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International Tax Review at 25: What has changed in a quarter of a century
Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of those changes have been reflected in the publication over the past 25 years.
So how different is tax now? The way in which tax news and information is delivered 25 years on is different, for a start. Websites were well into the future as far as this publication was concerned in November 1989 – the world's first ever website was not launched for another two years. E-mail newsletters? No, the founders were not thinking of those either. LinkedIn? Facebook? Twitter? They were long from being invented in the US, so International Tax Review was definitely not thinking about posting, poking or tweeting.
The other ways in which tax has changed have to do with it becoming cross-border. Of course there was international trade 25 years ago and executives thought carefully about tax treatments and what benefits they could eke out from planning a transaction in a particular way. But it was nothing compared to what we have today.
When International Tax Review began in November 1989, some jurisdictions had transfer pricing rules, though most did not. Tax administrators had little to do with their counterparts in other countries; now they meet regularly to talk about issues such as simultaneous and joint audits. And tax havens, or international financial centres, operated without that much scrutiny from outsiders. Now these places have signed numerous tax information exchange agreements – which did not exist 25 years ago either – and do their utmost to convince regulators and the public that they run regimes of the highest probity.
In the past 25 years, tax has moved from the exclusivity of the business pages to the general news pages of the press and to the homepage of any self-respecting news website. It is difficult to consider any matter of public policy or impossible to undertake any corporate transaction without discussing how it will be paid for and how much will have to be paid. One of the ways of doing that is by collecting tax revenue.
Multilateral
Other ways in which tax has changed are:
the critical role multilateral bodies such as the G20, EU, OECD and the UN now play in tax policy development. Such organisations existed in 1989 and were building their influence on tax issues, but it was at nothing like the level of importance they hold now.
the pressure that non-governmental organisations (NGOs) are putting on policy makers to construct the appropriate tax policies in response to problems of our time such as climate change and development and on taxpayers to ensure they pay what is due in every jurisdiction in which they operate; and
the interest the public has taken in how tax is raised and collected. Professionals will argue that the public does not, and will never be able to, understand the complexities of cross-border tax, but the fact is the man on the street wants to know more.
All of this means that politicians and companies have to think carefully now about every tax move they make, whereas 25 years ago they could go about their business untroubled by having to answer to activists or the public on tax.
However, while these all indicate that tax has been transformed, similar issues have a habit of cropping up again and again. International Tax Review has covered them over the past 25 years and we present a selection to you here. They were chosen because of the resonance they have for topics that are still being discussed and fought over a quarter of a century later.
New regime for tax havens in the nineties
Exchange of information and banking secrecy have been hotly debated as international tax rules have been reformed in recent years and jurisdictions have gone after the undeclared assets held by their taxpayers overseas. The 2014 endorsement of the OECD's Common Reporting Standard as the instrument for the global automatic exchange of information has led many to declare that this will end the idea of banking secrecy forever.
This article argued that "properly conducted offshore commercial operations and properly constructed tax mitigation programmes do not need secrecy beyond normal banking and professional confidentiality". It went on to suggest that offshore authorities could strike a deal with other jurisdictions, that in exchange for controlling their activities, suspected tax evaders could be offered tax amnesties. We have seen that many jurisdictions have implementing voluntary disclosure programmes with reduced penalties, without going as far as introducing amnesties.
Multinational tax departments come of age
"For all acquisitions, disposals and reorganisations, management is quite conscious of the tax effects"
A survey in this issue of the magazine of group tax managers from 30 blue-chip European and North American multinationals found that senior management were attaching more and more importance to tax. Where have we heard that before and since? The survey found that 70% of respondents reported to their company's chief financial officer. However, we question the accuracy of our colleagues' numeracy skills in 1991: they described this percentage as "fully two-thirds"!
"For all acquisitions, disposals and reorganisations, management is quite conscious of the tax effects," said Vinod Shah, then the tax director of Booker, the UK wholesale food provider. That is still true now.
US 482 regulations send shockwaves around the globe
The Internal Revenue Service shocked many taxpayers with its TP revisions
Twenty three years ago transfer pricing did not occupy the same position in the thinking of tax managers as it does now. The opening up of markets has changed all that and a lot more countries have regulations on intercompany pricing in place now.
While any changes to the US transfer pricing regulations would still excite plenty of interest and comment today, the change in 1992 caused consternation because of provisions that, for example, would allow the Internal Revenue Service to consider the combined effect of all transactions between related parties; to take into account the results of prior or subsequent years in its examination of a particular year and to disregard contracts or the absence of contracts between taxpayers.
What do multinationals think of global tax issues?
"If there is one clear message to emerge from their responses, it is that the US tax system is widely seen as baffling, unworkable, unfair and getting worse"
The International Bar Association's conference in New Orleans was the hook for another survey of senior in-house tax advisers.
"If there is one clear message to emerge from their responses, it is that the US tax system is widely seen as baffling, unworkable, unfair and getting worse," the survey's author wrote. It seems like nothing has changed. You might get a similar result if you questioned tax managers today.
Water's edge remains unresolved
Supreme Court upheld California's method of unitary taxation
The question of unitary taxation, a drum that tax justice campaigners are beating hard in 2014, reached all the way to the Supreme Court in the US 20 years ago. In the combined Barclays and Colgate-Palmolive cases, the justices were asked to decide whether California's method of worldwide unitary taxation was constitutional. They decided it was, meaning California could treat the taxpayers as part of a worldwide group and tax them on their operations in California.
The arm's-length principle (ALP) versus unitary taxation remains a lively debate for some, even if that was not directly the issue at stake in these cases and despite the fact that the OECD's BEPS work does not contemplate the overturning of the ALP.
Highlights from the evolution of tax 1989 – 2014
OECD accelerates tax work; interview with Jeffrey Owens
The OECD was getting going as a force in the production of international tax guidance in 1995 and its influence has only got stronger and stronger since then. "It can play a part where issues cannot be resolved simply at EU level," said Jeffrey Owens, then the OECD's head of fiscal affairs, in the February 1995 interview. That year saw the publication of its original set of transfer pricing guidelines, perhaps the work it was most closely identified with before the G20 commissioned it to lead the BEPS project in 2012.
Jeffrey Owens: the first director of the OECD's Centre for Tax Policy and Administration
The Organisation's Centre for Tax Policy and Administration was founded in 2001, with Owens leading it as director until 2012, and the rest, as someone may have said once, is history.
Plenty of tax activists, academics and others believe the OECD should not be solely responsible for driving international tax reform because it represents the 34 biggest economies in the world. Its opponents believe a strengthened UN Tax Committee would look out for the interests of all countries rather than the biggest. The OECD argues that it has created global fora covering tax administration, VAT, transfer pricing, and tax transparency and exchange of information, which are not confined to members of the Organisation.
Choosing regional headquarters in Asia
If tax competition is a dirty expression in some parts of the world, it has been accepted as a way of life in Asia. Hong Kong, Singapore and China, for example, have long battled with each other to attract companies, particularly financial services and high-tech, to set up in their jurisdiction.
This article looked at how Hong Kong, Singapore and Japan, in particular were hoping to capitalise on the expansion of multinational companies into Asia. Back then Hong Kong had a clear lead over the other two with its corporate income tax rate. Singapore's was 27% and Japan's was 37.5%, while Hong Kong's was 16.5%. While Japan's has come down a little bit, to just under 36%, Singapore's has shown the biggest fall and is now at 17%, just behind Hong Kong's, which is still at 16.5%.
EU tax competition takes centre stage
Tax competition in the EU was as much a hot topic 17 years ago as it is now
Tax competition is a topic that continues to generate strong arguments. Ulrich Wolff, the head of the German tax administration, used an interview in International Tax Review to rail against tax-favourable incentives in the EU, such as the International Financial Services Centre in Dublin, which still exists, Belgium coordination centres, which were phased out by the end of 2010, and financing arrangements in the Netherlands. Ecofin ministers adopted the Code of Conduct on Business Taxation on December 1 1997, which committed their governments to rolling back any harmful tax competition measures and declining to introduce any in the future.
VAT: Where are you coming from?
January 1 2015 sees the introduction of new place of supply rules in the EU on VAT for electronic services, where the tax will be payable in the jurisdiction where the consumer is located, rather than where the producer is. Place of supply has always been a thorny issue. This article analysed the rules in the EU, concluding: "Some of the rules are straightforward and should be quite easy to apply. However, other rules are less clear cut."
Irish tax rate: A phantom menace?
Ireland has stuck doggedly to a low corporate tax rate of 12.5% since its introduction
The Star Wars film of the same name which came out in 1999, lent its title to this article, which tracked how Ireland's corporate income tax rate had changed. The country has been fighting against efforts to raise its 12.5% tax rate on trading income since it took effect at the beginning of 2003. It had been even lower, at 10%, though this only applied to certain industries such as manufacturing, technology and financial services. Taxpayers and advisers discussed the importance of tax in location decisions. Irish practitioners pointed out, as they do now, that Ireland is an open, transparent economy with an open, transparent tax system available to all if the conditions are met.
Irish finance ministers have stuck to the 12.5% rate ever since. Michael Noonan repeated that it was not for negotiation in his Budget 2015 announcement on October 14 this year.
Grasp the moment in China
Investors streamed into China in the early part of this century as the country started on a series of tax reforms
This might have been the unconditional advice 14 years ago as overseas multinationals poured into China, but a taxpayer may not follow the same strategy now without realising that China is developing its tax system all the time and is adopting many of the features of tax practice and administration seen in other jurisdictions, such as much-closer scrutiny of transfer pricing and a clampdown on the indirect transfer of shares of a Chinese company.
"It will be costly for foreign investors to take a wait and see attitude towards China and the WTO, or focus on the talks and formal process itself to the exclusion of other developments worthy of attention"
The advice in this article was for overseas companies to rush into China before anything changed after it joined the WTO, which it did on December 11 2001.
"It will be costly for foreign investors to take a wait and see attitude towards the WTO, or focus on the talks and formal process itself to the exclusion of other developments worthy of attention," the authors wrote.
The common consolidated corporate tax base (CCCTB), Europe's attempt to harmonise corporate tax collection, has been a long time coming and it is not here yet.
A quick glance back over some of the headlines ITR has produced on the topic since the European Commission announced its intention to introduce a CCCTB in October 2001 shows the slow progress the CCCTB has made. The long and winding road to a common tax base, ITR readers not sold on CCCTB, and Exclusive: "No incentive to opt in to CCCTB" – Vodafone, are just a few that give insight into the troubled lifespan of this tax harmonisation proposal.
The thinking behind a common tax base is that a single set of rules that companies operating in the EU could use to calculate their taxable profits would represent an easing of the compliance burden. Indeed, filing one consolidated tax return for their entire activity in the EU instead of one in each country would reduce the administrative burden, compliance costs and legal uncertainty, and make it easier, cheaper and more convenient to do business in the EU, claimed Algirdas Semeta, the outgoing EU tax commissioner.
"It's crucial to look at where the business is going – what's going to happen in the future and what are the needs of the business – then find a transfer pricing policy that fits with the business and the needs. What you can't do is use transfer pricing as a tax planning tool. It isn't one"
Member states would retain their sovereign right to set rates, but taxable profits would be divided between the constituent companies of each group by a formula based on assets, labour and sales.
More than a decade later, however, the CCCTB has been a topic of largely academic debate since a working group on it held its final meeting in 2008 and a workshop was held in 2010. Despite various steps towards harmonisation within Europe and beyond, an unwillingness to cede a certain level of national sovereignty, among other factors, means the notion is lingering in pre-enactment purgatory.
Pierre Moscovici, who succeeds Semeta as EU tax commissioner on November 1 2014, has listed it among his priorities for action. But he is not the first to do so. To date, the CCCTB has been a topic that is frequently name-checked as an issue to develop, but one which is frequently delayed, though Italy hopes it can produce a compromise proposal on the topic before its presidency of the EU ends on December 31 this year.
As Richard Murphy, the UK tax campaigner, put it in our July/August 2001 special issue covering CCCTB, "the problem is national ego".
The first Global Transfer Pricing Forum
International Tax Review launched the Global Transfer Pricing Forum in Amsterdam in 2001 and it has been held every year since in glamorous locations such as New York, Barcelona, Rome and Berlin, attracting the world's most influential policy makers, taxpayers and practitioners to discuss the most topical issues in transfer pricing.
Speakers and delegates at the first conference talked about the impact of globalisation and the increasing aggression of tax authorities on transfer pricing; intangibles; e-commerce; dispute resolution and advance pricing agreements.
In a comment that has many resonances with what has happened in transfer pricing practice in the past 13 years, a senior manager with KPMG, the first sponsors of the conference, said:
"It's crucial to look at where the business is going – what's going to happen in the future and what are the needs of the business – then find a transfer pricing policy that fits with the business and the needs. What you can't do is use transfer pricing as a tax planning tool. It isn't one."
And look what happens to speakers at the event! Andrew Hickman, also of KPMG, who spoke at the first conference is now head of transfer pricing at the OECD.
Paul Sarbanes and Michael Oxley, who sponsored the Act
The Sarbanes-Oxley Act was signed into law by US President George W Bush in reaction to accounting scandals involving companies such as Enron and WorldCom. The Act required, among other things, boardroom certification of the accuracy of corporate financial information. Congress passed the legislation in July, which also restricted firms from offering tax services to audit clients as well as mandating that a company's chief executive officer must sign the company's tax return. Sarbanes-Oxley led many companies in the US to choose different advisers for tax and audit services. Other jurisdictions have adopted measures to ensure independence between tax and audit advice and from mid-2016 EU rules will limit the tax services that can be provided to their clients by audit firms.
What the EU Savings Directive means
After years of fierce debate, 2003 saw the European Savings Directive reach a compromise on banking secrecy and withholding tax. This marked a major step in multilateral attempts to combat tax fraud and increase cooperation between European countries on tax matters.
On January 21 2003 the European Council of Economics and Finance Ministers (ECOFIN) reached agreement on the contents of the European Savings Directive (ESD) and six months later, on June 3, it was finally adopted. It was planned that, from January 1 2004 the member states of the EU had to apply a system of automatic exchange of information on interest income derived from savings by non-residents. The original version actually came into effect in July 2005.
"The agreement on the ESD and the implementation… is a big achievement and it should ensure that income from savings of EU residents does not escape taxation John Brouwer, Allen & Overy, 2003"
A compromise was reached with Austria, Belgium and Luxembourg, which were reluctant to relinquish their bank secrecy rules unless other countries, particularly third countries such as Switzerland, also adopted a similar information exchange system. Austria, Belgium and Luxembourg agreed to apply a withholding tax (WHT) on interest earned by residents of other member states, starting at a rate of 15% from January 2004, moving to 20% from 2007 and 35% from 2010 onwards, with three-quarters of the WHT to be remitted to the country of residence.
