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Andrew Kim and Larissa Neumann of Fenwick & West discuss some of the important transfer pricing developments and US transfer pricing cases from 2017.
The OECD continues its BEPS work through the issuance of several significant discussion drafts addressing hard-to-value intangibles, the attribution of profits to PEs and the application of the profit split method. In the US, the IRS has been aggressive in asserting large transfer pricing adjustments, but has been unsuccessful in defending these adjustments in court.
The OECD released the 'Implementation Guidance on Hard-to-Value Intangibles' discussion draft on May 23 2017. The final BEPS report on Actions 8-10 (Aligning Transfer Pricing Outcomes with Value Creation) mandated the development of guidance on the implementation of the approach to pricing hard-to-value intangibles (HTVI).
The HTVI approach is intended to allow tax administrators to use after-the-fact profit information as presumptive evidence about the appropriateness of the parties' transfer prices. The new rules deviate from the arm's-length standard, and a major concern is how tax administrators will apply these rules. The new approach to HTVIs is not consistent with how unrelated parties handle after-the-fact information. The discussion draft assumes independent enterprises are able to renegotiate agreements if major unforeseen developments occur. However, renegotiations and repricing contracts after-the-fact are not common between unrelated parties.
The OECD transfer pricing guidelines (TPG) state that ex post (after-the-fact) outcomes can provide information to tax administrators about the arm's-length nature of the ex ante (before the transaction) pricing arrangement and the existence of uncertainties at the time of the transaction. If there are differences between the ex ante projections and the ex post results that are not due to unforeseeable developments or events, the differences may give an indication that the pricing arrangement may not have adequately taken into account the relevant developments or events that might have been expected to affect the value of the intangible and the pricing arrangements adopted. Ex post evidence provides presumptive evidence as to the existence of uncertainties at the time of the transaction. This presumptive evidence is subject to rebuttal if it can be demonstrated that it does not affect the accurate determination of the arm's-length price.
The new discussion draft regarding HTVI implementation guidance is helpful in that it states that tax administrators are not to base transfer prices and valuations solely on the ex post income. While it is helpful that the new discussion draft emphasises the limitations on the use of ex post results, the concern is that tax administrators could take this new HTVI guidance and apply ex post outcomes more broadly than the TPGs intend.
The term 'HTVI' itself is not objective. The term 'HTVI' covers intangibles for which (i) no reliable comparables exist, and (ii) the projections of future profit, or the assumptions used in valuing the intangibles, are highly uncertain, making it difficult to predict the level of ultimate success of the intangible at the time of the transfer. Defining HTVI by using subjective terms like 'highly uncertain' and 'making it difficult' is problematic. What is considered an HTVI has been heavily debated and many definitional issues are still unresolved. In this regard, it would be helpful to have concrete guidance regarding when an intangible might be considered an HTVI. Even a short list of objective factors would be helpful.
Taxpayers can overcome the presumption of an HTVI ex post approach by preparing a robust valuation that considers various possibilities. Taxpayers can also overcome the presumption by demonstrating the variance was due to an unforeseen circumstance. It would be helpful if there were examples demonstrating how the taxpayer could overcome the presumption by proving either the original valuation property took into account the possibility or the development was unforeseeable.
The OECD issued a new discussion draft in July 2017 addressing the attribution of profits to permanent establishments (PE). The additional guidance was deemed necessary following significant proposed revisions to the PE rules under BEPS Action 7 (preventing the artificial avoidance of PE status). These revisions are expected to dramatically increase the number of PEs under those treaties that adopt the recommended changes.
The new discussion draft replaces a prior 2016 discussion draft, and provides high-level guidance for the attribution of profits to PEs in the circumstances addressed by BEPS Action 7. In particular, the new discussion draft addresses profit attribution to PEs resulting from the expansion of the dependent agent PE rules in Article 5(5) of the OECD Model Treaty, and the changes to the preparatory/auxiliary and anti-fragmentation rules in Article 5(4).
With respect to the changes to Article 5(5), the new discussion draft notes that once it is determined that a PE exists under Article 5(5), the rights and obligations resulting from the contracts to which that provision refers should be allocated to the PE. This does not necessarily mean that the entire profit resulting from the performance of these contracts should be attributed to the PE. The determination of the profits attributable to the PE are governed by the rules of Article 7. Under Article 7, the only profits attributable to the PE are those that it would have derived if it were a separate and independent enterprise performing the activities that the dependent agent performs on behalf of the non-resident enterprise. Per the discussion draft, this principle applies regardless of whether a tax administration adopts the authorised OECD approach contained in Article 7 of the 2010 version of the OECD Model Treaty.
The discussion draft notes that both Article 7 (PEs) and Article 9 (associated enterprises) will apply where the PE results from the activities of a related party, and that the functions performed by the related party can qualify both as a significant people function for the attribution of a specific risk to the PE under Article 7, and as risk control functions for the allocation of a risk under Article 9. In these situations, it is important to ensure that the risk to which those functions relate is not simultaneously allocated to the intermediary and attributed to the PE. Otherwise, double income could result. Although the discussion draft does not provide an ordering rule for the application of Article 7 and Article 9, the report states that the order in which Article 7 and Article 9 are applied should not impact the overall amount of profit over which a source country has taxing rights as a result of the activities of a related party on behalf of its associated non-resident enterprise in the source country.
The discussion draft notes that the net amount of profits attributable to a PE may be either positive, nil or negative (i.e., a loss). In particular, when the accurate delineation of the transaction in the case indicates that the intermediary is assuming the risks of the transaction of the non-resident enterprise, the profits attributable to the PE could be minimal or even zero. This is consistent with comments by US Treasury Department officials, who have stated that the identification of additional PEs under the changes to Article 5 should not be expected to result in significant additional profits being allocated to the PE where the nonresident entity and local affiliate have transacted on an arm's-length basis.
The new discussion draft includes several examples that are intended to be illustrative and provide a conceptual framework based on the principles discussed in the discussion draft. Specifically, the discussion draft includes examples that address PEs resulting from the revisions to Article 5(5) of the OECD Model Treaty for a commissionaire structure for the sale of goods, an online advertising sales structure, and a procurement structure. The discussion draft also provides an example of the attribution of profits to PEs arising from the new anti-fragmentation rule in Article 5(4).
Each of the examples illustrating the attribution of profits to PEs under Article 5(5) provide that the PE should be attributed ownership of the assets of the nonresident entity that are related to the functions performed by the PE, and the assumption of the risks related to such functions. This attribution of ownership and risks to the PE raises important legal questions concerning a tax administrator's authority to restructure the actual transaction between the nonresident entity and its local affiliate. Further, as noted above, it is questionable whether such attribution to the PE will be necessary in most cases if the underlying activities which are performed by the local affiliate are properly compensated for in accordance with Article 9 of the OECD Model Treaty.
The OECD intends to hold a public consultation on the new discussion draft in November 2017 at the OCED Conference Centre in Paris.
The OECD issued a new discussion draft to clarify rules applicable to the transactional profit-split method by identifying indicators for use in determining the most appropriate transfer pricing method and providing additional guidance on determining the profits to be split and how to split them. The new discussion draft addresses situations in which profit splits of anticipated profits or actual profits are appropriate.
Earlier profit-split discussion drafts left a lot to be desired. The initial draft seemed more like a discussion draft on the subject of formulary apportionment. The second version was an improvement but still had significant problems.
The transactional profit-split method seeks to establish arm's-length outcomes by determining the division of profits that independent enterprises would have expected to realise from engaging in a comparable transaction. The method first identifies the profits to be split and then splits them on an economically valid basis that approximates the division of profits that would have been agreed to at arm's length.
