section 43(5) of the Act. An amendment was brought in from 1st April, 2006 excluding transactions in respect of trading in derivatives from 'speculative transactions'. This resulted in income earned on trading in derivatives to form part of 'business income'.
In quite a few cases, FIIs had submitted income on trading in derivatives under the head 'Capital Gains' instead of 'Business Income'. The tax department had contested these claims.
In the recent decision of Platinum Asset Management Ltd.34, the ITAT held that as derivatives are covered within the definition of 'securities' mentioned in Section 115AD, the income would be determined as per Section 115AD, and not as per the general provisions. As Section 43 defines terms used under the head 'Incomes from Business or Profession', the definition of 'speculative transaction' therein would not be applicable for transactions of derivatives covered under Section 115AD. The ITAT took support of its earlier decision in L.G. Asian Plus Ltd. v. ACIT35 mentioned above. A similar decision was provided for the same assessee for a different assessment year36. Further, the judgement of the Bombay High Court37 on derivatives being taxed as "business income" was not relied upon by the ITAT as its ratio could not be applied in case of an FII.
Therefore, the legal position presently is that income on transfer of derivatives would be brought to tax under Section 115AD as capital gains and not as business income under Section 28.
To enable foreigners to invest in Indian companies without having to be involved with the Indian capital market, the Government has come out with a scheme38 under which the Indian company issues shares or convertible debentures / bonds in foreign currency. The shares / bonds are issued in the official name of an Indian depository / custodian. Under a back- to-back arrangement, an overseas depository issues Global Depository Receipts (GDRs) to the non-resident investors. GDRs include American Depository Receipts (ADRs). These receipts are tradable on an overseas exchange.
In essence the investment is in shares or bonds of an Indian company, but through GDR mechanism. However as they are independently tradable, they are like simple derivative instruments.
In 2008, the Government came out with "Foreign Currency Exchangeable Bonds Scheme 2008" (FCEB). Under this scheme, the FCEBs are issued by the Indian company to non-residents under the GDR mechanism. The non-resident can exchange the bond, with the equity shares of a listed company, which is held by the FCEB issuing company (the issuing company and the listed company have to belong to the same group). Thus bonds are "exchanged" for shares. The strength of the listed company is used to raise funds by a group company.
Section 115AC deals with taxation of incomes earned on bonds of Public Sector Undertakings (PSUs), and GDRs purchased by non-residents out of foreign currency. The incomes covered are dividend (other than on which Dividend Distribution Tax (DDT) has been paid), interest and long term capital gain. Long Term Capital Gain is taxable @ 10%.
Practically there are not many issues regarding taxation of income on GDRs. The section and the scheme grant certainty. The tax regime of GDRs is running smoothly.
If the transfer happens outside India, there is no tax, provided that the transaction is between two non-residents. The scheme and Section 47(viia) clearly state this. Long-term gain & short-term gain – both are exempt from tax – on transfer of GDRs.
If the GDR is converted into shares by the investor, then it may amount to a gain on exchange. But the scheme is silent. It in fact proceeds on the assumption that only when the converted shares are sold, there is a tax. The appreciation or depreciation before conversion is ignored. Please refer para 7.5 below.
General provisions of the Act would apply in this case.
What happens if GDRs are transferred to Indian residents?
Earlier GDRs could not be sold to residents due to regulatory issues. However, under the Liberalised Remittance Scheme of FEMA39, an Indian resident can now buy foreign securities up to the prescribed limit. Even Indian mutual funds have been recently permitted to buy the GDRs.
The scheme and section 47(viia) of the Act exempt gains on transfer of GDR from one non- resident to another non-resident. Does it mean that a transfer to a resident is taxable?
If the non-resident sells the shares to an Indian resident, there can be a tax issue if we consider the GDR to represent Indian securities. As STT would not have been paid, there can be a tax on it.
If GDR is considered to be an independent security, there should be no tax, as the transaction takes place outside India.
The problem is if the GDR was sold on the overseas stock market, how will the non-resident investor know who is the buyer! From the buyer's angle, how will he know who is the seller! Can the Indian department state that the Indian buyer is the agent of the non-resident u/s. 163? The answer is yes. It has also been confirmed in the Advance Ruling of Trinity Corporation40.
If yes, how would he know who is the seller? Which DTAA is to be considered? Is it long- term gain or short-term gain? What is the cost, etc.?
In my view, the entire scheme is such that GDRs are considered as independent of the underlying securities. They are foreign securities, traded outside India. Hence there should be no tax payable by a non-resident on sale to an Indian resident.
However, due to the recent amendment in Section 9, shares traded outside India, which derive their substantial value from assets located in India, would be deemed to be situated in India. This can lead to taxation of GDRs, even if they are considered to be an independent security. However, in my view, as there is a specific exemption for trading in GDRs by non- residents, there should be no tax liability due to the amended provision of Section 9 also.
GDRs can be converted in to their underlying shares. On eventual sale of such shares, there is an issue of what should be the cost and period of holding of such shares.
"(3) On redemption, the cost of acquisition of the shares underlying the Global Depository Receipts shall be reckoned as the cost on the date on which the Overseas Depository Bank a d v i ses t h e D o m esti c C usto d i a n B a nk f o r redemption. The price of the ordinary shares of the issuing company prevailing in the Bombay Stock Exchange or the National Stock Exchange on the date of the advice of redemption shall be taken as the cost of acquisition of the underlying ordinary shares.
Thus the cost has to be considered as the price on the date on which the GDRs or FCCBs are converted. If the shares are sold immediately on conversion, then there may hardly be any capital gain. In other words, the appreciation or depreciation while the security is a GDR, is ignored.
the view that cost of share should be the cost of GDR will not be possible.
The date of holding is considered to be from the date of redemption advice by the overseas depository.
On sale of bonds of PSUs, if there is a long-term gain, the tax is 10%. On short-term gains, the tax is 30% / 40%.
If the bonds are listed, then the period of holding should be more than 12 months to qualify as long-term. If the bonds are unlisted, the period is 36 months.
under SEBI and RBI41 to invest in the capital market in India. The definition of 'QFIs' under the SEBI Regulations includes all 'persons' as defined in the Income-tax Act and FEMA. Further such person needs to be a non-resident of India as per the Income-tax Act and FEMA; and a 'resident' of a country specified in these Regulations as per its domestic tax laws. It specifically excludes FIIs, their sub-accounts and FVCIs.
The Income-tax Act has not provided any relaxation or special provisions for incomes earned by QFIs. Hence, QFIs would be taxable as per the general provisions depending on the type of investor. This results in a significant difference in taxation, as FIIs are taxed at a lower rate, as also enjoy exemption from deduction of tax at source. QFIs do not have any such relief.
The CBDT has released FAQs on various aspects related to QFIs. It provides the procedure by which taxes are required to be deducted at source on incomes earned by QFIs. QFIs are to operate in India through their Qualified Depository Participants (QDPs) – a financial intermediary registered with the SEBI. The QDPs have been assigned the responsibilities regarding deduction of tax at source from amounts remitted to the QFIs. QDPs will be treated as a representative assessee / agent of the QFI. The QDP must ensure that the broker deducts appropriate tax, failing which the QDP must deduct the taxes.
The FAQs provide the manner in which incomes are to be computed at the time of deduction of taxes at source. The QFIs will be required to file a tax return to claim the benefits as per the Act.
Foreign Venture Capital Investors (FVCIs) are registered under the SEBI Regulations for investment in securities of Indian companies. FVCIs enjoy relaxed pricing norms and lock-in period as compared to other investors.
Like QFIs, FVCIs also do not enjoy any special taxation policies or rates. Incomes earned by them are subject to tax rates as per the type of income and the nature of entity through which they are investing in India.
However, for investments made by them in Domestic Venture Capital Companies (DVCCs) or Domestic Venture Capital Funds (DVCFs), FVCIs can earn incomes without taxation at two levels. This is because DVCCs and DVCFs are treated as pass-through entities for incomes earned by them from investment in a Venture Capital Undertaking (VCU) as per Section 10(23FB) of the Act. Therefore, capital gains earned by DVCCs and DVCFs on sale of shares in VCUs would directly be taxable in the hands of FVCIs.
This also entails on them a responsibility to pay appropriate taxes on such gains in India. Further, as per Section 10(23FB), FVCIs need to pay tax on income earned by the DVCF or DVCC on an accrual basis, irrespective of when the income is received by the FVCI.
FVCIs which invest through tax efficient jurisdictions, avail of the benefits of tax treaties signed by India with such countries.
Income of Offshore Fund is entitled for special tax treatment on Mutual Fund Dividend & long-term Gain on units of mutual funds as per Section 115AB.
An Offshore Funds is an "overseas financial organisation" - a fund, institution, association or body, whether incorporated or not, established under the laws of a country outside India. It should have entered into an arrangement for investment in India with any public sector bank or public financial institution or a mutual fund specified under section 10(23D). The arrangement should be approved by the SEBI.
Long-term gains are exempt from tax under section 10(38), if the units are of "equity oriented mutual fund" and STT is paid. Therefore the relief granted by this section is redundant in case of such gain.
However, long-term capital gain on units of "non-equity oriented mutual fund", are taxable under this section @ 10%.
Other incomes like short-term capital gains are taxed as per normal provisions.
No deduction of expenses and no deduction under Chapter VI-A is allowed.
Long term capital gain on listed units of "non- equity oriented mutual fund" are taxable under this section @ 10%. The second proviso to section 48 is not applicable, i.e., inflation adjustment provisions do not apply42.
inflation adjustment, can the offshore fund pay lower of the two?
In my view, the answer is no. This is a specific section and overrides the general section. The principle laid down in Advance Ruling (that specific sections override general provisions) referred to in para 6.1 can equally apply here.
Therefore, in conclusion, there do not seem to be any benefits to offshore funds which are covered under Section 115AB. However, as there is no provision for these funds to opt out of this Section, taxability of gains earned by such funds will be determined as per Section 115AB.
'Indirect transfers' are used to describe transactions where overseas assets are transferred leading to a transfer in value of the underlying Indian capital assets. While in form there is no transfer in India, in substance there is a transfer. These transfers can lead to taxation in India as per recent amendments.
The reason for such amendments was the Supreme Court's decision in favour of Vodafone International Holdings B.V.43. In this decision the Supreme Court held that Hutchison's sale of one share of a Caymans Island company outside India, which led to transfer of its entire Indian telecom business to Vodafone B.V., will not be liable to tax in India. The Supreme Court's decision was based on the reasoning that in a transfer of an overseas asset outside India, one cannot adopt a 'look through' approach to tax the underlying assets in India. Based on several factors, it also upheld the transfer as genuine and not as a colourable device used to avoid tax.
The Government came out with a slew of amendments to counter this decision. As the Supreme Court held that such income was not within the scope of taxable income under the Act, the Government amended the scope itself.
Section 9(1)(i) lays down that income arising or accruing, directly or indirectly, through the transfer of a capital asset situated in India would be deemed to accrue or arise in India.
Any share or interest in a foreign company was deemed to be situated in India if the share or interest derives, directly or indirectly, its value substantially from assets located in India.
Further, amendments in the expression "through" used above; in the definition of 'capital asset' under Section 2(14); and in the definition of 'transfer' under Section 2(47); were also made to enable the above deeming provision; and to counter some other rulings laid down by the Supreme Court.
All the above amendments were brought in with retrospective effect from 1st April, 1962 and as 'clarifications' to existing law.
The important distinction to be noted in this amendment is that instead of deeming the capital gains that would be earned on such 'indirect transfers' to be within the scope of the Act, the overseas assets which would get transferred are itself deemed to be situated in India. This leads to a change in the fact pattern itself, though of course only for tax purposes. This can lead to a number of issues, some of them probably unintended.
If tax is payable in the foreign country on such transfer, there can be double taxation. Tax credit may not be available for such double taxation as both countries would claim a right to tax such income.
Further, while the provisions are aimed at taxation of capital gains, any other incomes earned on such assets may also be taxable within India. For example, dividends declared on such foreign shares can be taxable in India, as the shares will be deemed to situated within India.
What does one mean by 'substantial' value. Is it more than 50% or is it something close to the entire value?
In case tax is levied on such overseas transfers, what would be the taxation when the underlying Indian capital assets are sold? Whether credit would be available for taxes already paid?
There are ambiguities on how computation would be done for such gains in India, especially where the assets sold overseas represent both Indian and foreign assets, and value is not ascribed separately.
This provision is aimed at restructuring exercise or outright sale. However, technically this provision applies to even one share sold by a retail investor outside India which has it values based on Indian capital assets. How can a person operationally comply with such a provision?
Group reorganisations can also lead to taxation under Section 9 even though Indian capital assets are transferred as part of overseas assets.
A threshold of 50% should be applied for the word 'substantially'.
The phrase 'directly or indirectly' should be applied as a 'look through' approach, whereby all intermediaries should be ignored.
Investments made by non-residents through FIIs should be exempted from such a tax.
Transfer of shares on approved stock exchanges where such shares are frequently traded should also be exempted from these provisions.
the retrospective amendments under Section 9 cannot override provisions of the DTAA.
Therefore, the impact of these amendments to Section 9(1)(i) will be limited wherever a beneficial DTAA is available.
Unlike certain other provisions44, the amendments made in Section 9 are not 'non-obtstante' provisions. In other words, they do not override the DTAA. Therefore, wherever the DTAA provides a benefit, as per Section 90(2) the taxpayer can still opt for taxation under the DTAA. As seen in Para 4 above, transfer of shares (not otherwise covered) are taxable only in the COR. In certain DTAAs this results in double non-taxation. This benefit can be availed by non-residents taxed on their indirect transfers too.
In Sanofi Pasteur Holding SA45, two French companies (MA & GIMD) had sold the shares of another French company (ShanH) to a third French company (Sanofi Pasteur Hoding). ShanH in turn held shares of the Indian company Shantha Biotechnics Ltd.
As per Article 14(5) of the DTAA, capital gains on such transfers outside India were not liable to tax in India. Upholding the principle in Section 90(2), the Andhra Pradesh High Court has held that in absence of a non-obstante clause, the retrospective amendments under Section 9 cannot override provisions of the DTAA.
Deduction of tax on capital gain or gross consideration?
There is a concern whether tax is required to be deducted under Section 195 only on the capital gain, or on the whole amount of consideration paid to a non-resident. This issue has come up time and again before judicial authorities. The Karnataka High Court in Samsung Electronics Co. Ltd.46 held that deduction of tax at source was required on each remittance on the gross sum payable. It incorrectly applied the Supreme Court ruling in Transmission Corpn. of AP Ltd.47 that at the time of deduction of tax at source, the taxpayer needs to obtain an order under Section 195(2) to determine the amount of taxable income forming part of a composite payment.
However, there are a couple of recent decisions of the Bengaluru Tribunal which have not applied the above Supreme Court ruling. In Syed Aslam Hashmi49, the ITAT taking support of the Karnataka High Court decision in Samsung Electronics, has held that tax needs to be deducted at source on the whole of the consideration.
In R. Prakash50 the ITAT has upheld the computation of interest under Section 201(1A) on tax payable on the whole amount of consideration instead of on the amount of gain.
In my humble view and with respect, both the above decisions of the Bengaluru Tribunal are not correct in law as they have not considered the decision of the Supreme Court in GE Technology Cen. P. Ltd., which has clearly stated that deduction of tax at source is required only on the portion of income embedded in the payment.
Can the payer himself determine the amount of tax to be deducted at source?
The payer needs to determine the amount of capital gains earned by the payee and deduct appropriate tax at source. Determination can be difficult in certain cases, especially where capital gains are earned. However, the payer can, if proper details are available, compute the gain and deduct the taxes on his own. Approaching the tax officer for an order u/s. 195(2) is not required in every case.
This seems to be the department's stand too, which has in the FAQs prepared for QFIs mentioned at number 22 that the payer need not approach the tax department in every case of deduction of tax under Section 195.
There are concerns whether a Chartered Accountant (CA) can issue certificate in cases of capital gains, especially where sale of properties are concerned. As an extension of the above principle, a CA can also issue a certificate in Form 15CB determining the amount of tax deducted at source. There is no bar on issuance of such certificates by CAs. However, as a practice, and to avoid unnecessary risk of incorrect computation of tax payable, deductors tend to approach the income-tax department for a certificate in such cases.
It should be noted that, with effect from 1st April 2013, as per Sections 90(4) & 90(5), in case a tax payer wants to take benefit of a DTAA, it must obtain a Tax Residency Certificate (TRC) of the country of which it is resident for tax purposes. The TRC is required to be obtained at the time of availing the benefit of the DTAA. Further, it needs to contain the prescribed particulars, failing which the details need to be submitted under a self-declaration in Form 10F. In case no benefit of the DTAA is adopted, a TRC is not required.
Section 206AA provides for deduction of tax at source at higher rates in case Permanent Account Number (PAN) is not available. In case a non-resident earning income from India does not provide a valid PAN, the tax rate applicable would the rates as per the Act, the DTAA or 20%, whichever is higher.
This provision is a non-obstante provision, superseding all other provisions under the Act. Therefore, even if tax is required to be deducted at a lower rate under any of the beneficial provisions of a DTAA, it may be deducted at a rate of 20% in case he does not obtain a PAN. However, it should be noted that a non-resident whose income is not taxable in India would not be covered by these provisions.
In conclusion, taxation of capital gains for non- residents can raise tricky issues. However, the lower rates of tax now applicable (especially for long-term capital gains) has resulted in many special provisions to be largely ineffective in providing any further tax benefit.
Indirect transfer provisions recently introduced can lead to unintended taxation. However, clarity may come only after the provisions are suitably explained or amended. Existence of a DTAA can help mitigate the double taxation.
With GAAR coming into effect from 1st April, 2015, investment through offshore centres may not give any tax benefit.
Kanga & Palkhivala's The Law and Practice of Income-tax, Seventh Edition, Page 205.
Circular No. 554 dated 13th February 1990 183 ITR St 138.
As per first proviso to Section 48.
As per second proviso to Section 48.
Timken France, In re  164 Taxman 354 (AAR); McLeod Russel India Ltd., In re  168 Taxman 175 (AAR); Compagnie Financiere Hamon, In re  177 Taxman 511 (AAR); Alcan Inc. v. DDIT (16 SOT 8).
There are however a few old DTAAs where the right to tax Capital gain is only with the Country of Source, e.g., Bangladesh, Greece and Egypt.
Article 1 of the Protocol signed between India and Singapore on 29th June, 2005 with effect from 1st August 2005.
Article 3 of the Protocol signed between India and Singapore on 29th June, 2005.
V. Ravi Narayanan, In re  168 Taxman 65 (AAR).
Sarder Indra Singh & sons Ltd. v. CIT (1953) (24 ITR 415); G.Venkata Swami Naidu &Co. vs. CIT (1959) (35 ITR 594);Karam Chand Thapar and Brothers (P) Ltd vs. CIT (1971) (83 ITR 899); Commissioner of Income Tax vs. Associated Industrial Development Company (P) Ltd (82 ITR 586); Commissioner of Income Tax, Bombay vs. H. Holck Larsen (160 ITR 67).
ITA No.3598/Mum/2010dated 5th December 2012.
AAR No. 740 of 2006.
to units in any case.
Like Section 206AA of the Act with regard to holding of PAN.