The ESD was revised in March 2014 to strengthen the rules on exchange of information on savings income by closing loopholes including through the insertion of a look-through approach to prevent the imposition of a legal person or arrangement to distort effective taxation as covered by the directive. This means payments made through intermediary structures such as trusts and foundations would be captured.
Other developments in 2014 have had an impact on the ESD's scope and relevance, too. The updated provisions for the Directive on Administrative Cooperation (DAC) implements the OECD's Common Reporting Standard (CRS), representing the legislative framework for applying the new global standard of automatic exchange of information within the EU.
September 2003 also saw the European Court of Justice rule in the Bosal case that an important statutory restriction of Dutch corporate income tax relief violated EU law. The Dutch Ministry of Finance announced it would adopt new thin capitalisation rules in response to the decision, with significant consequences for acquisition and finance structures.
Bush signs new corporate tax law
George W Bush signed the American Jobs Creation Act
In the midst of campaigning for re-election, October 2004 saw US President George Bush sign the American Jobs Creation Act to end the five-year trade row with the EU over the foreign sales corporation (FSC) and extra-territorial income exclusion (ETI) schemes.
The 650-page Act was one of the most significant corporate tax laws in nearly 20 years, providing $137 billion in tax breaks over the following 10 years across three broad areas:
Tax relief for US-based manufacturing activities ($77 billion);
Reform of the taxation of multinational businesses ($43 billion); and
A range of targeted business income tax relief ($10 billion) as well as targeted individual tax cuts and excise tax reforms ($7 billion).
The revenue-neutral Act funded these tax breaks by repealing the FSC and ETI provisions (raising $49 billion) and $88 billion in other tax increases that include:
clamping down on specific abusive transactions ($30 billion);
increasing Internal Revenue Service (IRS) and customs-user fees ($19 billion);
closing other corporate and individual loopholes ($15 billion);
shifting and increasing excise tax liability ($14 billion);
general rules assuring more transparency with respect to tax shelter activity ($3 billion); and
other administrative charges ($2 billion).
One of the biggest benefits to many businesses was the 9% deduction for qualified manufacturing income (up to 50% of an employer's wage and salary costs), phased in over five years.
Another attractive element for multinationals was the temporary 85% deduction of dividends received (maximum $500 million of eligible dividends) from controlled foreign corporations (CFCs). This gave US companies a one-year window to repatriate profits from foreign subsidiaries at a significant tax discount.
The Act also simplified the use of foreign tax credits, with two credit baskets – one for passive income and one for general income – down from nine previously.
The main upshot of the Act was that it ended EU sanctions of up to $4 billion a year imposed on the US as a result of the ETI scheme, which the WTO declared an illegal export subsidy in January 2002.
Landmark Marks & Spencer case
The M&S case transformed loss relief rules
In a landmark case before the European Court of Justice, Marks & Spencer (M&S) won a split decision in December in which the court ruled the company should be allowed to offset losses incurred by overseas subsidiaries against its UK tax bill, but only if there is no possibility of using the losses in the jurisdiction in which the subsidiary was set up. The decision transformed loss relief rules throughout Europe.
The case is still running and an ECJ Advocate General now wants to overturn the original decision, barring the company from using the losses of a subsidiary. If this reasoning is upheld it would go against a series of cases concerning outward investment and would have implications for the EU's freedom of establishment principle.
In other UK news, 2005 saw the launch of HM Revenue & Customs (HMRC), with the unification of direct and indirect tax collection and administration, aimed at improving the service to taxpayers and cutting down on tax avoidance.
GlaxoSmithKline settles with the IRS and pays out $3.1 billion
GSK paid out more than $3 billion
The $3.1 billion settlement between the US Internal Revenue Service (IRS) and GlaxoSmithKline (GSK) in October was the largest ever single payment to resolve a tax dispute in US history. The controversy stemmed from whether GSK's profits from Zantac, an ulcer drug treatment, should be attributed to the US or the UK, where GSK is headquartered. The case signalled a marked increase in transfer pricing enforcement by the IRS.
In the same month, the ECJ ruled in the Cadbury Schweppes case that the EC Treaty's freedom of establishment rules meant that the UK's controlled foreign company (CFC) rules could only apply to EU subsidiaries that are "wholly artificial" tax arrangements. The ruling forced the UK and other EU member states to look at amending their laws on CFCs.
US adoption of FIN 48 accounting standard
FIN 48 cost Lehman $178 million
FIN 48 directs US reporting companies as to how, under the US's generally accepted accounting principles (GAAP), they should represent uncertain tax positions (UTP) in their accounts. In simple terms, FIN 48 requires the disclosure of UTP under the US GAAP. The Financial Accounting Standards Board (FASB) introduced the FIN 48 rules for accounting periods commencing after December 15 2006.
The FASB released an update on May 2 2007, with clarification of the term "ultimately settled" cutting compliance time for businesses. The guidance was retroactive, applying from January 1 2007.
The FASB previously required the tax authorities to specifically refer to and clear a tax position for it to be ultimately settled.
But the Board's clarification meant that so long as the tax position was included in a completed audit and the authorities are not questioning its legality then it can be considered ultimately settled.
Companies have been required to invest heavily in extra in-house and external support to ensure compliance with FIN 48. New IT and accounting systems have been implemented at the cost of millions of dollars.
In 2008 Lehman Brothers, which collapsed in the same year, claimed the accounting standard cost the company $178 million.
"On December 1 2007, we adopted FIN 48. The aggregate impact to opening retained earnings from the adoption of this standard was a decrease of approximately $178 million," said CEO Richard Fuld.
Vodafone loses dispute at Bombay High Court
Vodafone lost a case before the Bombay High Court in December 2008, which resulted in the company being assessed a multi-billion dollar tax bill. The case concerned the amount of tax due from Vodafone's purchase of a controlling stake in an Indian phone business.
Vodafone's dispute in India has impacted foreign investment into the country
UK-headquartered Vodafone paid Hong Kong's Hutchison Telecommunications $11.2 billion in 2007 for a 67% stake in Indian cellular phone operator Hutchison Essar. The Indian authorities subsequently slapped a $2.5 billion tax bill on capital gains from the transaction, claiming the assets purchased were located in India, though the transaction took the form of the acquisition of shares in offshore companies.
Vodafone argued that the Indian tax authorities had no jurisdiction to tax the transaction as the deal took place between two foreign companies.
The case went to the Indian Supreme Court in August 2011 and despite a positive ruling for the taxpayer in January 2012, India still tried to tax the transaction and introduced a retrospective amendment to the law in Finance Bill 2012 so that offshore transactions could be brought into the Indian tax net. The retrospective amendment went back 50 years, to 1962.
When Palaniappan Chidambaram succeeded Pranab Mukherjee as finance minister in 2012, he commissioned Parthasarathi Shome to assess the appropriateness of retrospective law amendments, with Shome concluding they should only be used in exceptional or "the rarest of rare cases".
The long-running dispute has had an adverse impact on foreign direct investment into India, which is only now altering the international perception that it is an inhospitable environment in which to do business.
OECD releases new transfer pricing guidelines
The OECD released a proposed revision of several important chapters of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in October 2009.
The changes followed two discussion drafts; one issued in May 2006 looking at comparability issues; and another released in January 2008, which focused on transactional profit methods. The 2009 amendments also drew from discussions with commentators during a two-day consultation that was held in November 2008.
The new guidelines updated the existing provisions relating to comparability and profit methods, which dated back to 1995.
An important change was to the hierarchy of transfer pricing methods. The previous guidelines recognised two categories of transfer pricing methods: the traditional transaction methods (found in chapter II) and the transactional profit methods (chapter III). Transactional profit methods (the transactional net margin method and the profit split method) are considered last resort methods, to be used only in exceptional cases.
The 2009 revisions sought to remove exceptionality and replace it with a standard whereby the selected transfer pricing method should be the "most appropriate method to the circumstances of the case".
FATCA included in Hiring Incentives to Restore Employment (HIRE) Act
The Foreign Account Tax Compliance Act (FATCA) is a US initiative but one with global ramifications.
First introduced in 2010, the initiative only took effect on July 1 2014 after a series of delays. The legislation represents a huge compliance undertaking, and no precedent existed for an undertaking of this scale with such a global reach, but around 90,000 foreign financial institutions (FFIs) – including banks, funds, brokers and investment companies – have registered as FATCA-compliant, and more than 100 jurisdictions have signed or negotiated bilateral intergovernmental agreements (IGAs) with the US to implement the measure.
The original intention behind FATCA was that FFIs would report the information about their US account holders directly to the IRS and Treasury. However, institutions in some jurisdictions pointed out that local law relating to data privacy, for example, would prevent them from doing this and the US developed the idea of bilateral IGAs to make compliance possible.
Under a Model 1 IGA, FFIs will report information about their US account holders to the local jurisdiction, which then exchanges with the US on an automatic basis. In abiding by the terms of a Model 1 IGA they will be judged to be compliant with FATCA and will not have to apply the final regulations.
A Model 2 IGA commits the overseas jurisdiction to "direct and enable" their FFIs to report directly to the IRS about their US account holders. Governments back this up with exchange of information about financial institutions that refuse to comply with FATCA. Under this type of IGA, FFIs will have to apply the final regulations to achieve compliance with the legislation.
The IGAs used as part of FATCA implementation have also been used as models for further information exchange efforts, including the Common Reporting Standard, the method for implementing automatic exchange of information, laid out by the OECD in 2014.
Occupy and Uncut social movements
This was the year during which the tax affairs of multinational corporations catapulted from the more obscure sections of the global media to being splashed across their front pages or leading broadcasting schedules.
For months, it was impossible to leave ITR Towers in London without wading through a sea of tents filled with hippies, socialists, anarchists in masks, punks, students and, yes, ordinary concerned citizens camped outside St Paul's Cathedral. For some they were an eyesore littering the pavement outside one of the UK capital's most famous buildings. For others they were heroes, braving the harsh winter to take a stand. Either way, they sent a message and the media heard it.
The new ad hoc, bottom-up social movements, exemplified by Occupy and Uncut, that have sprung up around the world to try to take over stores and Wall Street alike have tax at the heart of their agenda.
The original campers in Zuccotti Park in New York and outside St Paul's have long since been sent on their way, but the issues they brought to public attention cannot be swept aside so easily.
Detailed information about the tax corporations pay is being splashed across daily newspapers and websites like never before.
Corporate tax matters are no longer simply an interest for shareholders or tax officials, but have become one for society at large.
Occupy and Uncut's methods may divide opinion, but they arguably did more than anyone else to focus media and public attention on these issues.
Financial transaction tax (FTT)
The financial transaction tax (FTT), Robin Hood Tax or Tobin Tax, depending on how you want to describe it, was a long-mooted idea in the EU but not until September 2011, when Jose Manuel Barroso, European Commission president, used his annual State of the Union address to the European Parliament to outline the tax, calling it a "matter of fairness", did it become a policy objective.
The FTT has been referred to by tax justice campaigners as the Robin Hood Tax
The UK, which fears the disproportionate impact the FTT could have on the City of London as Europe's largest financial centre, came out quickly to oppose it. George Osborne, UK Chancellor of the Exchequer, said any non-global FTT proposal is "economic suicide" and "a bullet aimed at the heart of London".
But in spite of this, the once-radical fringe policy gained real momentum in 2012 as 11 EU member states decided to adopt the tax, which would levy a 0.1% tax on trading in shares and bonds and a 0.01% tax on derivatives transactions and which Barroso claimed would raise €55 billion a year.
In a sign of the increasing reach of international corporate tax issues, the FTT became a populist measure that was as much about reining in the financial sector as it was about raising revenues for deficit reduction, tacking poverty and climate change.
Since Nobel laureate James Tobin proposed a tax on currency transactions in 1972, the concept of an FTT has expanded and, as the notion collides with a public sentiment that the financial sector should contribute more towards restoring public finances destroyed in the global financial crisis, it now has backing from four of Europe's five biggest economies.
France and Germany have been the strongest advocates, and with Pierre Moscovici, the pro-harmonisation former French finance minister, about to take over as EU tax commissioner, prospects for FTT implementation are increasing all the time.
G20/OECD project on BEPS
Undeniably the dominant topic in international taxation over the past two years, the base erosion and profit shifting (BEPS) project was launched in September 2013 and constitutes the most ambitious attempt to update international tax rules ever.
"Everything needs to be analysed and revised with the brand new BEPS eyes"
Maribel Mendez, Spanish group tax manager for an automotive company
The OECD's work on harmful tax competition, which got under way in 1998, is a close relative, but the BEPS project has greater political backing based on full endorsement by G20 leaders and universal acknowledgement that rules have not kept pace with the globalisation and digitalisation of business.
Many question whether developing countries are getting enough say in what is being discussed, but the OECD has put significant effort into making the process as inclusive as possible through discussion drafts, public consultations, webcasts and other updates, though this has made reaching consensus more difficult.
The comprehensive BEPS Action Plan drawn up by the OECD
Address the tax challenges of the digital economy
Neutralise the effects of hybrid mismatch arrangements
Strengthen CFC rules
Limit base erosion via interest deductions and other financial payments
Counter harmful tax practices more effectively
Prevent treaty abuse
Prevent the artificial avoidance of PE status
Actions 8, 9 & 10
Assure transfer pricing outcomes are in line with value creation
8) Intangibles
9) Risks and capital
10) Other high-risk transactions
Establish methodologies to collect and analyse data on BEPS and the actions needed to address it
Require taxpayers to disclose aggressive tax planning arrangements
Re-examine transfer pricing documentation
Make dispute resolution mechanisms more effective
Develop a multilateral instrument
"This will not please the NGOs but the CbCR information will go to tax administrations only. This is extremely sensitive information"
Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration, acknowledges the compromises that have been reached to implement a new era of tax reporting for international business
Of course, much of the work to tackle BEPS remains to be completed. The 2014 deliverables were fairly well-received, with the OECD praised for sticking to its ambitious timeline for bringing coherence, substance and transparency to international tax rules around the world, and for managing to reach a degree of consensus without initial proposals being watered down.
The September and December 2015 deadlines are certain to become landmark dates in the history of the evolution of international tax rules.
The OECD unveiled the Common Reporting Standard (CRS) in July to implement the global automatic exchange of information. The standard, which largely builds on FATCA, was first presented to, and endorsed by, G20 finance ministers in February 2014.
Early adopters of the CRS, of which there are 50 countries including 26 of the EU's 28 member states (though not the US), have committed to start exchanging information under the instrument from 2017, with a further 20 jurisdictions saying they will start exchanging information from 2018.
On an annual basis, financial institutions, including custodial institutions, depository institutions, investment entities and specified insurance companies, will be required to report certain information from accounts held by individuals and entities, including trusts and foundations, to their national governments. The CRS will see governments exchanging this information, which will include details of balances, interest and dividends and sales proceeds from financial assets.
At their October meeting, EU finance ministers also agreed to adopt the draft Directive on Administrative Cooperation (DAC), which will incorporate the CRS and enable mandatory automatic exchange of information between member states' tax authorities once national legislation is in place.
UK officials have described the DAC's objective as "switching off" the reporting requirements under the EU Savings Directive.
ITR coverage in July included exclusive interviews with the OECD's Achim Pross, the man responsible for several of the BEPS action items and for the OECD's work on information exchange more broadly, and Jorge Correa, one of the principal drafters of the new standard.
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Coming up in 2016: the transition year
IRS releases final schedule UTP