The draft report states that the profit-split method can offer a solution for cases where both parties to a transaction make unique and valuable contributions to the transaction. According to the report, since those contributions are unique and valuable, there will be no reliable comparable information that could be used to price the entirety of the transaction in a more reliable way.
The transactional profit-split method can also provide a solution for highly integrated operations in cases for which a one-sided method would not be appropriate.
A weakness of the profit-split method relates to the difficulties in its application. Initially, the transactional profit-split method may appear readily accessible by both taxpayers and tax administrators because it tends to rely less on information about independent enterprises. However, associated enterprises and tax administrators alike may have difficulty accessing information from foreign affiliates. In addition, it may be difficult to measure the relevant revenue and costs for all the associated enterprises which could require stating books and records on a common basis and making adjustments in accounting practices and currencies.
Further, when a transactional profit-split method is applied to operating profit, it may be difficult to identify the appropriate operating expenses associated with the transactions and to allocate costs between the transactions and associated enterprises' other activities. Identifying the appropriate profit-splitting factors can also be challenging.
These weaknesses can present serious problems regarding the reliability of profit-split results.
The discussion draft states that it is sometimes argued that a transactional profit-split method is rarely used among independent enterprises (this is true; otherwise the result likely would be a partnership), and that its application in controlled transactions should similarly be rare.
In general, the presence of factors indicating that a transactional profit-split is the most appropriate method will correspond to an absence of factors indicating that an alternative method of pricing – one that relies entirely on comparables – is the most appropriate method.
One of the most significant and immediate impacts from the OECD's BEPS work is the new transfer pricing reporting that is required for large multinational enterprises under the three-tier reporting system set forth in the BEPS Action 13 report. Many countries were quick to adopt the country-by-country reporting (CbCR) requirement under Action 13, which requires large multinational enterprises to report on an annual basis the aggregate tax jurisdiction-wide information relating to the global allocation of income, taxes paid, and certain indicators of the location of economic activity among the tax jurisdictions in which the multinational group operates.
CbCR information is generally to be filed by the parent entity of a multinational group, and then exchanged among the relevant jurisdictions in which a multination group operates. As of June 22 2017, 64 countries have signed on to the OECD's Multilateral Competent Authority Agreement providing for the automatic exchange of CbCR. The US is a notable exception, having chosen to exchange the reports filed by US parent entities with the US's treaty and information exchange partners via bilateral competent authority and information exchange agreements.
As multinational groups expend significant time and resources to comply with the CbCR rules, important questions and concerns remain regarding the confidentiality and limitations on use of information contained in CbCR. Under Action 13, CbCR is intended to assist taxing authorities in the performance of high-level transfer pricing risk identification and assessment, and not used as a substitute for an appropriate transfer pricing determination based on a detailed and thorough review. However, most observers expect that CbCR will lead to additional transfer pricing audits and controversies based on the information contained in the reports. Another significant concern is the protection of information contained in CbC reports from improper disclosure. Although the confidentiality of CbCR was expressly incorporated in the Action 13 documents and was part of the negotiations between stakeholders, there continues to be a significant push for the public disclosure of CbC information, particularly within the EU. The potential public reporting of CbC information raises significant concerns for taxpayers, and also threatens the information exchange mechanisms. For example, the US has explicitly stated that it will not share CbC information with another jurisdiction unless that jurisdiction properly ensures the confidentiality and restrictions on use of the CbC information.
The Tax Court ruled that the IRS abused its discretion by canceling two advance pricing agreements (APAs) that Eaton and the IRS entered into to establish a transfer pricing methodology for covered transactions between Eaton and its subsidiaries. Eaton Corp. v. Commissioner, T.C. Memo 2017-147. In an earlier 2013 summary judgment decision, the Tax Court initially ruled for the IRS and rejected Eaton's argument that the APAs were enforceable contracts. Eaton Corp. v. Commissioner, 140 T.C. No. 18 (2013).
The IRS had cancelled the APAs retroactively, claiming that Eaton did not comply in good faith with the terms and conditions of the two APAs and failed to satisfy the APA annual reporting requirements. The two APAs involved the sale of products from manufacturing operations in Puerto Rico and the Dominican Republic to the US.
The Tax Court held that the cancellation of an APA is a rare occurrence and should be done only when there are valid reasons. A misrepresentation must be false or misleading, usually with the intent to deceive, and relate to the terms of the APA. The Tax Court stated that a different viewpoint is not the same as a misrepresentation and is not grounds for terminating an APA. The Tax Court stated that the negotiation process for these APAs was long and thorough and either party could have walked away at any time.
The Tax Court held that based on all the evidence presented, no additional material facts, mistakes of material facts, or misrepresentations existed that would have resulted in a significantly different APA or no APA at all. The IRS had enough material to decide not to agree to the APAs or to reject Eaton's proposed transfer pricing method and suggest another APA at the time the APAs were negotiated. The Tax Court concluded that it was an abuse of discretion for the IRS to cancel the APAs.
The Eaton case bears some similarities to Medtronic and Eli Lilly v. Commissioner, 856 F.3d 855 (7th Cir. 1988), in that each of these cases involved § 482, a prior transfer pricing agreement between the taxpayer and the IRS, and the IRS going against the prior agreement and asserting large tax deficiencies. All three cases were lost by the IRS. In all three cases, the courts effectively adjusted the transfer pricing to conform to the IRS and taxpayer's previous agreement, with minor changes.
The Tax Court decision in Amazon.com Inc. v. Commissioner, 148 T.C. No. 8 (2017), is another transfer pricing taxpayer victory. Judge Lauber rejected the IRS's attempt to relitigate the same cost sharing transfer pricing issues the IRS lost on in Veritas Software Corp. v. Commissioner, 133 T.C. 297 (2009).
The IRS claimed that Amazon undervalued the buy-in intangibles contributed to Amazon's Luxembourg subsidiary by more than $3 billion when Amazon entered into a cost share arrangement (CSA) with the Luxembourg subsidiary.
The Tax Court stated that by definition, compensation for subsequently developed intangible property is not covered by the buy-in payment. Rather, it is covered by future cost sharing payments, whereby each participant pays its ratable share of ongoing intangible development costs (IDCs). The Tax Court held that the foreign subsidiary, by making cost sharing payments, became a genuine co-owner of the subsequently developed intangibles that the IDCs financed.
The Tax Court stated that the useful life of the trademarks, brand names, and other marketing intangibles in Veritas was determined to be seven years. It is unreasonable, the Tax Court concluded, to determine the buy-in payment by assuming that a third party, acting at arm's length, would pay royalties in perpetuity for the use of short-lived assets.
The Tax Court held that an enterprise valuation of a business includes many items of value that are not intangibles. These include workforce in place, going concern value, goodwill, growth options and corporate resources or opportunities. The Tax Court stated these items cannot be bought and sold independently; they are an inseparable component of an enterprise's residual business value. These items often do not have substantial value independent of the services of any individual and do not derive their value from their intellectual content or other intangible properties. Thus, the Tax Court stated that as concluded in Veritas, there was no explicit authorisation in the cost sharing regulations for the inclusion of workforce in place, goodwill, or going-concern value in determining the buy-in payment for pre-existing intangibles.
The Tax Court held that because the going-forward value of the marketing intangibles would increasingly be attributable to marketing investments by the foreign subsidiary, an unrelated party in its position would not agree to pay royalties forever. A trademark is, at any specific moment, the product of investments of the past. Future investments can replace those made in the past, and therefore the value of a trademark built by investments of the past will diminish. If consumers were dissatisfied with their shopping experience, Amazon's marketing intangibles would rapidly decline in value. The Tax Court found that the marketing intangibles had a useful life of 20 years.
The Tax Court also found unpersuasive the IRS contention that Amazon US was the true equitable owner of any marketing intangibles legally owned by the European subsidiaries. Because of differing cultural preferences, retail traditions, and national regulations, the details of these operations often varied from country to country. Local teams were thus integral to Amazon's success in Europe. The Tax Court held that the European subsidiaries were not mere agents of Amazon US.


