Ireland as a tax haven

The Republic of Ireland has been labelled as a tax haven or corporate tax haven by multiple financial reports, an assertion which the state rejects. Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates "" of 0% to 2.5% on global profits re-routed to Ireland via their tax treaty network. Ireland's "aggregate " for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit. Ireland's tax-free QIAIF & L–QIAIF regimes, and Section 110 SPVs, enable foreign investors to avoid Irish taxes on Irish assets, and can be combined with Irish BEPS tools to create confidential routes out of the Irish corporate tax system. As these structures are OECD–whitelisted, Ireland's laws and regulations allow the use of data protection and data privacy provisions, and opt-outs from filing of public accounts, to obscure their effects. There is arguable evidence that Ireland acts as a , fostering tax strategies.
Ireland is on all academic "tax haven lists", including the , and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.
Ireland's situation is attributed to arising from the historical U.S. "worldwide" corporate tax system, which has made U.S. multinationals the largest users of tax havens, and BEPS tools, in the world. The U.S. Tax Cuts and Jobs Act of 2017 ("TCJA"), and move to a hybrid "territorial" tax system, removed the need for some of these compromises. In 2018, IP–heavy S&P500 multinationals guided similar post-TCJA "effective" tax rates, whether they are legally based in the U.S. (e.g. Pfizer), or Ireland (e.g. Medtronic). While TCJA neutralised some Irish BEPS tools, it enhanced others (e.g. Apple's "CAIA"). A reliance on U.S. corporates (80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add), is a concern in Ireland.
Ireland's weakness in attracting corporates from "territorial" tax systems ("Table 1"), was apparent in its 2017–18 failure to attract financial services jobs due to Brexit. Ireland's diversification into full tax haven tools (e.g. QIAIF, L–QIAIF, and ICAV), has seen tax-law firms, and offshore magic circle firms, set up Irish offices to handle Brexit–driven tax restructuring. These tools made Ireland the world's 3rd largest Shadow Banking OFC, and 5th largest Conduit OFC.
Context.
Ireland has been associated with the term "tax haven" since the U.S. IRS produced a list on the 12 January 1981. Ireland has been a consistent feature on almost every non-governmental tax haven list from Hines in February 1994, to Zucman in June 2018 (and each one in-between). However, Ireland has never been considered a tax haven by either the OECD or the EU Commission. These two contrasting facts are used by various sides, to prove or disprove whether Ireland is a tax haven, and much of the detail in-between is discarded, some of which can explain the EU and OCED's position. Confusing scenarios have emerged, for example:
The next sections chronicle the detail regarding Ireland's label as a tax haven (most cited "Sources" and "Evidence"), and detail regarding the Irish State's official "Rebuttals" of the label (both technical and non-technical). The final section chronicles the academic research on the drivers of U.S., EU, and OCED, decision making regarding Ireland.
Labels.
Ireland has been labelled a tax haven, or a corporate tax haven (or Conduit OFC), by:
Ireland has also been labelled related terms to being a tax haven:
The term tax haven has been used by the Irish mainstream media and leading Irish commentators. Irish elected TDs have asked the question: "Is Ireland a tax haven?". A search of Dáil Éireann debates lists 871 references to the term. Some established Irish political parties accuse the Irish State of tax haven activities.
Evidence.
Global U.S. BEPS hub.
Ireland ranks in all non-political "tax haven lists" going back to the first lists in 1994, and features in all "proxy tests" for tax havens and "quantitative measures" of tax havens. The level of base erosion and profit shifting (BEPS) by U.S. multinationals in Ireland is so large, that in 2017 the Central Bank of Ireland abandoned GDP/GNP as a statistic to replace it with Modified gross national income (GNI*). Economists note that Ireland's distorted GDP is now distorting the EU's aggregate GDP, and has artificially inflated the trade-deficit between the EU and the US. (see "Table 1").
Ireland's IP–based BEPS tools use "intellectual property" ("IP") to "shift profits" from higher-tax locations, with whom Ireland has bilateral tax treaties, back to Ireland. Once in Ireland, these tools reduce Irish corporate taxes by re-routing to say Bermuda with the Double Irish BEPS tool (e.g. as Google and Facebook did), or to Malta with the Single Malt BEPS tool (e.g. as Microsoft and Allergan did), or by writing-off internally created virtual assets against Irish corporate tax with the Capital Allowances for Intangible Assets ("CAIA") BEPS tool (e.g. as Apple did post 2015). These BEPS tools give an Irish corporate "effective tax rate" (ETR) of 0–2.5%. They are the world's largest BEPS tools, and exceed the aggregate flows of the Caribbean tax system.
Ireland has received the most U.S. corporate tax inversions of any global jurisdiction, or tax haven, since the first U.S. tax inversion in 1983.
While IP–based BEPS tools are the majority of Irish BEPS flows, they were developed from Ireland's traditional expertise in inter-group contract manufacturing, or transfer pricing–based (TP) BEPS tools (e.g. capital allowance schemes, inter-group cross-border charging), which still provide material employment in Ireland (e.g. from U.S. life sciences firms). Some corporates like Apple maintain expensive Irish contract manufacturing TP–based BEPS operations (versus cheaper options in Asia, like Apple's Foxconn), to give "substance" to their larger Irish IP–based BEPS tools.