A car means freedom and independence. We all love the feeling of driving down the road on our way anyplace for an adventure.
Unfortunately, as we age several roadblocks can pop up to force us to examine if this freedom is worth the price for not only the driver but everyone else on the road as well.
There are many causes of impaired ability to drive safely which can affect judgment, decision making, reflexes, memory or focus on the task.
There is no one disorder or reason that should automatically result in taking the keys away but rather each person should be evaluated individually.
A new screening tool to help professionals assess whether an older person is fit to drive has recently been used in Canada.
The SIMARD test (Screen for the Identification of Cognitively Impaired Medically At-Risk Drivers) developed in Alberta is a paper and pen test consisting of four tasks which takes about 5 minutes and is then scored. Depending on the score one can be identified as safe, unsafe or in need of a road test to determine safety.
Doctors in Canada are mandated to report unsafe drivers and this tool will help give older adults a fair way to show their abilities.
Your family, friends and even you worry about driving a car without incident as aging sets in.
We have all heard the news reports when an unsafe driver causes an accident and pray it won't happen to us.
We should all ask ourselves if our individual freedom is worth the risk of another person's well being.
As long as you are able to drive safely, stay focused, and respond appropriately, keep on driving.
When that is not the case, recognize it and ask a professional for help to determine if you are still safe.
Do you have any tips or stories to share to help others?
If you're unsure if it's time to take the keys away, or if your parent refuses to believe it's in his/her best interest, an interesting option is to install SafeKey in their car.
SafeKey is a device that is connected to the engine and will only allow the car to start if you can pass a short cognitive test on a keychain. You can set it up so that if 'Mom' fails the test 3 times you are notified, allowing you to call her and see how she's feeling and ask if you can drive her anywhere. It's a pretty neat tool!
Thanks Jill, that sounds like an interesting technology application to help keep seniors safe, thanks for sharing!
My Nan is an absolute terror on the road these days. She just bought herself a new car and doesn't realise how fast she is moving at times. She got done for speeding a few weeks ago and I'm worried she'll end up having an accident some of these days!
That sounds like a great idea Jill I've never heard of those.