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It is a lovely scene, the building, roofs and trees are so colorful. Great shot.
what a pretty spot! It seems like it has a lot of character, lovely photo!
Superb.. love the tree's in the backgroundWish you and your family a Merry Christmas
Definitely very scenic. Those buildings among the greenery over the lake is very beautiful.
Hello, thank you for visiting my blog. I appreciate your comments and suggestions. I will try to visit your blog too. If you like my blog I hope you follow meHave a nice day, Vicky

domain: artistic


If you are looking to repair your coolant overflow tank in your 1997-04 3.8L Mustang, Latemodel Restoration Supply had your fix! This is a direct replacement OE Ford plastic overflow tank for your 1997-04 3.8L Mustang V6. It will bolt up to existing factory mount points on your fan shroud and requires no other modifications.
Note: This tank accepts the factory coolant overflow sensor and cap.
Ford Motor Company Genuine Parts, Motorcraft® Parts and Ford and Motorcraft Remanufactured Parts are all excellent choices when it comes to performance, longevity and value for your Mustang or SVT Lightning. And they’re all backed by a Ford Motor Company limited parts warranty*, so you know their parts you use are going to perform like they should. Put the same parts on your Lighting & Mustang that came from the factory!


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Bioactive Materials is an international, peer-reviewed research publication covering all aspects of bioactive materials. The journal welcomes the submission of research papers, reviews and rapid communications that are concerned with the science and engineering of next-generation biomaterials that come into contact with cells, tissues or organs across all living species. Bioactive materials will feature adaptiveness to the biological environment, being designed to stimulate and/or direct appropriate cellular and tissue responses, or control interactions with microbiological species.
The journal publishes research on the entire range of bioactive materials that have been specifically and functionally engineered or designed in term of either their physical form (e.g. particulate, fibre, etc.), topology (e.g. porosity, surface roughness, etc.) or dimensions (i.e. macro to nano-scales). The journal invites contributions from the following categories of bioactive materials : (i) bioactive metals and alloys, (ii) bioactive inorganics: ceramics, glasses and carbon-based materials, (iii) bioactive polymers and gels, (iv) bioactive materials sourced from nature and (v) bioactive composites, for use in human or veterinary medicine as implants, tissue engineering scaffolds, cell/drug/gene carriers, imaging and sensing devices.

domain: chemistry


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The Perfect Gift by Joe Cosentino
What a wonderful holiday story to follow up the first book about these two men.
Both men, so unsure about each other had finally settled down to a normal, everyday life but after a year, things didn't seem to be as perfect anymore.
Their quiet wedding plans had been hijacked and they were feeling anything but sure about what they wanted to do....
I can't begin to imagine what being in such a demanding family must feel like but for them it's almost a push too far.
When they encounter a young boy, seemingly unloved and alone, they know exactly how they want their lives to be moving forward and we join them on their way as they reclaim what's theirs.
Fabulous, festive and full of feelings. Joe Cosentino evokes every emotion yet again in this beautiful little book.
4.5 out of 5 stars.

domain: library


The grace period for drivers caught on camera running a red light in Cedar Rapids ended Sunday, and they will now be looking at a fine of up to $100. Cedar Rapids police spokesperson, Cristy Hamblin says they been sending out warnings to drivers for the last 30 days to prepare drivers.
Hamblin says there are three set cameras and they’ve had 203 cases where pictures were submitted and the department rejected 12 of them. Hamblin says the cameras are designed to increase the safety at certain intersections where there have been right-angle crashes. She says they’ve gotten a lot of response since the cameras went up.
“It’s been really mixed,” Hamblin says. She they’ve received quite a few people who think it’s a good thing as they’ve had a lot of near misses because people aren’t paying attention. And she says there have been people who say it’s another case of “Big Brother” watching over them. Hamblin says they’ve had a lot of “very good questions” about the cameras. Hamblin says those who get caught on camera running a red light can appeal.
Hamblin says they will be able to view the violation and then decide if they want to pay the ticket or appeal. Hamblin says they have seven more cameras that will be going up. The cameras are expected to bring in around $750,000. Red light cameras are also in use in Sioux City, Council Bluffs, Clive and Davenport.
Here’s a city informational brochure on the red light cameras: Cedar Rapids red light brochure


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Ecologist Lizzy Lowe was studying how animals have adapted to the city life. While carrying out her research, she noticed a difference that spiders at Tamarama Beach are fatter and more fertile than the ones living in rural areas.
Lowe, from the University of Sydney, believes that golden orb weaving spiders love living near the coast. Suburb's condition also mattered for the health of the golden orbs. Lowe noticed that wealthier and more urbanized suburbs would have fatter and more fertile golden orbs in the nearby garden.

domain: news


How do I pay the application?
Having initial assessment of your information and document, our company will sign an entrustment agreement with the applicant. Upon the agreement is signed, applicant is required to pay the deposit. Around 6 months later, the Immigration Department will send a notification letter for collection of HK Identity Card. Within 3 working days after the notification issued, applicant is required to pay the outstanding consultant fee. Then our staff will accompany applicant to the designated office of the Immigration Department for collection of the HK Identity Card.


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The full moon thru the clouds from our back deck.
Husband and wife photographers specializing in Georgia nature and places of interest. We have transitioned from film and wet darkroom to exclusively digital. We still do Alternative process in our darkroom- Kallitype , Van Dyke Brown and Salt Printing on a small scale.
This work is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.
Please feel free to view and enjoy the images on this site.
Please be aware that all images are the property of Marks and Joey Culver and are, therefore, copyrighted.
Please do not copy, steal or use any images or text without our permission.
If you wish to use an image, please contact us and terms and cost (if any) can be discussed. Thank you


Turkey's president has defended the controversial construction of a grandiose new presidential palace, saying his old office was infested with cockroaches.
- Is Turkey on the path toward Putinization?
- Erdogan dares critics: Find my 'golden toilet' and I'll resign
- Erdogan to sue opposition for claiming he has a golden toilet
- Will Turkey's Kurdish voters block Erdogan's big plans?
Recep Tayyip Erdogan has been accused of squandering state resources when he was prime minister by building the 1,150-room palace, which critics say was illegally built on protected land. In the run-up to Sunday's parliamentary elections, opposition parties have criticized the expenditure.
Erdogan moved into the vast structure after he was elected president in August. The former presidential palace was given to the prime minister.
In a television interview late Friday, Erdogan said cockroaches had roamed the lavatories in the now-vacated prime ministry.
He said: "Does such an office suit the prime minister of the Republic of Turkey? There can be no question of waste where representation is concerned."