By refusing to implement the 2013 EU Accounting Directive (and invoking exemptions on reporting holding company structures until 2022), Ireland enables their TP and IP–based BEPS tools to structure as "unlimited liability companies" ("ULC") which do not have to file public accounts with the Irish CRO.
Ireland's Debt–based BEPS tools (e.g. the Section 110 SPV), have made Ireland the 3rd largest global Shadow Banking OFC, and have been used by Russian banks to circumvent sanctions. Irish Section 110 SPVs offer "orphaning" to protect the identity of the owner, and to shield the owner from Irish tax (the Section 110 SPV is an Irish company). They were used by U.S. distressed debt funds to avoid billions in Irish taxes, assisted by Irish tax-law firms using in-house Irish children's charities to complete the orphan structure, that enabled the U.S. distressed debt funds to export the gains on their Irish assets, free of any Irish taxes or duties, to Luxembourg and the Caribbean (see Section 110 abuse).
Unlike the TP and IP–based BEPS tools, Section 110 SPVs must file public accounts with the Irish CRO, which was how the above abuses were discovered in 2016–17. In February 2018 the Central Bank of Ireland upgraded the little-used L–QIAIF regime to give the same tax benefits as Section 110 SPVs but without having to file public accounts. In June 2018, the Central Bank reported that €55 billion of U.S.–owned distressed Irish assets, equivalent to 25% of Irish GNI*, moved out of Irish Section 110 SPVs and into L–QIAIFs.
Green Jersey BEPS tool.
Apple's Q1 2015 Irish restructure, post their €13 billion EU tax fine for 2004–2014, is one of the most advanced OECD-compliant BEPS tools in the world. It integrates Irish IP–based BEPS tools, and Jersey Debt–based BEPS tools, to materially amplify the tax sheltering effects, by a factor of circa 2. Apple Ireland bought circa $300 billion of a "virtual" IP–asset from Apple Jersey in Q1 2015 (see leprechaun economics). The Irish "capital allowances for intangible assets" ("CAIA") BEPS tool allows Apple Ireland to write-off this virtual IP–asset against future Irish corporation tax. The €26.220 billion jump in intangible capital allowances claimed in 2015, showed Apple Ireland is writing-off this IP–asset over a 10–year period. In addition, Apple Jersey gave Apple Ireland the $300 billion "virtual" loan to buy this virtual IP–asset from Apple Jersey. Thus, Apple Ireland can claim additional Irish corporation tax relief on this loan interest, which is circa $20 billion per annum (Apple Jersey pays no tax on the loan interest it receives from Apple Ireland). These tools, created entirely from virtual internal assets financed by virtual internal loans, give Apple circa €45 billion per annum in relief against Irish corporation tax. In June 2018 it was shown that Microsoft is preparing to copy this Apple scheme, known as "the Green Jersey".
As the IP is a virtual internal asset, it can be replenished with each technology (or life sciences) product cycle (e.g. new virtual IP assets created offshore and then bought by the Irish subsidiary, with internal virtual loans, for higher prices). The Green Jersey thus gives a perpetual BEPS tool, like the double Irish, but at a much greater scale than the double Irish, as the full BEPS effect is capitalised on day one.
Experts expect the U.S Tax Cuts and Jobs Act of 2017 ("TCJA") GILTI-regime to neutralise some Irish BEPS tools, including the single malt and the double Irish. Because Irish intangible capital allowances are accepted as U.S. GILTI deductions, the "Green Jersey" now enables U.S. multinationals to achieve net effective "U.S. corporate tax rates" of 0% to 2.5% via TCJA's participation relief. As Microsoft's main Irish BEPS tools are the single malt and the double Irish, in June 2018, Microsoft was preparing a "Green Jersey" Irish BEPS scheme. Irish experts, including Seamus Coffey, Chairman of the Irish Fiscal Advisory Council and author of the Irish State's 2017 "Review of Ireland's Corporation Tax Code", expects a boom in U.S. on-shoring of virtual internal IP assets to Ireland, via the Green Jersey BEPS tool (e.g. under the capital allowances for intangible assets scheme).
Domestic tax tools.
Ireland's Qualifying Investor Alternative Investment Fund ("QIAIF") regime is a range of five tax-free legal wrappers (ICAV, Investment Company, Unit Trust, Common Contractual Fund, Investment Limited Partnership). Four of the five wrappers do not file public accounts with the Irish CRO, and therefore offer tax confidentiality and tax secrecy. While they are regulated by the Central Bank of Ireland, like the Section 110 SPV, it has been shown many are effectively unregulated "brass plate" entities. The Central Bank has no mandate to investigate tax avoidance or tax evasion, and under the 1942 "Central Bank Secrecy Act", the Central Bank of Ireland cannot send the confidential information which QIAIFs must file with the Bank to the Irish Revenue.