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Shawn Colvin: Steady On 30th Anniversary Tour (Acoustic)
Kitchen 6:00pm
The Kessler (map)
1230 W. Davis St.
Three-time GRAMMY winner Shawn Colvin's debut album, Steady On, was released in October 1989, a stunning introduction to an artist who quickly established herself as a mainstay in the singer-songwriter genre. The album was lauded for its confessional songwriting and well-crafted melodies, and for Colvin's tender and provocative vocals. Colvin received the ultimate acknowledgement for Steady On when she was awarded the GRAMMY award for Best Contemporary Folk Album. She swiftly amassed a dedicated and passionate fanbase.
To commemorate the 30th anniversary of this landmark album, Colvin has released a newly-recorded solo-acoustic version. Colvin brings a 30-year lens to her treasured songs, casting new light on the stories she first told as a young artist. Colvin has long been hailed as an exemplary solo acoustic performer and these new recordings are a brilliant showcase for her enduring artistry.
"I was 32 years old, and the dream of my life had been fulfilled," Colvin says, "not only because I made an album but mostly because I had written or co-written every song, an accomplishment that was hard won. I was so proud. My feeling was then—and still is—that if I never made another album, Steady On would have been enough."
Steady On Acoustic strips each song to the core, placing Colvin's songwriting masterclass on full display. "I've played these songs countless times, primarily as a solo acoustic artist," she says. "All in all, this is the incarnation that feels most genuine. And so, to commemorate this milestone I decided to celebrate Steady On by recording it again, this time using only my voice and my guitar. This represents who I am as an artist and all I ever wanted to be, and I believe it does its predecessor proud."
Over the course of three decades, Colvin has established herself as a legacy artist by creating a remarkable canon of work, touring relentlessly both nationally and internationally, and having her songs featured in television and film. She is a revered storyteller deserving of the special recognition of both her peers and those who have been inspired by her songs. The reworking of her iconic debut feels not only timely but essential, further underscoring that Colvin remains a vital voice for women in music and reaffirming her status as an Americana gamechanger.
Shawn Colvin will perform Steady On Acoustic in its entirety in what promises to be a very special evening for her longtime fans.
Meet & Greet packages available.
The Kessler
The Kessler © 2021 Terms | Refunds Ticketing by