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This year marks the 225th anniversary of the adoption of the Bill of Rights, the first ten amendments to the U.S. Constitution. This year it is especially important that Americans know and recommit themselves to the principles of the Bill of Rights because we face the inauguration of a President who threatens to undermine many of the rights we cherish. His statements during and after the campaign have shown a disregard for rights that have been the underpinning of our democracy for more than 200 years.
The Bill of Rights guarantees freedoms that apply to all Americans – regardless of who is in the White House. The ACLU has fought to protect the Bill of Rights for nearly a hundred years. We remain fired up to defend freedom.
President Franklin D. Roosevelt designated December 15 as Bill of Rights Day in 1941. To celebrate our freedoms, the ACLU of Washington on Dec. 15 is distributing wallet cards with the Bill of Rights – in plain language – at Seattle’s Westlake Park from 11:00 am-3:00 pm. The first 100 visitors to our table there will receive free ACLU-WA “Fired Up For Freedom” T-shirts. We’ll also have “No One Trumps the Constitution” bumper stickers and buttons, know your rights information, and sign-ups for our E-Activist Network.
Cupcake Royale is helping celebrate Bill of Rights Day by offering free cupcakes to the first 20 people to join the ACLU at each of its six locations around Seattle. Cupcake Royale will donate a portion of its Thursday’s proceeds to the ACLU-WA.
Our December 15 actions are part the ACLU-WA’s Fired Up For Freedom campaign that responds to the election of Donald Trump. As a presidential candidate, he promised to take actions once in office that in many cases would be unlawful or unconstitutional. These included promises to amass a deportation force to conduct mass removals of undocumented immigrants; ban the entry of Muslims to our country and aggressively surveil them; punish women who choose to have abortions; reauthorize waterboarding and other forms of torture; and erode protections for freedom of the press and freedom of expression.
The ACLU has made clear that if President Trump moves to implement any of these proposals, we will see him in court.
In Washington state, the ACLU is working on a broad range of issues, including major efforts to end mass incarceration, ensure police accountability, curb the school-to prison pipeline, safeguard voting rights, oppose the use of religion to discriminate, and preserve LGBT rights. In addition, in light of the 2016 elections, we are increasingly vigilant to take action in several areas:
Free Speech & Protest
- Oppose any efforts to crack down on peaceful protest and hold police accountable if they violate the rights to free speech and assembly.
- Resist a proposed a new state law that treats civil disobedience as “economic terrorism.”
- Provide workshops on Free Speech & Protest Rights to groups across the state.
- Urge cities to follow lead of Bellevue, Olympia, and Seattle, where local officials are protecting their communities, not doing the bidding of the federal immigration police.
Student Harassment and Bullying
- Ensure that public school officials respond swiftly and forcefully to any incident of harassment or bullying of Muslim, immigrant, female, or students of color.
- Hold accountable the Spokane psychologists who designed torture programs for the government.
- Make sure that people are not subjected to government surveillance based on their political or religious views.
- Ensure that government acquisitions of new surveillance technology occur only with public debate and safeguards for privacy rights.
- Oppose bills in the state legislature that would undermine abortion rights.
- Ensure that public health districts provide abortions in their local community, as the WA Reproductive Privacy Act requires.
The Bill of Rights lays out important limits to government power, protecting the rights to free speech and assembly, freedom of religion, freedom from unreasonable searches and seizures, the right to a fair trial, and more. Let’s keep in mind that it was written by James Madison after several states called for greater protection for individual liberties to be included in the Constitution. Its guarantees of freedom are as important today as ever.

domain: sociology


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Air Freight Keeping Airlines Afloat
The International Air Transport Association’s (IATA) data for global air freight shows that demand for air cargo decreased by 10.6 per cent in 2020 compared to 2019 – the largest drop in year-on-year demand since IATA started monitoring it in 1990. This figure outpaces the 6 per cent drop in the global goods trade.
In South Africa, average international air freight cargo handled at OR Tambo International Airport in February 2021 was 806 136kg per day, compared to 854 139kg per day in February 2020, according to Business Unity South Africa statistics. That volume was down to about 300 000kg a day in April 2020 and only recovered to above 800 000kg daily in the last week of January 2021.
Pier Luigi Vigada, director Eastern and Southern Africa at Air France KLM Martinair Cargo, says that despite some positive results, the air freight industry was as affected as passenger services, and had to reinvent itself to ensure it could continue delivering to customers. “We had to face challenges at all levels, like customers not having enough staff to deliver to our warehouses, where we had to ensure working staff and environment were safe to operate and handle goods. Testing, disinfecting, sterilisation of goods and crew regulations were just some hurdles that soon became the norm for us.”
After lockdown in March 2020, Air France and KLM continued operating by deploying passenger aircraft for cargo-only flights and offering repatriation flights to Europe, along with their five-times-weekly Martinair Cargo flights. “The extra capacity deployed by the airlines came at an extra cost. Operating passenger planes to carry only cargo is a pricey operation if not supported by passenger revenues and is mostly deployed to sustain the industry where margins are very tight,” says Vigada.
Capacity and costs
CFR Freight air freight director Stephen Bishop says that getting cargo in and out of South Africa became a huge challenge because the bulk of the country’s cargo is carried in the holds of passenger aircraft. When carriers stopped operating passenger flights under lockdown conditions, capacity dried up rapidly. “Ethiopian Airlines helped keep the country and the continent running, operating as our major connection to the rest of the world, particularly the Far East. While the cargo industry was deemed an essential service under lockdown, there were challenges with ground handling companies operating on skeleton staff and a myriad new COVID-19 protocols”.
According to Vigada, air freight costs fluctuate alongside all other costs in relation to the supply-demand ratio. “Freight into South Africa comes from all over the globe, and pricing depends on where the cargo originates from and how constrained the capacity is on that leg – and, ultimately, on the capacity on the final leg. The demand for capacity has been massive all over the world; both capacity and volumes are currently lower than they were back in 2019.”
Bishop says that in Q2 of 2020, they saw inbound freight pricing increase five-fold, particularly from the East. “It was simple supply and demand economics – and prices remain two to three times higher now than they were before lockdown last year.”


Morris Lubricants has released a series of short videos documenting the first serious road tour and pull by a classic 20th century steam engine built from scratch by Cumbrian engineer Alex Sharphouse.
The lubricants industry must be seen as part of the solution and not part of the problem as the world evolves to a greener, more sustainable future.
The Rail and Heritage Account Manager for one of the UK’s leading independent lubricants companies, who died last year, is to be remembered for posterity at North Norfolk Railway (NNR) where he volunteered.
The engineering manager on the Flying Scotsman restoration project at the National Railway Museum has been recruited by leading independent lubricant, oil and grease company Morris Lubricants.
Simon Holroyd, from Halifax, who has helped to restore a series of famous locomotives, has taken up a sales role as Heritage Account Manager with the Shrewsbury-based firm.


Police Officer Susan Farrell and Police Officer Carlos Puente-Morales were killed when their patrol car was struck head-on by a wrong way driver on I-80, at mile marker 117.
They were transporting a prisoner from Council Bluffs back to Des Moines when the crash occurred. Both officers, the prisoner, and the driver of the wrong way vehicle were killed.
Officer Farrell had served with the Des Moines Police Department for only five months and had previously served with the Polk County Sheriff’s Office for several years.
Read more: http://www.odmp.org/officer/22822-police-officer-susan-farrell#ixzz44CctdMpk
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Just sawthis press release
from the Dallas Police Department that contains relatively few details about something called Operation Car Wash, which DPD says has resulted in 27 arrests since warrants were first issued back on September 9. The release catalogs the drugs also seized, and DPD spokesman Kevin Janse tells Unfair Park that "more arrests and seizures are possible."
Reason I called Janse is because the main address listed on the release sounded awfully familiar: 2702 Martin Luther King Jr. Blvd. Yup -- sure enough, that's the car wash owned by one Dale Davenport, about whom Schutze wrote back in 2005, when Davenport and the DPD were at odds over who was to blame for the crime at his car wash. The release says Davenport's now a DPD partner: "The owner of this car wash is now cooperating with the Police Department by participating in the Criminal Trespass Affidavit Program [which] allows officers to give Criminal Trespass Warnings to individuals on the property who are not conducting car wash business and follow up with arrests if these individuals return to the property."
That's right, Davenport says: "And I applaud their actions," he tells Unfair Park. "They try to hit the car wash five times each shift, so if there are undesirables hanging around, they will issue criminal trespass citations, and I don't have a problem with that." Still, it's not all bubbles and rinse: "Why don't they do something about the crack houses on Peabody, Pennsylvania and Myrtle?" To which Janse responds: "How does he know we're not?"
Keep the Dallas Observer Free... Since we started the Dallas Observer, it has been defined as the free, independent voice of Dallas, and we would like to keep it that way. Offering our readers free access to incisive coverage of local news, food and culture. Producing stories on everything from political scandals to the hottest new bands, with gutsy reporting, stylish writing, and staffers who've won everything from the Society of Professional Journalists' Sigma Delta Chi feature-writing award to the Casey Medal for Meritorious Journalism. But with local journalism's existence under siege and advertising revenue setbacks having a larger impact, it is important now more than ever for us to rally support behind funding our local journalism. You can help by participating in our "I Support" membership program, allowing us to keep covering Dallas with no paywalls.