Do you want to know when to sell Bitcoin?
A researcher at MIT has come up with a way to use machine learning to predict the price of the Bitcoin virtual currency. With his system, you could figure out when to sell the remaining Bitcoins you have in order to minimize your loss or maximize your gain. Or you could find out the right time to buy.


Imagine an automation workcell that has many localized work regions of 1 micron accuracy in which commercially available micro-postioners can do their job. And there is a method to move these micro-positioners from various pickup sites to their desired task sites. But this workcell does not need the 1 micron accuracy over a large range of motion, which would have prohibitively high costs.


text:
Movies On The Radio: Movies Set In School Offer Rebellion And Redemption
By Jennifer Brookland ,
The Green Party of Ireland/Flickr Creative Commons
Are school movies enjoyable because they are so relatable? Or do they present the far-fetched, fantastical experiences most bored students only daydream about?
In September's installment of "Movies on the Radio" film experts discuss movies about school. Selections include films that feature righteous teens rebelling against the crushing authority of parents and teachers, and meaningful relationships forged with caring mentors in the classroom.
Host Frank Stasio talks with Laura Boyes, film curator at the North Carolina Museum of Art, and Marsha Gordon, film professor at North Carolina State University, about the best school movies. They also discuss listener's recommendations of movies that deserve an A+.
The North Carolina Museum of Art presents its fall film series, beginning on Friday, Sept. 22 with the Cary Grant film, "Notorious."
Here are some of our listener's favorite school-related films:
1979 film, "Over The Edge"
2003 film, "School of Rock"
1967 film, "To Sir, With Love">/p>
1995 film, "Mr. Holland's Opus"
1999 film, "10 Things I Hate About You"
The State of Things The State of Thingsschool moviesLaura BoyesMarsha GordonNorth Carolina Museum Of ArtNorth Carolina State University
Jennifer Brookland
Jennifer Brookland is the American Homefront Project Veterans Reporting Fellow. She covers stories about the military and veterans as well as issues affecting the people and places of North Carolina.
See stories by Jennifer Brookland

redpajama_set_name: RedPajamaCommonCrawl


text:
Q: Suppose I want to check using if statement like that: IF(?p a dbo:Person,1,0) SELECT * WHERE {
<http://dbpedia.org/resource/Indian_Institute_of_Technology_Kharagpur>

<http://dbpedia.org/ontology/director> ?p.

OPTIONAL{?p rdfs:label ?s}

BIND(IF(isURI(?p) && ?p a <http://dbpedia.org/ontology/Person>.,?s,?p) AS ?r)

}

A: There is still an issue with the exists function in IF statements with Virtuoso. As a workaround, cast the output of exists to xsd:boolean:
SELECT * WHERE {
 dbr:Indian_Institute_of_Technology_Kharagpur dbo:director ?p.
 OPTIONAL{?p rdfs:label ?s}
 BIND(IF(isURI(?p) && xsd:boolean(exists{?p a dbo:Person}),?s,?p) AS ?r)
}

redpajama_set_name: RedPajamaStackExchange


Fun and funky, Laurel Burch's colorful floral design brings nature's whimsy to life.
Light up your home with Narrative's exclusive lighting collaboration with renowned artist, Laurel Burch. Lamp shade is printed with Laurel Burch's original 'Aqua Lavender Floral' art and handmade from the highest quality organic cotton. The vibrant design celebrates creativity with bright pastel flowers in shades of blue, purple, pink and green.


text:
Q: What is the difference between SELECT and SET in T-SQL I'm working on a stored proc that executes some dynamic sql. Here's the example I found on 4GuysFromRolla.com
CREATE PROCEDURE MyProc
  (@TableName varchar(255),
   @FirstName varchar(50),
   @LastName varchar(50))
AS

    -- Create a variable @SQLStatement
    DECLARE @SQLStatement varchar(255)

    -- Enter the dynamic SQL statement into the
    -- variable @SQLStatement
    SELECT @SQLStatement = "SELECT * FROM " +
                   @TableName + "WHERE FirstName = '"
                   + @FirstName + "' AND LastName = '"
                   + @LastName + "'"

    -- Execute the SQL statement
    EXEC(@SQLStatement)

If you notice, they are using the keyword SELECT intead of SET. I didn't know you could do this. Can someone explain to me the differences between the 2? I always thought SELECT was simply for selecting records.