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Video released of gender reveal that started massive Arizona wildfire
Wildfire cause over $8 million in damages
Shannon Barbour
Gender reveals sometimes don't go according to plan. From alligator reveals to the ones that leave baby girls screaming when they find out they're getting a baby brother, there's no shortage of failures on the internet. But all those pale in comparison to the unwise reveal party that sparked the massive Sawmill Fire in Arizona, which resulted in $8 million worth of damage. The reveal made headlines in April 2017 when an off-duty Border Patrol agent named Dennis Dickey set up a reveal for his wife using tannerite, a legal explosive. Things didn't go as planned when Dickey shot at his target full of tannerite and a blue powder to show that his wife was having a baby boy. As soon as he fired the shot, the target went up into flames and Dickey called the police to admit what he had done. There wasn't a video of how the fire started (which, by the way, ended up burning through 47,000 acres of land) until now — the U.S. Forest Service just released footage because MVP NBC News affiliate KVOA filed a Freedom of Information Act request. The video is quite alarming and terrifying because you can see the dry field catch fire and spread almost immediately. You can also hear someone shout, "Start packing up!" During a September 2018 court appearance, Dickey said, "It was a complete accident. I feel absolutely horrible about it. It was probably one of the worst days of my life."After pleading guilty to starting the fire, Dickey was sentenced to five years probation and agreed to pay more than $8.1 million, which he already started to do in installments.
Gender reveals sometimes don't go according to plan. From alligator reveals to the ones that leave baby girls screaming when they find out they're getting a baby brother, there's no shortage of failures on the internet. But all those pale in comparison to the unwise reveal party that sparked the massive Sawmill Fire in Arizona, which resulted in $8 million worth of damage.
The reveal made headlines in April 2017 when an off-duty Border Patrol agent named Dennis Dickey set up a reveal for his wife using tannerite, a legal explosive. Things didn't go as planned when Dickey shot at his target full of tannerite and a blue powder to show that his wife was having a baby boy. As soon as he fired the shot, the target went up into flames and Dickey called the police to admit what he had done.
California's deadliest, most destructive wildfire fully contained
Gender reveal party ends in fight outside Applebee's, police say
Gender reveal party results in massive wildfire, $220K fine
Alligator helps family with gender reveal party, video goes viral
There wasn't a video of how the fire started (which, by the way, ended up burning through 47,000 acres of land) until now — the U.S. Forest Service just released footage because MVP NBC News affiliate KVOA filed a Freedom of Information Act request.
The video is quite alarming and terrifying because you can see the dry field catch fire and spread almost immediately. You can also hear someone shout, "Start packing up!"
During a September 2018 court appearance, Dickey said, "It was a complete accident. I feel absolutely horrible about it. It was probably one of the worst days of my life."
After pleading guilty to starting the fire, Dickey was sentenced to five years probation and agreed to pay more than $8.1 million, which he already started to do in installments.