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I wa overly optimistic when I thought I’d finish these blocks before my trip tomorrow. I have 25 done and the stripsets are made for the last 10 blocks but they’ll have to wait until I get home next week after my visit to Mom.
I’m using the fabric I have here and don’t have access to my stash so I’m not sure about those lighter blue blocks. If I was in GA, I’d probably stick to darker blues but since I’m not, I’m debating whether to line those light ones up in a row like I have them here or to scatter them. There are two more blocks that use the lighter blue so I’ll make them them first and decide when I have all the blocks up there.
It feels so good to be making spending time with my knitting and quilting and making progress.


Mr Dean Joneswarden@lundyisland.co.uk
Iam the full time warden on Lundy, a small but ecologically important island located of the North coast of Devon in the Bristol Channel. Every year as part of the island High level stewardship scheme, the productivity of the islands seabirds are studied, firstly to see how the islands populations are recovering after the eradication of rats from the isle in 2006, and secondly to see how these values compare between years. Full island seabird census studies are carried out by the RSPB as well as burrow occupancy studies of Manx shearwater by tape play back calls. Storm petrel (a very recent coloniser to the isle) studies will hopefully commence this year now that a breeding colony has been located.


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Samsung has changed its build quality drastically in the last year. The use of metal and glass has taken a prominent place in the design. And, the plastic covered Samsung phones we loathed, are slowly disappearing. Currently only the flagship phones stay true to this new design philosophy. But, besides the flagship Galaxy S6 and new Note phones, Samsung has a A-series which offers an almost similar design approach. From this line-up we have the Galaxy A8 with us today. So, we thought, why not take you through it.
Before we begin, here is a quick spec rundown.
SoC: Exynos 5420
Display: 5.7-inch 1080p
Camera: 16MP and 5MP
OS: Android 5.1
The 5.7-inch 1080p display on the front uses a Super AMOLED panel that has very good viewing angles. Also, the bezels on the side are quite thin.
At the top of the phone, there is an array of sensors and the 5MP front-facing camera.
At the bottom we have the 'Home' button that also doubles up as a fingerprint-sensor. You can also see the micro-USB as well as the 3.5mm jack situated the bottom.
The phone has two separate buttons for volume controls at the left side. The power button is on the right side
The phone supports dual SIM, and you can swap the second SIM with a 128GB microSD card if you require more storage over the 32GB inbuilt storage.
There is a 16MP camera at the back that is coupled with a single LED flash. The speaker is located here as well.
The phone features a non-removable back and a 3050mAh battery and weighs around 151 grams.


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The Paws Ahoy! Collection – Custom Branded Nautical Yacht Wear + Products for Your Pet
From the Tradewinds to the Tailwinds
Have your pet aboard proudly cruising in style! There is no better way to showcase your pet’s yachting loyalty and capture the flair of living a life upon the tropical seas with our exclusive Paws Ahoy! Collection. We can create a line of personal pet care products and pet clothing for your yacht. We can custom brand dog sweaters, t-shirts, polos, feeding and water bowls, towels, placemats, personalized play date cards, pet’s own log book, and collars / leashes, or pet sized fresh flower leis. All can feature the name of your yacht whimsically displayed on each product (except fresh lei).
We also can custom create a custom boat flag for your yacht, yacht club, or marina. We can personalize with your pet’s name, breed, or simply welcome pets aboard by displaying our Paws Ahoy branded burgee.
We also can produce a creative custom branded line of tropical, nautical wear for yacht clubs, marinas, and the Island Chamber of Commerces.
So calling all pets on deck – there are now some great ways to get all “decked out”!
Please contact us for more ideas and creative yacht products exclusively branded for your pet and yacht or marine establishment. With the purchase of each product we will make a donation to an island animal shelter of your choosing on one of the Caribbean Islands.

domain: pet


Weld thru primer - Copper - Technical spray cans
Acrylate resin based copper anti-corrosion primer offers rust protection for SPOT, MIG & TIG welding applications. High concentration of copper in the dry film in a fast drying formulation to speed up the welding process with limited impact on the weld. Has excellent adhesive properties. The product can be used before and after welding.Visabella - Adhesive and Sealant Brand and ManufacturerVisbella is a global brand and manufacturer. With one of the largest adhesive and sealant manufacturing capability, it covers a wide range of applications including automotive, hardware, household, furniture, personal items, DIY, machinery, electronic appliances andTitan Capspray 105 5 Stage HVLP Turbine Paint Sprayer wste255 north korea spray paint WeldingLarger projects involving heavier-bodied coatings require the 5-stage power and long-term dependability of the CAPSPRAY 105, a solid but remarkably lightweight workhorse HVLP capable of atomizing thick latex or solvent-based paints, enamels or varnishes with
This Mans 1969 Mustang Restoration Is One For The Books wste255 north korea spray paint Welding
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MIAZ BROTHERS - THE PAST, PRESENT & IMPERCEPTIBLE |
Maddox Gallery is proud to present The Past, Present & Imperceptible, a solo exhibition of works by Italian duo, the Miaz Brothers.. Following residency this past year at Maddox Gallery in Shepherd Market, the Miaz Brothers return with a body of work that challenges perception more than ever before.Images of Wste255 North Korea Spray Paint Welding See allSee all imagesHurry up! Steel Nickel Alloy Weathervane.No Rust For 10 wste255 north korea spray paint WeldingMANUAL PROCESS - After manual welding by professional craftsmen, the surface is painted with spray paint and anti-rust handling, which is smooth and rust-free, and very durable. MATERIALS - Made of high quality stainless steel, and the weight is about 1.20-1.40lbs, UV-resistant, easy to assemble, durable to use, and long lasting.
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Scale, excess rubber, paint and carbon deposits from hard to reach areas. 4500 Max Rpm. Aeronca. Diamond Plated Jig Grinding Pin 0.500" X 0.260" X 1/4" Shank X 3" OAL 200/240Export Rules & Regulations | US SuperalloysMany specialty steel and specialty metals producers are concerned with materials and materials processing controls that are found in Categories 0, 1 (materials), and 2 (materials processing) of BISs Commerce Control List (CCL), which is part of the Export Administration Regulations (EAR). These categories identify products that are controlled for export, specify which controls apply, and help determine which shipments will require an export license. Certain nickel powder or porous nickel metalSee more on ussuperalloys wste255 north korea spray paint WeldingLast updated: Apr 29, 2014Custom Industrial Cyclone Dust Collectors from Imperial wste255 north korea spray paint WeldingIndustrial cyclone dust collectors are used alone or with other dust collectors in many applications. Imperial Systems cyclones feature many options that certainly make them the best choice for your unique challenges.
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Located in the heart of Philadelphia’s Chinatown, this restaurant serves excellent dim sum. There are no carts as the restaurant in a long narrow space, but the steamed and fried dumplings are made fresh and worth the wait. There are plenty of vegetarian choices and wonderful shrimp shu mai. The noodles with scallion sauce were extremely good. Nice friendly staff, who served the food the instant it was done and kept our water glasses filled. Highly recommended.
Own or manage this property? Claim your listing for free to respond to reviews, update your profile and much more.