A: Basically, SET is SQL ANSI standard for settings variables, SELECT is not.  SET works only for single assignments, SELECT can do multiple assignments.  Rather than write a long explanation that is well summarized in many places on the net:
ryan farley blog
tony rogerson
stackoverflow

A: Select allows multiple assignments.
EDIT you beat me by 44 seconds

A: SELECT is ANSI, SET @LocalVar is MS T-SQL
SELECT allows multiple assignents: eg SELECT @foo = 1, @bar = 2

A: SELECTs may be faster if you need to assign multiple values:
http://sqlblog.com/blogs/alexander_kuznetsov/archive/2009/01/25/defensive-database-programming-set-vs-select.aspx

A: Select can also be used to get the variable assignment from a select statement (assuming the statement only returns one record)
Select @myvariable = myfield from my table where id = 1


text:
<?php

/*
 * This file is part of PHP CS Fixer.
 *
 * (c) Fabien Potencier <fabien@symfony.com>
 *     Dariusz Rumiński <dariusz.ruminski@gmail.com>
 *
 * This source file is subject to the MIT license that is bundled
 * with this source code in the file LICENSE.
 */

namespace PhpCsFixer\Tests\Fixer\Casing;

use PhpCsFixer\Tests\Test\AbstractFixerTestCase;

/**
 * @author Dariusz Rumiński <dariusz.ruminski@gmail.com>
 *
 * @internal
 *
 * @covers \PhpCsFixer\Fixer\Casing\LowercaseKeywordsFixer
 */
final class LowercaseKeywordsFixerTest extends AbstractFixerTestCase
{
    /**
     * @param string      $expected
     * @param null|string $input
     *
     * @dataProvider provideFixCases
     */
    public function testFix($expected, $input = null)
    {
        $this->doTest($expected, $input);
    }

    public function provideFixCases()
    {
        return [
            ['<?php $x = (1 and 2);', '<?php $x = (1 AND 2);'],
            ['<?php foreach(array(1, 2, 3) as $val) {}', '<?php FOREACH(array(1, 2, 3) AS $val) {}'],
            ['<?php echo "GOOD AS NEW";'],
            ['<?php echo X::class ?>', '<?php echo X::ClASs ?>'],
        ];
    }

    public function testHaltCompiler()
    {
        $this->doTest('<?php __HALT_COMPILER();');
    }
}

redpajama_set_name: RedPajamaGithub


text:
Governments change… the lies stay the same.
A slew of legal troubles behind the scenes led to a six year gap between Bond films. As a result, Timothy Dalton resigned and Pierce Brosnan was brought in to take the helm (the man originally intended to step in for Roger Moore were it not for other contractual obligations).
The fall of the Berlin wall has changed the face of world politics since the last film. Bond, although never directly involved with America's struggle against Russia, is very much a product of the Cold War. That's all over now, leading some to wonder if the franchise should end altogether.
This leaves the producers with an uphill struggle, trying make Bond relevant and interesting in a age where the very core of the character has been dissolved.
Instead of dodging the issue, GoldenEye tackles it head on.
In 1986 007 is sent on a mission with 006 (Sean Bean) to destroy a Russian military facility. 006 is captured and Bond leaves him for dead in his escape. Years later we rejoin Bond on a mission to follow a member of a crime syndicate. He uncovers a plot to steal an EMP weapon from the Russians, fronted by his ex-colleague.
One would expect GoldenEye to try something radically different in its attempts to appeal to a 1995 audience, and yet the exact opposite happens. This is almost a 'back to basics' for Bond, not quite harking back to Dr. No but almost. The women, the action & the gadgets are all there, but somehow it all feels revitalised.
Instead of a completely new idea, the producers opted for a subtle shift in tone. This is a deft move; it keeps the fans happy while helping to bring the franchise into the 21st century.
At the forefront of this change is Judi Dench as M. She gets a small but key role in establishing some of the much needed self-awareness GoldenEye exhibits. She's cold towards Bond and shows disdain towards him, famously saying "…I think you're a sexist, misogynist dinosaur. A relic of the Cold War…". This is something that needed to be said before we could move on; Bond has been getting away with this crap for sixteen films now…
There are lots of new elements brought in behind the scenes too, notably the new director Martin Campbell. He is confident and makes the big action scenes stick. He has a way of bringing us into the moment through close attention to detail. The close-ups of the actors match the wide-shots exactly, despite being shot in two completely different studios. We never feel like we are about to sit back and watch a stunt man do his thing for ten minutes.
Brosnan is also a welcome addition. He is intense but not without a sense of humour, and seems more involved in a lot of the stunt work. He also manages to convey a situational awareness sometimes lacking in the others; it looks like he's actually thinking about the plot and what he's supposed to be doing, rather than just 'do I look cool?'.
He's helped out by some talented writing. Every character in GoldenEye serves some purpose and no-one is forgettable. Alan Cummings as Boris the computer hacker, Robbie Coltrane as the Russian gangster, Famke Janssen as the crazy thigh-squeezing killer Xenia Onatopp… the list goes on. If you've seen the film, you know who I am talking about. This probably hasn't been the case since Goldfinger (where you know the characters even if you haven't seen the film…).
Ironically enough the dullest character is the one most central to the plot - Sean Bean's Alec Trevelyan.
GoldenEye is a promising start to a new era. It somehow breaks new ground on an idea that began in a very different time, whilst being every bit as entertaining and exciting as the best of them.
Dir. Martin Campbell, 1995


Reminder Tabs is a Google Chrome extension. When you have a tab open you can click on the Reminder Tabs button and have that tab automatically open at a later time. You can set it to open once at a later time, or daily, weekly, or monthly.
I made it because bookmarks never worked very well for me. I would bookmark a page and then never look at my bookmarks. With Reminder Tabs, the page will automatically open up later so I won't forget about it.
Snap Together is an Android app I made in Summer 2017. It's for groups of people to be able to share photos easily. A user creates an album and others join the album. Each album has a start and end time, name, and a password. Anyone who joined the album will automatically have their any photos they take during between the start and end time added to the album. Everyone who joined the album will have easy access to everyone else's photos.
This app is intended for when groups of people get together for a event, such as a wedding, party or trip. Everyone in the group can easily access everyone else's photos. No more having to ask everyone to send their photos to you or monitor their Facebook page for new photos.
This is an Android app, so it's written in Java and uses Gradle and Android Studio. It also uses Cloudinary, Retrofit, Glide and the Google login API for Anrdoid. Python, MongoDb, and Flask are used for the backend server. During development I hosted the backend on my Linode (Ubuntu server).
I haven't published the app to Google Play. For now I have other projects that I am more interested in.


Specially designed for garages that don't allow for a traditional garage door opener, our ultra-quiet, space-saving, wall-mounted jackshaft opener is perfect when you need to save space or have an oversized door or cathedral ceiling. It mounts on the wall beside the garage door, so ceiling space is freed up for maximum storage. This unique system offers the added option of our Battery Backup system to let you in and out of your garage even when the power is out, as well as our premier line of accessories for the ultimate in garage access.


Why Having a Responsive Website Is Not Enough for Startup Success?
Why Having a Responsive Website Is Not Enough for Startup Business Success?
So you have resized your browser and found responsive website pages adjusting according to the size?
You are happy because you believe that your website is now ready for mobile devices and you think you have achieved all your website design goals.
Let us be more frank before discussing further. You are actually losing users and even sales if your goals are all about responsive web design. However, you can do it well.
Since the 2000s, developers and designers have been offering responsive web solutions to simplify the problem. Likewise, people now perceive responsive website is the one-shot solution to all their issues.
Above any other goal, it is universal fact that mobile web should be fast and smoother. Today, delivering the smoother, fast and reliable user experience to all the mobile users has been a big challenge for marketers, especially when it comes to implementing a technique of responsive web.
In simple words, responsive website design is good, but it cannot be a silver bullet. If you rely only on responsive web design for mobile, even a performance issue can hinder the conversion. Today, over 11% of websites in the world are responsive. So, let's talk about it!
If you have really an amazing dynamic website which has all the relevant content but still not enough to get business, it's time to make changes to your digital marketing strategy.
These days, everyone is looking forward to making their website mobile-friendly so it appears well. But it is not enough to take your digital strategy to another level. According to a research, customers spend around 89% of their media time on mobile apps worldwide, for using most popular apps for news, email and social network.
According to the reports, users spent up to 82% of media time to access services on smartphones in 2012. According to a recent data from Flurry analytics of Yahoo, users spend over 90% of the time in apps.
Get a mobile app that generates significant revenue!
We live in an App World and the whole Web Resides here. So, if you still rely on the responsive website, you are losing up to 90% of target users on the web for just 10% of user time.
Initially, responsive web design was considered as a "First Aid" solution, a quick fix for website owners who were trying to attract more new users. This approach just focuses on turning a traditional old-fashioned website into a mobile friendly one. But as smartphones become too common, it becomes more important to provide a complete mobile platform.
In responsive web design, content is one of the major issues. These days, content is just rearranged as per the screen size of mobile devices. So, it is important to make a complete mobile web strategy, instead of just focusing on mobile-based perspective.
As of now, responsive design has no back end support. It is the worst part of it. There are chances that you will have to restructure the design to deliver content in a wide range of devices in the near future.
When a site is loaded on your mobile device, it may also cause lagging issues. Due to less processing strength and slower connection, mobile devices can hardly load websites when compared to desktops. So, it is important to use cascading style sheet (CSS) for an app to run on every device.
Sometimes, responsive website design does not get most of the native features available on mobile devices. Using basic features like camera integration and GPS totally change the look and feel for mobile users.
Graphics and images also cause issues in responsive design as they have to be resized or scaled from the content. They sometimes take a longer time to appear and they are not suitable for mobile devices. This way, additional images are created to improve page load times, ideal UI, and adjust for the device detected.
With the help of responsive delivery, the server can also detect the device and adjust the content for the device without delivering any extra data.
Instead of acclimatizing the menu with responsive design, responsive delivery creates a different mobile menu. New menus add external elements and leave unwanted pages and open maps with Google Maps and other map applications.
The same text is displayed in responsive web design no matter a visitor comes from a desktop or mobile. On the other hand, responsive delivery customizes the text as per the needs of visitors and features like click-to-call.
The desktop versions have mouse over elements that are obviously useless for mobile users. On the other hand, one can replace these events with new image sets or components which can go well with mobile, in the case of responsive delivery.
Since browsers will parse and load all the styles and selectors for all devices, it is not wise to rely on CSS media queries always. A mobile device will parse and download the CSS to work on larger screens. CSS would waste the valuable milliseconds of the users relying on mobile data as it blocks rendering.
On the native devices, the matchMedia query won't change. For instance, iPhone is not able to convert the page as per the size of iPad. So, it becomes important to load CSS. However, a feature detection tool like Modernizr is also used to make quick and sensible steps to improve the user interface and functionality which relies not just on dimension.
We can help you reach your desired business goal with our cost-effective mobile application development!
To address the needs of your customers, there are several invaluable tools available thanks to the advancement of technology. Since 90% of traffic comes from mobile apps, it's time to go mobile completely with mobile app development.
The custom mobile application development can help you stand out of competition, save time to market and interact with more customers the right way. The mobile app showcases a lot of things about your business. So, you should develop a smooth and quick application for the business to reach the target audience.
Well, there are some other techniques to get the most of the responsive design without having to affect its performance. Responsive web design has never been made to improve performance. So, it doesn't make sense to blame the technique as a whole. On the flip side, assuming it to fix all the issues, as most people do, is also not good.
Responsive web design is important as we have to face several screen sizes from desktops to mobile. But considering screen size only is overlooking other aspects of increasing visibility. The line between mobile and desktop has been blurred, but there are still various possibilities as per the type of devices.
Some of the reviewers may call it just 'responsive web design' with modern outlook while some call it a 'responsible responsive website design'. Without going further, be sure to understand and know the problem.
Prefer a mobile-friendly approach if you are starting from scratch.
Each page must have the same URL for all the devices with same content. But it is not necessary to deliver it with same the structure.
Improve and measure performance with certain optimization tools.
Test responsiveness on real devices to see what if when applying"display: none" and when resources will load, rather than just resizing the desktop browser.
Showcase above-the-fold content before others, or align initial view of pages for your target mobile devices.
Responsive delivery is likely to become a potential solution for some of the issues in responsive design. But it cannot fix all the issues. However, it can definitely mitigate the performance issues. However, you can still find much in native features and back end support. You can rest assured that mobile technology will evolve and become the leading web strategy for many.
We are not saying that you must go completely mobile with an "m." subdomain and we are not against responsive web design. In fact, it is better to assign only one URL in all devices is better with the emergence of social sharing. However, it doesn't mean you have to deliver the same thing on a single URL or that same resources must be downloaded on all devices. Having just a responsive website for your business has become the things of the past. Today, you need to perform responsive delivery of content.