Health insurance has a lot of different aspects to it, which makes it very difficult to navigate. It is common to be overwhelmed by everything you need to know in order to select the right coverage. Due to the importance of choosing the right insurance policy, you need to make sure you know what you are doing. These health insurance tips may help you begin.
If you've recently finished college and are looking for health insurance, you should consider a few things before purchasing any policy. If you are employed, you can use the employee insurance provided by your job. If you are 26 or under in age, your parents can keep you on their policy, and you may also search for your own insurance as well.
Figure out what your needs are before open enrollment is offered. You may want to make changes to your current policy if something isn't working, or maybe your health needs have changed or your family has grown. You can also make changes to vision, dental and other insurance options.
An individual buying a health policy typically costs much more than going with a group policy; keep that in mind and plan accordingly. This means that you could possibly have to get and settle for a higher deductible, less coverage or both. You can get the best rates and coverage by shopping around.
Pay attention to which prescriptions are covered under your policy. Insurance companies will revise their rules regarding prescriptions on a yearly basis, so take the time to read the new rules before you re-enroll. If your medication isn't covered anymore, you may want to look for another insurance company.
One way you can monetarily save on health insurance premiums is to choose catastrophic coverage instead of comprehensive. You will be covered for emergency care, but not for simple visits to your doctor.
Look over your health insurance policy in order to have knowledge about which prescriptions will be covered through it. This list changes from year to year so check the list when you re-enroll, to make sure that you are not going to be surprised when you go to refill your prescription.
If you are considering having a baby, try to find an insurance plan for healthcare that will provide you with the money you need throughout your pregnancy. This is vital to know since many insurance plans don't cover certain things for pregnancy and labor.
HSAs (savings accounts designed specifically to cover your health needs) are a consideration when you only occasionally visit the doctor. Just think, the money you are not paying in higher insurance costs can be set aside for any future medical expenses.
As indicated by this article, there is a wealth of information available to help you readily understand the intricacies and complexities of health insurance. All you need to do is a little bit of research. The hints and tips that were given to you in this article can help you make decisions about your health insurance that are more prudent, more informed, and more financially sound.
This entry was posted in Health and tagged health insurance, health needs, insurance policy by Tree Of Knowledge. Bookmark the permalink.