domain: food


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Continue to watch for FREE ➞
It takes less then 1 minute to Sign Up,
then you can enjoy Unlimited Movies & TV Show
Elsa, Anna, Kristoff and Olaf head far into the forest to learn the truth about an ancient mystery of their kingdom.
Release: Nov 20, 2019
Country: United States of America
Duration: 103 minutes
Copyright © 2021 FMovies HDQ

domain: entertainment


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This paperwork of AED 204 Week 4 Assignment Debunking Gender Misconceptions consists of:
Resource: Appendix E Due Date: Day 7 [Individual] forum Consider that there are many gender misconceptions in education. For example, some people believe that boys are more suited for and more interested in math and science.
Think about other stereotypes that exist related to gender. How do these stereotypes and misconceptions impact education in the United States? What are your beliefs regarding ability differences between males and females in general and in education? What evidence can you present to validate your viewpoint? Also consider the existing laws that are meant to guarantee equal treatment in education for girls and boys.
For this assignment, address at least three of the following common misconceptions:
Boys are more suited for and more interested in math and science than girls are.
Boys who participate in the arts are more likely to be homosexual.
Girls are more interested in domestic arts than boys are.
Boys are more interested in auto shop and wood shop than girls are.
Boys are more competitive in sports and academics than girls are.
Check the Main forum to see which discussion cluster your instructor has assigned you to work with. In this cluster, you and your peers must discuss the impact of at least three of the above misconceptions on education. You must include information from your discussion cluster in your Microsoft


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Fan Guard Grills/Fan Cover
Fan Guard is also called fan cover.
Material and Technology: It is made of low-carbon steel wire or stainless steel wire through cutting,rolling,bending and welding.
Specification: according to the design and requirement of the customer's.
Characteristic: various mode,beautiful and practical, flat welding,corrosion resistance,durable service.
Used: the protection hood of blower,air condition,electric engine etc
Contact Person: Ms. April


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The Book of Prayers (Kitab Al-Salat)
Muslim :: Book 4 : Hadith 1803
Abu Huraira is reported to have said that the Messenger of Allah (may peace be upon him) prohibited to observe prayer after the 'Asr prayer till the sun is set, and after the dawn till the sun rises.
Source materials are from the University of Southern California MSA site|
Hadith eBooks converted from Imaan Star


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Werner Herzog – A Guide for the Perplexed
The award-winning director of Grizzly Man and Fiztcaraldo talks about his inspiring career in cinema.
19 in stock
We are temporarily only able to ship Faber Shop orders to addresses in the UK.
‘One of the best things published about cinema.’ Sight & Sound
Herzog was once hailed by Francois Truffaut as the most important director alive. Famous for his frequent collaborations with mercurial actor Klaus Kinski – including the epics Aguirre, the Wrath of God and Fitzcarraldo, and the terrifying Nosferatu – and more recently with documentaries such as Grizzly Man, Cave of Forgotten Dreams and Into the Abyss, Herzog has built a body of work that is one of the most vital in post-war German cinema. Here, he reflects on his legendary and inspiring career.
Magnificent . . . One of the most fascinating minds to where we are fortunate enough to have collective access . . . Indispensable.
The heftiest and most fascinating one-stop guide that the Herzog fan, or even newcomer, could possibly ask for.
One of the best things published about cinema . . . so expansive, detailed and thought-provoking that it feels like more than a book.
One of the best, the most inspirational and definitely the most unusual guides to filmmaking ever written . . . Just about anyone who wishes to follow an art or craft or trade or passion can learn from this book.
A blockbuster performance . . . an invaluable guide to a hard-fought life and career.
Extraordinary . . . So full of marvellous passages that one could go on quoting forever.
Browse a selection of books we think you might also like, with genre matches and a few wildcards thrown in.


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Jeff Huebner, vice president of treasury for CSAA Insurance Group, has been named chairman of the board of governors for the California Insurance Guarantee Association.
Huebner joined CSAA Insurance Group in 2001 as manager of risk finance and captive operations, and currently oversees an insurance and pension assets investment portfolio of $7 billion.
Established by the California Legislature in 1969, CIGA provides insurance for more than one hundred member companies. CIGA administers and pays covered claims for insolvent property/casualty carriers, using member company premiums and state-managed security deposits to settle outstanding claims.
CSAA, a AAA Insurer, offers automobile, homeowners and other personal lines of insurance to AAA members through partnerships with AAA clubs in 23 states and the District of Columbia.
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FLABAIRE, SHCAA, PALM HONEY - "HOT SIMIAN WEATHER (REMIXES)" - u(r)blue001
The first u(r)blue - a series of white label 12 inches venturing into electronic music. The record celebrates Palm Honey's tune 'Hot Simian Weather', the first track released on untitled, with two remixes by cutting edge producers Flabaire & Shcaa.
Flabaire's edit is a dancefloor-ready house remix capturing the raw energy of the tune.
Shcaa, in his distinctive style, blends guitar licks and his own vocals with a slo-mo electronic beat that will send you on a travel within the inner elements of the track.
A1. Flabaire (Remix)
B1. Shcaa (Remodel)
B2. Palm Honey (Original Mix)


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Open Position – Image Annotator and Reviewer
Horizon Surgical Systems Inc.
As an employee at Malibu-based Horizon Surgical Systems Inc., you will join a group revolutionizing the field of surgical ophthalmology and microsurgery. Your work will contribute to a paradigm shift focused on automating ophthalmological surgical procedures with robotic platforms. These systems supersede surgeons’ hand dexterity, integrate imaging modalities that outperform the human eye, and are supported by AI technology that automates the entire surgical procedure. In this role, you will support image labeling efforts by reviewing and annotating images as part of a complete product subjected to FDA regulations.
Horizon Surgical Systems Inc. offers:
- An opportunity to build features to be integrated into autonomous surgical robotic systems for the future of affordable, high-quality healthcare.
- The opportunity to work alongside clinicians, engineers, and global leaders in cutting-edge AI, imaging, and robotics technology.
- Competitive compensation and an excellent company-paid benefits package.
General Responsibilities include:
- Use computer programs to review labeled images and decide to reject/accept them
- Annotate anatomical structures on medical images after being trained by an expert
- Analyze data to provide statistics and observations
- Document the reviewing process and record observations to assist the team in improving the process
- Assist engineers in creating educational tutorials to explain good practices and provide examples of quality output
- Perform quality assurance duties regarding labeled images and frames from surgical videos
- Perform filtering and quality assurance on surgical videos to separate good/bad videos
Required Qualifications and Abilities:
- Good computer knowledge and skills
- Attention to detail and a commitment to producing quality work
- The ability to work independently in a self-motivated capacity
- College degree (university or technical school) or currently enrolled in college
- Strive for addressing challenging problems to improve the patient outcome
- Ability to work at a computer for several hours per day
- Ability to find patterns between complicated data and organize information to organize the workflow
- Basic knowledge of ophthalmology is a bonus
- Exceptional communication skills and documentation
- Be on site at least 90% of the work time at Malibu office
- Part-time position - Must work at least 20 hours per week
Company Profile: Horizon Surgical Systems, Inc.
Horizon Surgical Systems, Inc. is revolutionizing ophthalmology through the development of a novel, imaging-guided intraocular surgical robotic system. Automated by AI technology, Horizon Surgical Systems, Inc. aims to expand access to care, enhance patient outcomes, and provide superior capabilities to human surgeons.
Our core values are:
1. Commitment to Excellence: We aim to deliver superior patient outcomes and surgeon experiences
2. Passion for Creativity and Innovation: We are driven by new ideas and aim to push the boundaries of what's possible
3. Teamwork and Camaraderie: We achieve our best when we collaborate and work together
4. Welcoming of Critical Opinion: We are enriched by constructive criticism and support the best ideas
5. Personal Accountability: We honor our commitments and take responsibility for our actions
This is an exciting opportunity to join a high-tech startup that is poised to revolutionize surgical robotics in ophthalmology.
Job Type: Part-time
Pay: $30.00 per hour
- Dental insurance
- Flexible schedule
- Health insurance
- Paid time off
- Referral program
- Vision insurance
Supplemental pay types:
Ability to commute/relocate:
- Malibu, CA 90265: Reliably commute or planning to relocate before starting work (Required)
Work Location: Hybrid remote in Malibu, CA 90265