Like every other institution in our society, colleges and universities are affected by the changing climate. They face new threats to campus infrastructure, and to the safety of students, faculty and staff. But while colleges and universities grapple with these problems, they can also be part of the solution. That's the conclusion of a pilot project — Climate Resilience in Urban Campuses + Communities (CRUX) — designed to boost the resilience of higher education institutions and the communities they inhabit.
A campus is not an island; its risk and resilience is tied to that of its surrounding community. It makes sense, then, to work with community members to assess challenges and brainstorm solutions. Colleges and universities have much to bring to the table, including research and technical capacity, and the stature to convene a diverse group of interested parties.
In some places — such as Fayetteville, Arkansas — universities are starting the conversation about climate resilience. Faculty and students from the University of Arkansas convened community leaders responsible for pieces of the resilience puzzle — including human health, the natural environment, and emergency response — who rarely sat at a table together. Together, they reviewed likely climate impacts, tallied community assets, and developed an action plan to reduce vulnerability.
Elsewhere, the conversation begins with a climate-related crisis. That's what happened in Aurora, New York, home to Wells College. Despite a history of strained town-gown relations, the college and town came together in the summer of 2017 to deal with harmful algal blooms (HABs) in neighboring Cayuga Lake that threatened their shared drinking water supply. The college and town worked together to explore short-term solutions, and — because HABs are a known climate change impact — this crisis lent urgency to broader resilience planning.
Climate disasters hit marginalized people first and worst. Many colleges and universities have connections to vulnerable communities, through direct service programs or ties to local community organizations. Those connections can be leveraged to build the resilience of those communities, ensure their inclusion in adaptation planning, and provide help in an emergency.
And, as "anchor institutions" in their communities, colleges and universities can lend their facilities to the cause of preparing for — and recovering from — climate impacts. For example, a university can designate a space on campus as a resilience hub, which offers community relationship-building as well as cooling centers and emergency shelters.
Research and innovation are the twin superpowers of higher education institutions — and they can be deployed to address the challenge of climate resilience. Faculty can design curricula on climate impacts and solutions, and support students in research, outreach, and implementation of projects.
Universities can improve the resilience of campus infrastructure, which may also benefit surrounding neighborhoods. And, because universities face many of the same challenges as the larger community, they can model actions and pilot initiatives on a smaller scale.
Many colleges and universities are initiating efforts to conserve energy use and develop responsible storm water management. For example, the University of Illinois Chicago has developed a green infrastructure plan that would re-landscape UIC's 240-acre downtown campus to capture and retain storm water. This will help keep runoff out of the city's combined storm water-sewer systems, which contaminate local streams, rivers, and Lake Michigan — Chicago's drinking water source. Storm water management is especially impactful as climate change triggers more intense precipitation events.
Hunger is a problem for many communities and campuses, and climate change can make the problem worse. Droughts and storms can ruin crops and boost food prices; disasters can sever food supply chains. Colleges and universities can help address food insecurity and promote greater local self-sufficiency by, for example, supporting urban agriculture initiatives and expanding access to food assistance programs.
To help ensure food security among its students, California State University Northridge (CSUN) maintains a food pantry, food garden, fruit trees, and a food system that works to find and help students who are food insecure. CSUN also promotes the use of CalFresh EBT cards (a state food aid program) at campus farmers markets for those who need it. Similarly, Chatham University in Pittsburgh works with the local Food Policy Council to improve access to healthy foods in public schools and low-income communities. And Chatham's food service sources food from local farms — including one on campus — leveraging its purchasing power to build a vibrant local food movement.
Climate change poses unprecedented challenges to our communities, colleges and universities included. As we work to address these challenges, institutions of higher learning have much to contribute. Through innovation, infrastructure, and our greatest asset — engaged, committed, smart students — we can lead the way to a climate-resilient future.


text:
require_relative '../helper.rb'

describe SpheroPwn::Commands::SetDeviceMode do
  it 'stringifies a normal mode request correctly' do
    set_device_mode = SpheroPwn::Commands::SetDeviceMode.new :normal
    sequence = 0x52

    assert_equal [0xFF, 0xFF, 0x02, 0x42, 0x52, 0x02, 0x00, 0x67],
                 set_device_mode.to_bytes(sequence).unpack('C*')
  end

  it 'stringifies a user hack mode request correctly' do
    set_device_mode = SpheroPwn::Commands::SetDeviceMode.new :user_hack
    sequence = 0x52

    assert_equal [0xFF, 0xFF, 0x02, 0x42, 0x52, 0x02, 0x01, 0x66],
                 set_device_mode.to_bytes(sequence).unpack('C*')
  end

  describe 'when sent to the robot' do
    before do
      @session = new_test_session :set_device_mode

      @session.send_command SpheroPwn::Commands::GetDeviceMode.new
      response = @session.recv_until_response
      unless response.code == :ok
        raise RuntimeError, 'Could not retrieve initial mode from device'
      end
      @old_mode = response.mode
    end
    after do
      @session.send_command SpheroPwn::Commands::SetDeviceMode.new(@old_mode)
      response = @session.recv_until_response
      unless response.code == :ok
        raise RuntimeError,
            "Could not restore initial device mode #{@old_mode}"
      end

      @session.close
    end

    it 'impacts the result of the get device mode command' do
      [:normal, :user_hack].each do |mode|
        @session.send_command SpheroPwn::Commands::SetDeviceMode.new(mode)
        response = @session.recv_until_response
        assert_kind_of SpheroPwn::Commands::SetDeviceMode::Response, response
        assert_equal :ok, response.code

        @session.send_command SpheroPwn::Commands::GetDeviceMode.new
        response = @session.recv_until_response
        assert_equal :ok, response.code
        assert_equal mode, response.mode
      end
    end
  end
end