Browse: Home » Green vs Brown – Which would you choose?
So yesterday as I was handed a pint of Kingfisher beer, I chose to share with a friend the fact that green bottles have been proved to be worse for storing beer than brown. He laughed at what to him was pointlessness information, but is a much debated topic in beer circles. So I'm sharing it with you, in case you haven't heard it already, and hoping for a better response!
The owners of BrewDog have gone to the extent of saying, "Any beer in a clear or green bottle is made by brewers who don't give a damn about their beer or the people who drink it. Feel free to take organised vigilante action against anyone who drinks beer from a clear or green bottle." Well, vigilante or not, I do think this whole green vs brown thing is pretty interesting.
Scientifically, it has been found that the wavelengths of light which penetrate clear and green glass affect the hops in a beer and cause it to become old and skunky. Some people claim that it is like the beer equivalent of leaving milk in the sun. Apparently Chemists at the University of North Carolina and Ghent University in Belgium have found that 'sunlight breaks down alpha acids in hops that react with sulphur to make a chemical that is nearly identical to the smelly chemical that skunks spray'. Brown glass on the other hand is resistant to these types of light, which allows the beer to stay fresh and un-smelly.
So why do beer companies still use green bottles? One reason is probably that green bottles are more eye catching than staid brown ones. Other than that, I'm not sure.
With big brands like Corona, Peroni, Tuborg, Carlsberg opting for green/clear bottles, it makes you wonder how much truth there is to this whole theory. This is all I know about it. It won't stop me from drinking KF pints. Atleast not yet. If you have more information on this please do share.


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Neolitsea sericea är en lagerväxtart som först beskrevs av Carl Ludwig von Blume, och fick sitt nu gällande namn av Gen-Iti Koidzumi. Neolitsea sericea ingår i släktet Neolitsea och familjen lagerväxter. Inga underarter finns listade i Catalogue of Life.

Källor

Externa länkar

Lagerväxter
sericea

redpajama_set_name: RedPajamaWikipedia


So comfortable, you'll want to wrap both arms around this hold.
Like over-stuffed pillows, this series is a little over-weight! Holds range from gentle slopers to rounded edges to comfy pinches.
Geometric feature with lots of pinching potential.
Rounded edges make for comfortable grips.