domain: medical


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Choosing the Best Interior Paint Finish for a Job: Building Moxie
The last time you painted a room, I can pretty much guarantee that you spent a lot of time and energy trying to decide on the color.Should it be something subtle like a tan or an off-white? Or more dynamic like red, green, or purple? And then … after you pick the basic color, which one of the 30 or so different shades fits best with what you want.
Now think about the paint finish. I’m betting that decision was made on the fly. Either you didn’t think about it at all, or your decision was made based on the offhand advice of the clerk at wherever you purchased your paint.
But your choice of finishes (aka sheen) is incredibly important. It will determine things like whether the color stands out or fades into the background, and if you have to repaint every time it gets too dirty and/or even if you can wash it.
Learning a little bit about each of the different kinds of paint finishes can help you make an informed decision when buying paint and can even help you avoid more work down the line.
-Matte or Flat – Got a few small cracks, bumps, or other unsightly features on your walls? Well, matte or flat might be the way to go. Because it doesn’t reflect light like glossier paints, it’s easier to hide imperfections. What’s the negative? It’s not known for washability. If you get scratches or other marks on your walls, you might be forced to cover them with more paint.
-Eggshell - A very slight step from matte finish, in both shine and washability, this finish tends to hold up better than matte but not hide imperfections as well. People sometimes use it when they want to give their room or furniture a more rustic quality. The name? Well, that comes from the fact that it has the textural appearance of an egg, of course.
-Satin – If eggshell doesn’t quite hold up as well as you’d like, the next step up in shine is a satin finish. Got a room that sees a lot of traffic and wear and tear like, say, your kid’s bedroom? The velvety smooth look of a satin finish can be cleaned repeatedly without harming the paint, but it’s not as shiny and reflective as other glossier paints.
-Semi-Gloss – Generally speaking, semi-gloss is the vanilla of finishes – and I don’t mean that in a bad way. Typically recommended for kitchens, bathrooms, doors, and trim, it gives off a great shine without overdoing it. Semi-gloss will also hold up to moisture (hence its use in the kitchen and bathroom) and can be easily wiped clean. The only thing you need to worry about is making sure the areas you’re going to use it on are smooth and well-prepared. If you leave imperfections, the shine of semi-gloss will only highlight them.
-Read More On BuildingMoxie! Tips For Choosing The Best Paint Finish

domain: design


NBA playoffs 2018: Predictions, picks for Celtics vs
NBA playoffs 2018: Celtics vs. Bucks The key player. Jaylen Brown has the athleticism, the smarts and the defensive instincts for stardom, but he has not established consistency on the offensive
The Bucks vs. Celtics ending is why we love NBA Playoff
Apr 22, 2018 · The Bucks led the Celtics by 20 points in the third quarter, but Boston scrapped its way back to making it a game late. It was a game that came down to …
Boston Celtics vs. Milwaukee Bucks: Celtics will guard
Boston Celtics vs. Milwaukee Bucks: The Celtics will guard Giannis Antetokounmpo with Al Horford and ‘everybody on our team,’ according to Brad Stevens.
Boston Celtics’ Jaylen Brown ‘loves the moment’ in Game 2
Boston Celtics wing Jaylen Brown ‘loves the moment’ in Game 2 vs. Milwaukee Bucks.
NBA News, Videos, Scores, Teams, Standings, Stats | FOX Sports
Find live NBA scores, NBA player & team news, NBA videos, rumors, stats, standings, team schedules & fantasy games on FOX Sports.
Providence Boston Celtics | News, Weather, Sports
Irving scores 28, Celtics beat Bucks 117-113 Irving scores 31, Celtics beat Pistons again 108-105 Celtics hand Pistons first loss of season, 109-89
Boston Celtics – Wikipedia
The Boston Celtics are an American professional basketball team based in Boston, Massachusetts.The Celtics compete in the National Basketball Association (NBA) as a member of the league’s Eastern Conference Atlantic Division.Founded in 1946 as one of the original eight NBA teams to survive the league’s first decade, the team is owned by Boston Basketball Partners LLC.
Southwest | FOX Sports
Get the latest regional sports teams, scores, stats, news, standings, rumors, and more from FOX Sports Southwest.
Toronto Raptors tickets at StubHub!
Toronto Raptors tickets – 100% guaranteed by FanProtect. Buy and sell Toronto Raptors tickets and other NBA basketball tickets at StubHub!


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worldpay merchant account
Is worldpay expensive compared to other merchant accounts? what is cheaper worldpay or authorize.net?
I am thinking of using worldpay.
We use Worldpay and we are very happy with them.
They offer an excellent service.
They are well known in the UK.
It looks like authorize.net will be cheaper (depending on the reseller you use).
Here is WorldPay's US rates:
Setup Fee (non refundable) US$399
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domain: economics


Followers of that account were also automatically added as followers to the newly created @POTUS account for the Trump administration.
The Biden team says the new plan is for @Transition46 to become @WhiteHouse. Followers of @JoeBiden and @WhiteHouse will be encouraged to follow the new account with a one-time front page notification, but will not be migrated over automatically.
Twitter has been working on the transition for the platform widely used by Mr Trump since the election results were finalised, and has indicated that as a private citizen Mr Trump may not have as much leeway in stretching the rules for newsworthy comments.
While not as widely followed as Mr Trump’s personal account, @POTUS has some 33 million followers and @WhiteHouse 26 million.
The transfer will affect other institutional accounts such as @VP, @FLOTUS, @PressSec, @Cabinet, and @LaCasaBlanca, according to Twitter.
Last month, Twitter indicated any special treatment that Mr Trump has enjoyed ends with his presidency.
“Twitter’s approach to world leaders, candidates and public officials is based on the principle that people should be able to choose to see what their leaders are saying with clear context,” the San Francisco company said.
“This policy framework applies to current world leaders and candidates for office, and not private citizens when they no longer hold these positions.”


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Brighten a bare wall in your home with the Bella Wall Mirror. Made from solid metal with a gold finish, this sunburst mirror is simple yet striking. Display it among pieces of contemporary decor for a fresh, chic look.
Manufactured ByStratton Home DecorSold ByHouzzSize/WeightW 20" / D 1" / H 20" / 6.16 lb.ColorGoldMaterialsMetal/Glass/MDFAssembly RequiredNoCategoryWall MirrorsStyleMidcenturyCollectionBursts
Stratton Wall Mirror - Midcentury - Wall Mirrors - by Stratton Home Decor 417201224575


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Dallas Mayor Eric Johnson on Friday reflected on the series of crises that defined his first year in office: an EF3 tornado, the COVID-19 pandemic, and civil unrest following the killing of George Floyd. The mayor addressed a virtual audience of Leadership Dallas members and alumni during the annual “LDAA Breakfast with the Mayor” event. Read our recap or watch the full interview below.
- On FEMA’s recent denial of the state appeal for disaster relief, Mayor Johnson said Dallas taxpayers will now have to cover tens of millions of dollars in repairs to public infrastructure damaged in the 2019 North Dallas tornadoes.
- Mayor Johnson pointed to his experience in Leadership Dallas, which gave him a knowledge of how things work behind the scenes, and inspired him to serve the community, both as a state legislator, and now as mayor.
- The mayor stressed the importance of an increase in equitable testing for COVID-19 throughout the city. The City of Dallas has worked closely with Dallas County to expand testing and COVID-19 contact tracing.

domain: politics


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Perth v Sydney FC wrap
Clint Wheeldon and Stan Lazaridis recap an entertaining draw between Perth and Sydney FC.
Source: ABC News | Duration: 3min 14sec
By Kerry Brewster
Australia's first community-owned clean energy generator and retailer is taking shape in Byron Bay.
By Monique Schafter
While music streaming websites have made the internet a music lover's paradise, musicians themselves are divided on the benefits.