text:
Restaurant Report: Catch on the Ave.
by Britt Patterson | 12.27.18
"This is exactly the restaurant Alexandria needed," was the consensus the other night as we sat in our spacious booth at the soft opening of Catch on the Ave. Stuffed to the brim with bang-bang shrimp, scallops, and Mahi, while still slowly sipping on "Apples for Sail" and "Gin and the Giant Peach" signature cocktails, we all agreed this restaurant is going to be a hit.
Between the seasonal menu and innovative cocktail program, "Catch" brings a completely unique experience to Alexandria residents. The way Chef Eric Reid, the head chef at Augie's Mussel house, was able to marry seafood fare with East Asia and Southeast Asia flavors is something totally different and the result is fantastic food.
You will find items on the menu where unexpected Asian influences delight. Whole rainbow trout in ginger and scallion sauce, shrimp po' boy sandwiches with shaved napa cabbage, jackfruit lettuce wraps, Shrimp and Vegetable Dumplings and Sticky Pork Rib Wings were the ones that stood out to me. But, of course, you still have your seafood classics – bang-bang shrimp, pecan-crusted Mahi, hot catfish sandwiches, and beer-battered fish and chips.
The shabby-chic vibe of the reclaimed wood walls and the bright red accents give you the feeling you're in a trendy downtown bar that will likely become your go-to, post-work drink spot, but at the same time, you feel this is a place where you can bring the entire family and grab an awesome, stress-free meal (there's a kids menu!).
"Catch" is the newest restaurant by Common Plate Hospitality (Mason Social, Augie's Mussel House, and Urbano 116 – opening soon) opened for business last week at 2419 Mount Vernon Avenue, where SnackBar was previously located. They will be offering lunch, dinner, and brunch menus, and their hours will be 11am-midnight Monday through Friday, and 9am-midnight Saturday and Sunday.
photos courtesy Catch on the Ave.
The latest from Britt
Britt Patterson
Vice President	|	The Patterson Group
http://phyllispatterson.com/
britt@pattersonrealestategroup.com
Born, raised, and bred in Alexandria, VA, Britt Patterson is a true product of the great state of Virginia. Britt attended Waynewood Elementary (Class of '96), Carl Sandburg Middle School (Class of '98) , and West Potomac High School (Class of '02), she then went on to attend Virginia Tech (go Hokies!) where she majored in Business Marketing and Minored in Real Estate. Britt "officially" joined the family business as a licensed Realtor in 2008 after two years of working the political fundraising field and prides herself on her Alexandria real estate knowledge, alongside her integrity, loyalty, and professionalism as an agent and Vice President for the family business.
By	Britt Patterson
My Burke Drive Memoir
The Four Best Engagement Photo Locations in Old Town
The Patterson Group is one of the most experienced and trusted real estate teams in the area, serving Alexandria, VA for over thirty years. We offer professional, hardworking, detailed and friendly service and a large network of contacts and resources accrued over our many years in Alexandria real estate. Comprised of seven Alexandria locals, six of whom are licensed realtors and three of whom are accredited staging professionals, The Patterson Group is passionate and knowledgeable about Alexandria, VA and here for all of your Northern VA real estate needs. Allow us to help you find your home here and discover all that the Alexandria lifestyle has to offer.
phyllispatterson.com


Pvc sheet is used for for chemical storage tanks, towers, oil tanks, and photographic developing instruments. In case of fires, this material is self-extinguishing. Easy to fabricate and has strong glue joints. Can be painted and screen printed.
<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />PP sheet are widely used in chemical industries, anti-corrosion project, water purification, environment protection equipment, electronic etc industry .such as structural tanks and covers, tank linings, plating barrels and tanks, vacuum forming all kinds of parts and trays ,artificial limb etc. pickling tanks.
pp sheet may be customized by adding reinforce material(glass fiber), fire resistance and filling modification material(calcium),such as FRPP sheet and Calcium-added pp sheet etc.


During the afternoon/evening on Wednesday June 29, there will be a possibility to join an excursion.
There will be two alternatives. Please indicate in the registration form which excursion you would like to attend.


This website is operated by AirLuxe Ltd (hereinafter referred to as 'the company') and is aimed primarily at a UK Mainland (excluding Northern Ireland) b2b audience, although some products may also be available for delivery to Northern Ireland, UK offshore islands, Irish Republic and to much of Europe, please contact us to establish availability of products to these destinations. Freight surcharges will apply to areas not within mainland England, Scotland or Wales, please establish with us these costs before placing an order.
The placing of an order on this website will in no way imply acceptance of an order and we reserve the right to reject any order placed, for whatever reason and at any time prior to delivery, should we feel it to be necessary or prudent. Any monies paid will be refunded without undue delay should we reject any order.
The company employees, directors and associated companies accept no liability for loss or injury arising from the use of any information contained within this web site. All copyright, design rights and other intellectual property rights in our designs and products (and in the images, text and design of our websites) are and will remain the property of the company and / or the copyright holder if a third party. Any infringement of these rights will be pursued vigorously.
From time to time, certain terms and conditions may be reviewed and updated, but not necessarily listed on this site. Please e-mail for any amendments. All orders placed with the company by whatever means are subject to these terms and conditions and the placing of any order explicitly implies acceptance of our terms and conditions.
No information contained within these terms and conditions is intended to affect the statutory rights of the purchaser.
When placing an order for Carpets, Vinyls or other types of floorcoverings, we strongly recommend that you add at least 10cm to both length and width of your measured sizes, to allow for manufacturing tolerances and to ensure a good fit. An exact colour match can not be guaranteed when ordering different widths of material or when ordering at different times. Samples supplied by us are only representative of shade, colour and texture, and an exact match can not be guaranteed as your floorcovering will be supplied from stock which is current at the time of ordering. Illustrations are for guidance only, please bear in mind that screen resolutions and settings vary between devices, meaning that colours shown on your screen may not be an accurate representation and we do therefore recommend checking colours against a sample.
Please note that all carpets are subject to dye batch variation, therefore carpets ordered on two separate occasions may not be a perfect match. There may also be a dye batch variation between representative samples submitted and a carpet subsequently supplied. Colours of certain underlays and their chain pattern or backing may vary from batch to batch. Some products may be sold under more than one name and occasionally wrappers will display one of the alternative names, but the contents of the wrappers will be as per our listed specification. In the rare event that we are out of stock of a particular product, we will not send a substitute without your approval either written or verbal. If we are unable to supply part of an order due to stock delays or issues, we may despatch those items which are in stock, with the remainder to follow, or alternatively, provide a refund in respect of items that are unavailable.
When ordering more than one piece of carpet from the same width you are asked to inform us at the time of ordering if the carpets are required to be shade matched from the same production batch. It is not possible to shade match different widths of carpet. Carpets of the same type and colour, but ordered on separate occasions can not be guaranteed to shade match. It is the sole responsibility of the purchaser to ensure that measurements and quantities ordered are fit for the purpose intended and the company can take no responsibility for errors by the purchaser. All goods are offered subject to usual b2b trading terms and conditions. When ordering a product shown on this site you are explicitly confirming eligibility to purchase. We do not solicit, nor enter into, consumer contracts.
All products offered on this site are subject to manufacturing tolerances. Measurements for surface floorcovering materials such as carpet and vinyl are subject to a manufacturing tolerance of +/- 1.25% in respect of width and length. Products such as underlay are offered subject to a manufacturing tolerance of +/- 1.25% in respect of width and length, the tolerance on thicknesses being +/- 10%. These tolerances apply to items offered for sale as perfect or first quality product only. These tolerances do not apply to items offered as graded products whereby variations may be greater than normal tolerances. When purchasing roll quantities these will normally, subject to availability, be sent as whole roll items although occasionally it may be necessary to fulfil an order for roll quantity in more than one piece. When ordering by the square metre, the quantity will be sent according both to manufacturers maximum roll size and/or available stock.
Goods are supplied on the understanding that they will be examined before being cut and installed, as we will not accept for return, any goods displaying visual defects which reasonably should be expected to be obvious before cutting and installation. We will not accept liability in respect of any expenses incurred by way of installing products which you later claim to have defects. We will not accept liability in respect of any third party who fails to discharge their duties for any reason whatsoever.
Delivery times quoted are approximate and are subject to prevailing circumstances. We do not accept responsibility for any delay in delivery caused by circumstances outside of our control, such as, but not limited to, mechanical breakdown, road closures, adverse weather conditions, delivery company errors or oversight. We do not accept liability for expenses incurred with third party organisations or individuals and therefore strongly recommend that you do not arrange for installation of products until those products are in your possession.
When you order products from the company, we make only a one off delivery charge for the first item, additional items are carriage free when ordered at the same time. This is referred to as the 'nominal delivery charge' and is often less than the 'actual delivery cost' of getting the goods to you, so is often the equivalent of a substantial discount. Delivery services are operated by third party carriers who will require a signature confirming that goods have been delivered in good condition, it is therefore essential that you examine goods for damage prior to accepting delivery, as the carriers will not consider complaints regarding transit damage afterwards. If you request us to leave goods without a signature, these will be deemed as arriving in good condition and no claims will be entertained for loss or damage.
Many goods are despatched by us on a 'next working day delivery' basis, but allowance should be made for the eventuality that the carrier is unable to deliver on the anticipated day, due to unforeseen circumstances such as weather conditions, road closures, etc. It is the responsibility of the purchaser to ensure that sufficient arrangements have been made to accept delivery of the goods. The company will not be responsible for any consequential loss or damage when this requirement has not been met. Any re-delivery costs incurred will be charged to the purchaser when sufficient arrangements have not been made to accept the delivery. Please note that most carriers operate a doorstep delivery service, which in the instance of tenement blocks, tower blocks or similar with shared access, means the entrance to the building rather than individual flats or apartments.
'Off The Shelf' items are those that have not been cut, altered or modified to satisfy your order, these may be considered for return in the event that you have changed your mind or have over-ordered. Examples of 'Off The Shelf' items are full rolls of underlay, full boxes of gripper, full rolls of tape, etc.
'Off The Shelf' items may be considered for cancellation within 7 days and should be returned to us within 7 days of cancellation if accepted by the company, in which event a handling charge of 15% will be deducted from any refund, subject to a minimum charge of £25.00 in addition to any carriage and freight charges for which you are liable. You are required to contact the company in writing to obtain a 'returns authorisation' as no refunds will be processed without this. The purchaser is responsible for return carriage costs if the goods have already left our premises, the cost of returning an item will vary from product to product and a quote should be obtained from a parcels or freight carrier. Returned items should be in unused, undamaged and re-saleable condition. Items that have been returned that are not in a condition that would be regarded as reasonable, such as items that have been poorly handled, abused, cut or used will have an appropriate deduction made from any refund due. The 'actual delivery cost' of sending the items to you will be deducted from any refund.
Bespoke items, such as carpets, vinyls, matting and part rolls of underlay that have either been ordered in from our supplier or cut from our own stock to fulfil a specific requirement in terms of colour and size, will not be considered for cancellation. No refund or credit will be considered in respect of goods which have been cut, tailored, altered or manufactured in accordance with a purchasers order or instructions, nor for special order goods procured by the seller to fulfil a purchasers requirements. Some carpet and floorcovering products shown on this site may be displayed with example sizes and prices which can be selected from a drop down menu. These are not pre-cut sizes. Once an order is placed, the carpet or floorcovering is then cut from the roll and tailored to meet that specific order, this is therefore regarded as a bespoke order.
If you refuse to accept delivery because you have changed your mind or have made a mistake, you will be responsible for the 'actual delivery cost' of the outbound element of the carrier charge, together with the 'return delivery cost' of the goods being returned to us by the carrier. When placing your order you will have paid a 'nominal' delivery charge which is often substantially less than the 'actual' delivery cost charged by the carriers and in the event that you refuse or cancel your order after despatch, you will be liable for the 'actual' delivery cost in addition to the return carriage costs. It is the responsibility of the purchaser to ensure that the goods are returned to us and in a saleable condition, commensurate with the condition in which the goods were originally dispatched.
The above does not apply to goods proven to be faulty, whereby purchasers legal rights apply.
From time to time we operate promotions whereby items such as underlay, gripper or other products are given away free with an item purchased. In the event that you wish to return a purchased item, the company will also require the return of the items given free as part of the promotion.
Refunds are usually made within 14 days from cancellation or return. If you have paid by Credit Card a deduction of 2.5% to cover card processing fees will be made, similarly, if you have paid by Debit Card a deduction of £1.00 will be made. There is no deduction for payments via PayPal.
Modern methods of production, scanning and inspection mean that it is unlikely that you will receive a product that has any kind of manufacturing defect, although it is impossible to give 100% assurance. In the unlikely event that you feel a defect is present in goods you have taken delivery of, we require written advice of this, together with photographic evidence in all instances. Such photographic evidence is essential in determining the extent and possible cause of any defect and no complaint can be progressed without photographic evidence. Once a complaint has been actioned, you will be issued with a reference number. Please note that we will not accept liability for defects which have been caused after delivery, by negligent or wilful actions of the purchaser. their agents, or any person working on behalf of the purchaser or their agents. Complaints that are raised to gain financial benefit and which are proven to be not genuine, will be treated as attempted fraud and appropriate action taken.
Some products may be offered in the general market place under more than one brand name, there may therefore occasionally be a variation of identification shown on wrapping materials, but the product delivered will be otherwise as per specification. All product information is to the best of our knowledge correct at the time of publication, however allowances should be made for specification changes made to any product by the manufacturer.
In the event of any errors or omissions from our terms of trading, it will be deemed that normal business to business terms and practises apply.