Fletching skipper Glenn Potter believes the destiny of the East Sussex League title may not be decided until the final Saturday of the season.
Britain's manufacturing industry suffered a massive setback in June after recording its biggest fall for more than 20 years.
Global banking giant HSBC reported a seven per cent fall in pre-tax profits after becoming the latest group to show a rise in bad debt charges.
A councillor is demanding a map be produced of all the masts in Brighton and Hove.
Another seafront casino opens its door to customers this week, the latest in a string of new venues marking the city's move towards becoming Las Vegas-on-sea.
Supporters are being asked to step out to show the strength of opposition to proposals to move a breast cancer unit out of Brighton.
Legal history was made when a disabled woman, who claims she was indecently assaulted by a care worker, gave evidence to a Sussex court via a live television link.
Following successful outings on the PlayStation 2 and Xbox, Electronic Arts' SSX Tricky has hit the Nintendo Gamecube with its mix of high-octane thrills and snowboarding spills.
Some games scream "buy me". Others don't. Sid Meier's Sim Golf just does not provide £30-worth of gaming.
Sussex Sharks faced just ten balls in their National League match against Gloucestershire Gladiators last night before the match was abandoned due to heavy rain.
Sussex skipper Chris Adams is poised to give his side a boost by declaring himself fit for back-to-back games against Surrey this week.
Albion are giving a trial to former Wimbledon and Crystal Palace utility player Andy Roberts.
The biggest picnic in the world could be happening at the South of England Showground in Ardingly.
Defective genes may be to blame for the rare condition that caused Brighton model Jordan's two-month-old son Harvey to be born blind, say researchers.
A teenage girl was punched to the ground and kicked in an unprovoked attack.
Teacher numbers in Sussex have increased despite fears that spiralling property prices could lead to a recruitment crisis.
Residents fear a harbour will be turned into a concrete jungle if plans to introduce more than 70 flats and houses are approved.
Brighton is the third coolest place in Britain behind London and Manchester, according to a poll of 18 to 30-year-olds.
When Wally the cat went missing, Robert and Michaela Sturman thought they had lost their beloved family pet for ever.
Desktop design packages are thick on the ground but this one stands out from the rest.
A Disabled man bombarded a couple with scores of threatening and sexually-explicit letters, a court heard.
Writer Julie Burchill will not face prosecution over an article she wrote which critics claimed whipped up racial hatred against the Irish.
An investigation has been launched after a hospital operated on four patients using equipment which had not been properly sterilised.
Council workers have called off a one day strike scheduled for Wednesday August 14 following an improved pay deal from employers.
Sussex could provide a model for other regions looking to promote links between education and business.
A man who died in a speedboat crash off Brighton beach has been named as 45-year-old Ian Langan.
Sarah Payne's family are shedding no tears for their daughter's killer after he was slashed with a knife.
A marketing company is using the internet to boost interest in digital design.
Police searched a man twice in the space of five weeks and both times found he was in possession of hard drugs, a court heard.
A woman has been banned from keeping animals for life after admitting mistreating four dogs, a rabbit and a rat.
The next stage of a long-awaited project to build a replacement children's hospital for Brighton is under way.
Motocross fans will enjoy EA Sports' Freekstyle for the PlayStation 2.
Trading standards are investigating tactics used by a power company's sales reps.
A beauty spot on the Downs which was littered with rubbish has been restored to its former glory.
Epic is designing a web site to help Channel 4 nurture creative talent.
Too many lorries are exceeding weight restrictions on West Sussex roads.
The Manchester Commonwealth Games resulted in a bumper medal haul for English athletes.
Britain could hold its first electronic general election by the end of the decade, according to the Electoral Commission.
It was once the centrepiece of entertainment for princes and prime ministers.
A pub is helping with a girl who suffers from an ageing disease.
Grandad wears girls' shoes and Daddy wears a burgle," said two year old, conspiratorially to Sara but within earshot of Tony.
One of Sussex's most famous gardens could struggle to survive if ramblers are given free access, its owner has warned.
Homes could be built on the site of a derelict petrol station in Eastbourne.
We are facing a rat plague. Instead of waiting for it, we should be doing something about it right now.
I have just had a brilliant idea. That is: Re-surface a road and then paint the lines. Perhaps Brighton and Hove City Council might like to use this idea?
Sixties sensation Petula Clark and eighties icon Limahl will top the bill at the UK's most popular free gay festival.
Well done to Brighton and Hove Bus and Coach Company for the new Ditchling Beacon bus at weekends.
An aircraft simulator company which began life in a garage has received its fourth Queen's Award.
Summer has brought a bundle of exam successes to the Brighton office of accountancy firm Mazars Neville Russell.
Specialist recruitment agency Hays Montrose has opened an office in West Street, Brighton, to meet growing demand for construction and property sector jobs.
Businesses in Brighton and Hove have signed up to a programme giving them a voice in the city's future.
A search is under way to find businesses in Brighton and Hove that will lead the city to a prosperous future.
We came over from Hastings to perform at the Lammas Fair and had a great day.
Magistrates in a town have issued their first anti-social behaviour order.
Police are concerned for the safety of a woman who has been missing for almost two weeks.
A van driver was punched in the arm as she stopped at a junction.
I gather we have a "communications officer" in Brighton and Hove, though I have never fathomed what he or she actually does.
Three Albion fans set up a fantasy football web site after failing to win anything in contests run by national newspapers.
I write to complain about the volume of debris that is now being left within the city centre of Brighton and Hove.
Brighton has sometimes been compared to San Francisco but gamblers are hoping the comparison will soon be with Las Vegas.
With the changes coming into force last week, there were bound to be teething troubles with the refuse collection (The Argus, August 3).
Few tears will be shed in Sussex for Roy Whiting, the child killer whose face was slashed with a knife while he was in Wakefield Prison.
As someone who is Jewish and a student of Zionist history, I am surprised a "Palestinian" would make the claims M Jawed does (Letters, August 1).
Chris Summers hit the first century in division one this season, but it may not be enough to save Southwick from the drop.
In response to Denis Goatcher's letter Mechanical Waste in Stonery Road (Letters, July 31), I must defend the crew that sweeps my very busy road.
In response to your correspondent (Letters, July 30), Brighton and Hove City Council already operates a popular free doorstep recycling service serving 40 per cent of homes in the city.
More than 80 people took to the streets today to demand plans for a sewage treatment plant are ditched for good.
Heavy rain has closed an exhibition in a museum and art gallery re-opened just two months ago after a £10 million refurbishment.
Imagine organising a small game of football with your mates - then having 45,000 people join in uninvited.
So we have a rat problem because of the rubbish (The Argus, August 1). Last week, the refuse department informed this neighbourhood rubbish would be collected on Monday instead of Tuesday.
It is arguably the hottest seat in Britain - and next month the infamous Big Brother chair could be yours.
In this picture are a gaggle of Thirties and Forties supporting Hollywood actors. At the rear between Frank Sully and Dorris Bowdon is trilby-hatted Eddie Quillan.
As I prepare to swap my desk at Worthing Theatres for a new desk at Eastbourne Theatres, I would like to wholeheartedly thank all The Argus readers who have attended our shows and events at Worthing Theatres over the past two years.
"Wilkommen, bienvenue, welcome . . ." Yes, Cabaret is back and looks set to be the hit of the summer at Chichester.
BT has announced a huge increase in the number of internet phone boxes, from 500 now to 28,000 within five years.
An art gallery has launch-ed an online resource for visually-impaired people.
The British Red Cross has launched software aimed at promoting first aid confidence.
Hove-based games specialist Babel has produced a TV commercial for chart-topping video game Neverwinter Nights.
There is more to unicycling than circus tricks, according to the unicycling.com web site.


text:
FBI director: Cellphone encryption has "very serious consequences"
Eric Tucker And Jack Gillum, The Associated Press October 16, 2014
WASHINGTON – FBI Director James Comey warned in stark terms Thursday against the push by technology companies to encrypt smartphone data and operating systems, arguing that murder cases could be stalled, suspects could walk free and justice could be thwarted by a locked phone or an encrypted hard drive.
Privacy advocates and technology experts called the concerns exaggerated and little more than recycled arguments the government has raised against encryption since the early 1990s.
Likening encrypted data to a safe that cannot be cracked or a closet door that won't open, Comey said the move by tech companies to protect user communications in the name of privacy is certain to impede a wide range of criminal investigations. New legislation to allow law enforcement to intercept communications is needed at a time of advancing technology and new forms of communication, he said.
"We have the legal authority to intercept and access communications from information pursuant to court order, but we often lack the technical ability to do so," Comey said in a Brookings Institution speech.
Comey cited particular cases in which he said access to cellphone data aided in a criminal investigation. But in a question-and-answer session after the speech, he said he could not cite particular instances in which someone was rescued from danger who wouldn't have been had law enforcement been blocked from that information.
"Rescuing someone before they're harmed? Someone in the trunk of a car or something?" Comey asked. "I don't think I know yet."
But, he added, "Logic tells me there are going to be cases just like that."
The speech, which echoes concerns he and others in law enforcement have previously made, comes soon after announcements by Apple and Google that their new operating systems will be encrypted, or protected with coding by default. Law enforcement officials could still intercept conversations but might not be able to access call data, contacts, photos and email stored on the phone.
While the companies' actions are understandable, Comey said, "the place they are leading us is one we shouldn't go to without careful thought and debate."
"Encryption isn't just a technical feature. It's a marketing pitch. But it will have very serious consequences for law enforcement and national security agencies at every level," Comey said.
The government's concerns may also centre in part on the use of Apple's iMessage platform, which offers end-to-end encrypted text messages that supersede traditional SMS messages. That kind of encryption likely provides access to those messages on users' iPhones, of which Apple has sold more than 240 million since 2013.
He acknowledged a rise in public mistrust of government in the year since former National Security Agency systems analyst revealed NSA secret intelligence collection programs. But he said the public was wrong to believe that law enforcement can access any and all communications with the flip of a switch.
"It may be true in the movies or on TV. It is simply not the case in real life," he said.
Comey also said the FBI was committed to a "front-door" approach, through court orders and under strict oversight, to intercepting communications. Privacy advocates have long been concerned that that development would create an opening for hackers to exploit. The American Civil Liberties Union noted that federal law protects the right of companies to add encryption with no backdoors and said the companies should be credited for being "unwilling to weaken security for everyone."
"Whether you call it a 'front door' or a 'back door,' weakening the security of a system to enable law enforcement access also opens that door to foreign governments and criminals," said Christopher Soghoian, principal technologist with the ACLU's Speech, Privacy and Technology Project.
Matthew Green, a cryptology professor at Johns Hopkins University, said the debate over personal encryption isn't new: Back in the 1990s, when personal computers were a novelty, he said most consumers weren't even aware of encryption. When a form of email encryption called PGP was released, he said, there was a fear that criminals would use it.
"These technologies exist" for consumers to protect their privacy, he said, "and it's very hard to do anything about it."
The Center for Democracy and Technology said in a statement that law enforcement already has ways to obtain the electronic data it needs.
"Encryption of our personal devices and communications enhances the security of our most private information," the centre said in a statement.