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40 Pictures That Capture Lil' Kim's WILD Hollywood Evolution
The only thing more insane than 44-year-old rap legend Lil' Kim's talent may just be her gasp-worthy ensembles. From sexy to downright shocking, Lil' Kim never holds back when it comes to expressing herself on the red carpet, and some of her looks have even inspired other stars to get in touch with their wild sides. Though we may never know what hair colour, eye colour, or lip colour she'll be wearing, if Lil' Kim's more than 20 years of gracing the red carpet have proved anything, it's that her outfits will never disappoint. Read on to see the Original Queen Bee's style evolution over the years.

domain: celebrity


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Kittyville hat from Stitch N'Bitch. Minus the earflaps.Yarn is Mondial Artico knit on size 6 needle. 100% superwash merino wool. The hat is for my daughter's friend's 3rd birthday. I hope it fits her!
aww she is so cute and I love that hat...to cute!!!:blooby:
You did an incredible job Candice! It looks machine knit! Beautiful!
Simply beautiful. I love the lining on the inside as well. Great idea. I am sure the child receiving this gift is going to be thrilled. Great job!!!
How sweet and the lining just finishes it off nicely xx
That is just adorable - I'm sure she will be thrilled.
That's so cute! I'll bet she'll love it.
It looks wonderful. You did such a great job .
The hat is cute, the model cuter!
I'll need to make one of these for my GD after the new year.
That is adorable!


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So I also decided it would be fun to use it to make my next card and here it is. This is another of those rather simple cards that I really enjoy making and sharing during the holidays.
This card was very quick and easy. I started with a pre-cut white card base that is 4 1/4 x 5 1/2". I stamped the pine trees from the Nature's Wish stamp set (this is a great stamp set for masculine cards including father's day, birthdays, etc.) using the new Willow ink. I then stamped the sentiment onto a piece of white daisy cardstock that was 2 1/2 x 2 1/2" using Peackock ink (the sentiment is from the Very Merry stamp set). I mounted that onto a piece of peacock cardstock that measured 2 3/4 x 2 3/4". The strip on the left is 2 x 5 1/2" and from the City Sidewalks paper packet.
Below is a list of supplies I used to make this card. They can be purchased from my OBA at www.craftwithronnie.ctmh.com or by clicking the shopping cart at the top of this blog. As always, happy crafting!!!
Cardstock: White Daisy (1385), Peacock (X5776)
Paper Packet: City Sidewalks (X7213B)
Ink: Willow (Z2807) Peacock (Z2849)
Stamp Sets: Very Merry (D1694), Nature's Wish (D1703)


Phone: 1800 888 009Mobile: 0438 170 099
1 x 2.5 metres long.
Charges vehicle battery via cigar lighter.
1 x 5 metres long.
Constantly maintains the battery in optimum condition.
Soft felt pads to protect tire rims from scratches & knicks. Comes as a set of 4.
Fan, Fan Mounting, All 3 Filters, Socket and Fully Wired (one only).
Six filters in total (includes carbon filters).
For all current model Carcoon's, indoor and Outdoor including Drive-in


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One of the centre pieces of the exhibition is a Bronze Age sword which was found in a field near Lockerbie many years ago.
It was kept under a bed for 50 years before being handed in.
More top news
Kerrie brings you Saturday nights forecast
Dry, warm and sunny with sea breezes. Isolated heavy showers by evening and overnight, although many areas will escape
Inspectors have surveyed almost two thousand miles of roads across the region to identify the damage.

domain: history


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Star Ranch Fitness is the “All Inclusive” solution to achieving your fitness goals and keeping them for a LIFESTYLE!
If there is an element that plays a role in reaching your goal, it’s included in ALL of our Programs!
Our facility is solely based on one-on-one training to give you the best full attention in our comfortable private setting!
As some Elements may be configured differently for a successful transformation, our Meal Planning is included in long term Programs due to the significance it has in changing your body!!
Below you will discover the difference between the average “Trainer” and a Star Ranch Fitness Trainer! Below is a list of all the significant elements we provide, a description about each element and the significance it has in our Programs.
As you will find there is a lot involved to ensure success in reaching your fitness goals, if any elements are missing or not performed properly then you will have little to no results. (This is why many people fail when they try it on their own!) We specialize in perfect configuration in all the below elements to ensure your success!
All of these Elements are also ongoing and continually assessed to ensure the best configuration to be in line with your goals!
1. Evaluation: Complete Past, Present & Goal Assessment
2. Evaluation: Current Health/Ailment Evaluation
3. Evaluation: Body Composition Testing & Measuring Success
4. Nutrition: Meal Plan Design
5. Nutrition: Accountability & Counseling
6. Exercise: Strength Training
7. Exercise: Cardiovascular Training
8. Exercise: Accountability
9. Training: Motivational Support
10. Training: Expert Supervision & Safety
11. Training: Complete Exercise Training Logging
12. Lifestyle: Continuing the Journey
In order to achieve your goal we need to learn more about your past and how you’ve gotten to the condition you are in now. This will help us identify what patterns may need to be broken and what new patterns may need to be installed. Once we’ve identified these patterns we create strategies for you to break and install new patterns and habits.
Complete past and present assessments include evaluations about how you feel and have felt about yourself mentally and physically; past/present exercise habits (if any), past/present eating and drinking habits, past/present sleeping habits, past/present stress related problems, past/present energy level patterns, past/present mental changes and past/present physical changes. All of these factors will play a major role in the foundation of your physique development. Following our assessment process we can easily spot a poor habit to begin installing new habits for success towards your goal and a better quality of life!
Now that we know your past and present habits, we need to know were you want to be! You MUST have a clear vision; you can’t reach a goal if you don’t know what it is specifically! Goal setting has an odd connotation attached to it in our society because of the strange methods we’ve been exposed to. When you use our techniques to make a real decision of what you want and why you want it specifically, then you will have lasting drive and motivation to get there instead of only drive in the beginning. There are many things to think about achieving that will come with your physical goals such as life feelings, life experiences, confidence, relationship changes, your contribution to family and others, financial changes and your health to name a few! All these awesome changes are why we call this change a transformation! Because it’s not just a physical change, it’s a LIFE change! You are investing in your longevity! This specific type of method of focus will create an awesome foundation for your success.
In order to best understand how to condition your body we must first understand what it has been through! There could have been injuries in the past that we may need to be aware of so we can work around them. Any health problems or concerns should be presented to us so they do not get amplified or worse. We can work around most injuries; people without limbs have gone through this program effectively! In most cases Members doctors have taken them off medications and what once were ailments have been relieved!
Before any training begins, we will do a complete health evaluation focusing on your current status and any past injuries. Included in the evaluation we’ll need to know of any medications you are taking or have taken, any mental problems and any physical traumas or problems (especially treated by a physician). It is wise to consult your physician before beginning an exercise and nutrition routine to possibly get advice of what to avoid. Many physicians will review your history and remind you of an ailment and/or to be cautious in possible areas of the body or to avoid certain nutritional foods.
Remember building a smart strong foundation will help you later on!

domain: health