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text:
Florida Governor Calls for Special Session to Counter Vaccine and Mask Mandates
Thursday, Oct 21, 2021 - 03:02 PM
By Jannis Falkenstern of The Epoch Times,
Florida Gov. Ron DeSantis on Oct. 21 called for a special legislative session to consider bills countering vaccine and mask mandates.
The move follows a series of covid vaccine mandates imposed by the administration of President Joe Biden. This does not sit well with the Florida Governor, and he has "had enough" of federal interference into state business, Christina Punshaw, Press Secretary told the Epoch Times.
The legislative proposals include the provision of reemployment assistance to people who are fired due to failure to comply with an employer's vaccine mandate. Under another proposal, Floridians who have an adverse reaction to a vaccine would be eligible for workers' compensation.
Employers who fire workers solely based on the vaccine mandate would be prohibited from enforcing non-compete agreements against the employees, according to another proposal. Another provision would require employers to provide and religious and health exemptions to vaccine mandates. Meanwhile, companies that fail to notify employees about the exemptions would be liable to lawsuits by fired employees.
President Joe Biden last month ordered the Occupational Safety and Health Administration (OSHA) to create a rule to require all private employers with 100 or more employees to mandate vaccines or require them to submit to weekly COVID-19 testing. The rule could affect nearly 80 million workers according to administration officials. Businesses could face fines up to $14,000 per violation.
Although the rule is not yet in effect, a large number of private companies have mandated vaccines for their employees in anticipation of the rule.
According to Charlotte County attorney Charles Heekin, the Florida legislature could tackle the vaccine mandate issue by building on the right-to-work protection in Florida's Constitution.
Florida is an at-will employment state. Employers can fire, demote, hire, promote and discipline employees for almost any reason, or no reason at all. As a result, the strongest recourse for private company vaccine mandates is through legislative action.
In April, DeSantis signed an executive order banning vaccine passports in the Sunshine State. In May, he signed a bill into law codifying the ban. The law (pdf) prohibits businesses from requiring customers to prove their vaccination status. It also prohibits government entities in Florida from issuing such documents.
"In Florida, your personal choice regarding vaccinations will be protected and no business or government entity will be able to deny you services based on your decision," DeSantis said in May before he signed the bill into law.
Republicans in Texas, Wyoming, and Nebraska are considering statewide laws against vaccine mandates.
A special session in Texas wrapped up without a vote on a bill countering the vaccine mandate backed by Gov. Greg Abbott (R).
Lawmakers in Wyoming will hold a special session next week to consider bills to counter vaccine mandates.
In Nebraska, Republicans need more votes to trigger a special session to consider similar bills. In a news release, the senators say there is a "growing concern that employers will require their employees to choose between their jobs or being vaccinated without regard to their good faith personal objections."


Now that we are officially 30 days from Auburn's 2015 season-opener against Bobby Petrino's Louisville Cardinals in the Georgia Dome, let's do something fun. Let's countdown the top 30 Auburn games over the last 30 years that were played inside the great Jordan-Hare Stadium. And let's take the next 30 days to do it.
Wait… haven't we done that before? Well yes, we did that prior to the 2010 season. Do you remember what happened in the 2010 season? But on top of that, I think there may have been a few games over the last 5 years (*cough* 2013 *cough*) that probably knock a few of those older ones out. Not to mention, I had two games in the previous list that are now over 30 years old.
Just as last time, I expect many disagreements, so let me know you disagree – or agree – in the comments section. I think most of the games that do stick around will at least be a in different spot, so the excitement will be so fresh and so clean. As I say that, I realize #30 is the same as the 2010 version of this list. Oh well, that's the only one.
How I Remember It: This game was supposed to be a blowout. Syracuse came in with a lousy record. Auburn had the close loss to USC, but had won three straight and was nationally ranked. I had no doubt going into Jordan-Hare Stadium that night that Auburn would easily exact revenge over the 2001 loss to the Orangemen (they were still the Orangemen at the time).
My only visual memories of the game were Syracuse returning a punt for a touchdown in the first half and watching Cadillac run around left end (I think) in triple overtime to win it. I also remember the game ended around midnight as a result of the free football.
What Really Happened: Auburn came into the game heavily favored and should have blown Syracuse away, but after the Orangemen kicked a field goal, returned a punt 85 yards, and tacked on a 68-yard rushing touchdown, things looked pretty bleak for the Tigers. That's when backup quarterback Jason Campbell and Company scored 24 straight points, taking the lead 24-17 with seven minutes to play.
Syracuse ended up driving down the field, with their own backup quarterback, and scored to the tie the game with 25 seconds left. That's when things really got crazy.
In the first overtime, Syracuse had to settle for a field goal attempt. They ended up fumbling the snap, giving Auburn the chance to win with just a field goal. As if the 2010 Outback Bowl gods were watching, Auburn ended up having their field goal attempt blocked to send the game into double overtime.
Both teams scored rushing touchdowns in the next overtime period, Cadillac scoring his first of two for the game.
In the final overtime, Syracuse had to settle for a field goal and was successful, giving Auburn the chance to win with a touchdown. That's when Cadillac ran around left end for a 7-yard score to give Auburn the win.
Fun Fact: Auburn and Syracuse have played three times in football and two of the three ended regulation with a tie score.
Why did I pick this game? After going down 17 points, the game seemed lost, but Auburn battled back, and won it with a wild finish in three overtimes. Most Auburn fans still talk about this game, even though there were no national or conference implications, because of how crazy the comeback and finish were. The after-midnight finish was also pretty unique.
The week after the game, a Syracuse journalist wrote an article titled "Go to Auburn, Be Changed Forever" about his trip to the plains and how it changed his perception of college football in Auburn and how it compares to football in upstate New York. If one game's atmosphere can leave that kind of impression on an outsider, then it definitely deserves to be in the top 30 games every played at Jordan-Hare.
Play of the Game: Cadillac's touchdown-scoring run in triple overtime.
Player of the Game: Obviously, this go to Cadillac. 202 rushing yards and two rushing TD's in overtime, including the game-winner, will get you "player of the game" honors any day.
I listened to this game in Jerusalem – eight hours ahead of Alabama time. Listening to it on-line made me late for breakfast, but I was way too happy to care!
This will be a good series, Blogle. Looking forward to your new entries. I have a hunch about the #1 game!!!
I no longer get chain emails but the link to that article from the Syracuse writer had to have been the most forwarded link of the early 2000s. Imagine if Facebook had been around back then!
I was at this game as a student! I remember it because I didn't get back to my apartment until like 1:30 in the morning. It seems like the game didn't even start until like 9pm and we had been partying all day by that point. It may have been the single longest day of football I can remember.
Is there any video footage for this game out there? I looked all over Youtube and could not find it.