As long as we've been in the business of window treatments, the name of Hunter Douglas has reigned supreme—and for good reason! Over the last 25 years, their line of products has given them a reputation for tasteful craftsmanship, and brilliant functionality. Being window treatment connoisseurs near Bucks County, PA, we love everything that they create. Today, we wanted to talk about their Silhouette Window Shadings and all the engineering, and options behind them.
When Hunter Douglas designs their window shadings, they intend to completely transform and enhance an interior. Diffusing all the glare and harshness of sunlight into a gorgeous ambiance, a Hunter Douglas Silhouette Window Shading may, in fact, be light years ahead of anyone else.
Adjustable, S-shaped vanes gently float between two sheer fabrics, allowing natural sunlight to filter into living spaces as desired. Homeowners adjust how much privacy and lighting they want by simply tilting the vanes, be it manually or remotely. In the process, these shadings deflect all those destructive UV rays that decolorize our furniture and our flooring.
We're not talking about PowerPoint, but PowerViewfrom Hunter Douglas. Giving you complete control and scheduling via your smartphone or tablets, this latest technological advancement is perfect for homes filled with small children and family pets. Recipient of the Red Dot Design, the PowerView wireless operating system may be controlled through their intuitive Apple or Android Hunter Douglas app.
Bundled with a retractable wand, the Hunter Douglas UltraGlide allows anyone how to perform household magic tricks with their Silhouette Window Shadings (always available for browsing at our Main Line, PA location). With said wand, you can say goodbye to all of those obtrusive, and potentially hazardous cords.
All of these technologically advanced window shadings come in a range of shapes that can fit in any window and home. Hunter Douglas's Arches include stationary, half circle, eyebrow, Gothic, and perfect configurations; Patio and Sliding-Glass Doors can be fit to the largest expanses of windows, for homeowners with accessible patios. Simply elegant, Sidelights customize to entry doors, both operable and non-operable.
To learn more about the Hunter Douglas window shadings, as well as others, contact us at 610-228-0189.


text:
Unnecessary Endings
April 5, 2013 ~ drdoyleeditorial
Thanks to the magic of home video, I finally got a chance to watch Spielberg's Lincoln — which is not, despite its title and its director, a sprawling epic biopic. It's actually, for the most part, a tightly focused docudrama about the passage of the Thirteenth Amendment to the US Constitution, in which Abraham Lincoln employs every political tool in the book, up to and including bald-faced lies and outright bribes, in order to secure the crossover votes in the House of Representatives necessary to bring about the abolition of slavery. The story ends with Mr. Lincoln leaving a gathering of his political associates in order to join Mrs. Lincoln for a night out at the theater, in a lovely moody shot of the President walking down a darkened White House corridor toward the lighted doorway at the end.
Unfortunately, the movie goes on for several minutes after that.
We get the assassination — well, actually, we get an audience at a different performance in another theatre being told that the President has just been shot. (I suppose this was meant to be clever film-making, but it felt to me like a bait-and-switch. Mileage, of course, may vary.) We get Mary Todd Lincoln weeping at the deathbed. We get "Now he belongs to the ages." We get a final Inspiring Voiceover Montage. And I'm damned if I know why the movie needed any of that stuff, unless it was for the historical enlightenment of the three or four people in Outer Mongolia who don't already know that Abraham Lincoln was assassinated while watching a play at Ford's Theater.
The whole thing reminded me of another movie with an equally unnecessary ending — First Knight, the Arthurian film with Richard Gere as Lancelot and Sean Connery as King Arthur. Except for the assumption that any woman in possession of her right mind could possibly prefer Gere† to Connery, First Knight was a perfectly serviceable film adaptation of Chrétien de Troyes's The Knight of the Cart, and would have worked just fine if they'd left it at that. But the film-maker stuck a Mort D'Arthur sequence onto the end of it, presumably because nobody involved trusted the audience to remember what was going to happen a few years down the fictional road.
One of the good things about being in the business of making novels and short stories instead of films is that we can get away with putting a bit more trust in the intelligence — and the literacy — of our audience.
†Of that vintage, at least. Perversely, as Gere's gotten older he's acquired a kind of sleazy shopworn charm that is attractive in its own right. But I digress.
Posted in Film and Television filmpeevesplot
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2 thoughts on "Unnecessary Endings"
James Macdonald says:
Another film with an unnecessary ending is Nightmare on Elm Street. The film actually ends when the young lady turns her back on Freddie and walks away, causing him to vanish, his power broken.
Then, for reasons that probably have to do with studio interference, they tack on an ending with the villain returning from the dead.
See how much better the film is if you just stop the DVD at the point I indicated, without the breakfast-with-Mom-next-morning scene.
(The movie probably did need a brief coda with the young lady hugging her father the next morning with her saying something about how she won't have any trouble sleeping, but that's it.)
francisguenette says:
My husband and I were anxious to see Lincoln – thinking it would be big! Well – we made it through – once we realized it was the docum-drama you describe. Daniel Day Lewis made a great Lincoln, but I totally agree with you about the ending. It needed to end at the point you suggested. Ah well – I'm no Spielberg (though people often say my husband looks a bit like the guy) but I have my opinions.


IT goes by many names – the 'squeak', the Herald, the 'Lockerbie paper' – but next month the Annandale Herald could have another title . . . Scottish Weekly Newspaper of the Year.
For we are delighted to announce that mid Annandale's most local newspaper is one of six finalists shortlisted for the prestigious prize in the Scottish Press Awards.
And it's fingers crossed that our selection of local news, views, sport and features will be enough to sway the judges.
Editor Fiona Reid said: "We submitted three different editions of the paper from last year, including our tribute issue for the 30th anniversary of the Lockerbie Air Disaster, and we were over the moon to find out that we are finalists.
The winner will be revealed at an awards night in Glasgow on April 25.


text:
Striving for Social Justice
Until we acknowledge the inequities in our valley, we cannot indulge in an "all is well" narrative.
"Formerly known as Talahalusi (Beautiful Land), the Napa Valley is one of California's longest inhabited areas. Archaeological surveys indicate 10,000 years of uninterrupted habitation....It was a paradise - a cultivated paradise where one only had to reach out their hand to eat. A place rich in beauty, water and food."
-Suscol Intertribal Council
Napa is special to us all, but Napa also suffers from a history of violence. Only about 170 years ago, in 1851, military forces abused and marched our first people north in what was the last "bloody run." The reservations where the people were placed (and where their relatives remain, like Napa's farmworker housing of today), are not places where any of you would feel comfortable living.
But that is not all. We have a long and ugly history of police and military abuses and wealth made at the cost of other socially and economically disadvantaged populations, many from Mexico and Guatemala. Until we acknowledge the inequities in our valley, we cannot indulge in an "all is well" narrative. We cannot fast-forward healing.
We work to understand the impact of white privilege on legislation and rulings that adversely affect our residents. We watch the actions of the local Farm Bureau and vintner associations that use immigrant workers but inadequately care for them, their health and their families in our communities.
We are ready to be uncomfortable and awkward in acknowledging white fragility and privilege in our organization and in the community. We are ready to have honest conversations and advocate for the changes needed.
We envision a diverse community where we value the essential workers, not just with good intentions but with real support, such as the Governor mandate for Workers Compensation to cover ag workers who have contracted Covid-19 on the job as essential workers. We imagine a Napa County with affordable, safe housing and healthcare for those who work here.


Air conditioning is wonderful expertise that has made it doable for individuals to dwell comfortably in the southern states. Stanford University researchers collaborated with the Division of Power this 12 months to develop a new photo voltaic gadget that may purify water when exposed to sunlight The minuscule tablet (roughly half the dimensions of a postage stamp) is not the first solar machine to filter water, nevertheless it has made major strides in efficiency compared to past innovations.
I additionally own a dental consulting business, where I assist people design dental offices. The primary permits clients to refill and handle their prescriptions from their cell devices and skip the line after they attain the pharmacy counter. Your gadgets can hook up with autos by means of application interfaces and vehicle manufacturers are providing elective in-car Wi-Fi routers.
Expertise has infiltrated virtually each aspect of our lives and lodge builders want to grasp that almost any person checking in at a hotel, resort, spa or lodge, can have a smartphone in their pockets. Listening units are often known as; Bugs and Wires and is a mixture of a radio transmitter and a microphone. These representations of pain, by eliciting an intense response from their viewers, teach folks what a know-how can do. If a medium can make you cry – as VR can, famously – it really works.
Throughout the years there have been so many products that I've invested in, including an air abrasion system, rotary endo devices, a diode and erbium laser, intraoral cameras, digital x-rays, a computerized tomography machine, a CariVu caries detection device (DEXIS), a CEREC chairside milling unit (Dentsply Sirona), and our latest software for success bought a year-and-a-half in the past, the Solea 9.3 μm CO2 laser (Convergent Dental).
Tim Merel, managing director of Digi-Capital , a Menlo Park, Calif.-primarily based augmented and virtual reality adviser, predicted that by the end of 2018, there may very well be as many as 900 million smartphones and tablets able to supporting augmented reality apps created from device kits like Apple's ARKit, Google's ARCore and Facebook's Digital camera Effects And that quantity may grow to greater than three billion by 2021.


text:
Q: TSQL find records with different writing in another table I have a "MasterTable" with the following records:
MasterTable:
Col1
PX02894
PX02895
PX02896
PX02897/98

From the lookup table I want to get the Col2 links, keeping the formatting of the MasterTable, represented as the Output table below.
LookupTable:
Col1            Col2
PX02894-PX02895 Link001
PX02896         Link002
PX02897-PX02898 Link003

OutputTable:
Col1         Col2
PX02894      Link001
PX02895      Link001
PX02896      Link002
PX02897/98   Link003

As you can see the writing is different "/" and "-".
I've tried with

len(col1) > 7 THEN LEFT(col1,5) + RIGHT(col1,2)

but that's wrong. Do I need a Union first?
Here's a Fiddle
What do I need to do here? Thanks in advance.

A: select m.col1,l.col2
From MasterTable m
inner join linkTable l
On (Substring(m.col1,1,7) = SubString(l.col1,1,7)) or (Substring(m.col1,1,7) = Substring(l.col1,9,7))

should do it as long as you can trust the data formating. if not a few more checks e.g
Substring(l.col1,8,1) = '-'

A: Try this --
This works in sybase-- if you using SQL server find alternate functions
select substring(col1,1,(charindex("-",col1)-1)),
UNION
select substring(col1,(charindex("-",col1)+1),char_length(col1))
Thanks,
Gopal

redpajama_set_name: RedPajamaStackExchange


Sigve Knutson's debut body of work "Drawing Objects" has already identified him as one of the most exciting new names in contemporary design. With exhibitions, as of April 2017, in Milan, Beirut and now Oslo.
Sigve Knutsons first solo presentation in Norway is a collaboration between Galleri Format Oslo and Carwan Gallery Beirut. Showing a series of drawings and objects created using specific methods and material combinations, born out of a common intuitive and spontaneous spirit.


Our Quality & Safety information provides objective and timely information to help you gauge the performance of Norwalk Hospital in various clinical care areas. Norwalk Hospital also uses this information to identify places where we could improve the quality of our care even more.
The Centers for Medicare and Medicaid Services (CMS), a federal agency, requires all U.S. hospitals to track and report certain statistics, called performance measures. More than 100 measures are tracked, although some hospitals don't have enough patients with a certain condition to report on it, or don't perform a certain procedure.
Norwalk Hospital distributes Press Ganey satisfaction surveys to patients who use our services, and we also receive unsolicited messages from patients who write to tell us about their experiences. We are grateful to those who took the time to write and are pleased to share with you some of their recent comments.


View from the Couch: The Craft, Green Book, The Kid Brother, etc.
View from the Couch: Burning, The Favourite, Year of the Dragon, etc.
View from the Couch: The Little Mermaid, The Mole People, The Sisters Brothers, etc.