QIAIFs have been used in tax avoidance on Irish assets, on circumventing international regulations, on avoiding tax laws in the EU and the U.S. QIAIFs can be combined with Irish corporate BEPS tools (e.g. the Orphaned Super–QIF), to create routes out of the Irish corporate tax system to Luxembourg, the main Sink OFC for Ireland. It is asserted that a material amount of assets in Irish QIAIFs, and the ICAV wrapper in particular, are Irish assets being shielded from Irish taxation. Offshore magic circle law firms (e.g. Walkers and Maples and Calder, who have set up offices in Ireland), market the Irish ICAV as a superior wrapper to the Cayman SPC (Maples and Calder claim to be a major architect of the ICAV), and there are explicit QIAIF rules to help with re-domiciling of Cayman/BVI funds into Irish ICAVs.
Captured state.
There is evidence Ireland meets the captured state criteria for tax havens. When the EU investigated Apple in Ireland in 2016 they found private tax rulings from the Irish Revenue giving Apple a tax rate of 0.005% on over EUR€110 billion of cumulative Irish profits from 2004 to 2014. When the Irish Finance Minister Michael Noonan was alerted by an Irish MEP in 2016 to a new Irish BEPS tool to replace the Double Irish (called the Single Malt), he was told to "put on the green jersey". When Apple executed the largest BEPS transaction in history in Q1 2015, the Central Statistics Office suppressed data to hide Apple's identity. Noonan changed the capital allowances for intangible assets scheme rules, the IP–based BEPS tool Apple used in Q1 2015, to reduce Apple's effective tax rate from 2.5% to 0%. When it was discovered in 2016 that U.S. distressed debt funds abused Section 110 SPVs to shield €80 billion in Irish loan balances from Irish taxes, the Irish State did not investigate or prosecute (see Section 110 abuse). In February 2018, the Central Bank of Ireland, who regulates Section 110 SPVs, upgraded the little used tax-free L-QIAIF regime, which has stronger privacy from public scrutiny. In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (or 25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs.
The June 2017 OECD Anti-BEPS MLI was signed by 70 jurisdictions. The corporate tax havens, including Ireland, opted out of the key Article 12.
Tax haven investigator Nicholas Shaxson documented how Ireland's captured state uses a complex and "siloed" network of Irish privacy and data protection laws to navigate around the fact that its tax tools are OECD–whitelisted, and therefore must be transparent to some State entity. For example, Irish tax-free QIAIFs (and L–QIAIFs) are regulated by the Central Bank of Ireland and must provide the Bank with details of their financials. However, the 1942 "Central Bank Secrecy Act" prevents the Central Bank from sending this data to the Revenue Commissioners. Similarly, the Central Statistics Office (Ireland) stated it had to restrict its public data release in 2016–17 to protect the Apple's identity during its 2015 BEPS action, because the 1993 "Central Statistics Act" prohibits use of economic data for revealing such activities. When the EU Commission fined Apple €13 billion for illegal State aid in 2016, there were no official records of any discussion of the tax deal given to Apple outside of the Irish Revenue Commissioners because such data is also protected. When Tim Cook stated in 2016 that Apple was the largest tax-payer in Ireland, the Irish Revenue Commissioners quoted Section 815A of the "1997 Tax Acts" that prevents them disclosing such information, even to members of Dáil Éireann, or the Irish Department of Finance (despite the fact that Apple is circa one-fifth of Ireland's GDP).
Commentators note the plausible deniability provided by Irish privacy and data protection laws, that enable the State to function as a tax haven while maintaining OECD compliance. They ensure the State entity regulating each tax tool are "siloed" from the Irish Revenue, and public scrutiny via FOI laws.
In February 2019, "The Guardian" reported on leaked Facebook internal reports revealing the influence Facebook had on the Irish State, to which Cambridge University academic John Naughton stated: "the leak was “explosive” in the way it revealed the “vassalage” of the Irish state to the big tech companies". In April 2019, "Politico" reported on concerns that Ireland was protecting Facebook and Google from the new EU GDPR regulations, stating: "Despite its vows to beef up its threadbare regulatory apparatus, Ireland has a long history of catering to the very companies it is supposed to oversee, having wooed top Silicon Valley firms to the Emerald Isle with promises of low taxes, open access to top officials, and help securing funds to build glittering new headquarters."
Rebuttals.
Effective tax rates.
The Irish State refutes tax haven labels as unfair criticism of its low, but legitimate, 12.5% Irish corporate tax rate, which it defends as being the "effective" tax rate ("ETR"). Independent studies show that Ireland's "aggregate" effective corporate tax rate is between 2.2% to 4.5% (depending on assumptions made). This lower "aggregate" effective tax rate is consistent with the "individual" effective tax rates of U.S. multinationals in Ireland (U.S.–controlled multinationals are 14 of Ireland's largest 20 companies, and Apple alone is over one-fifth of Irish GDP; see "low tax economy"), as well as the IP–based BEPS tools openly marketed by the main tax-law firms in the Irish International Financial Services Centre with ETRs of 0–2.5% (see "effective tax rate").
Two of the world's main , estimated Ireland's "effective corporate tax rate" to be 4%: James R. Hines Jr. in his 1994 Hines–Rice paper on tax havens, estimated Ireland's effective corporate rate was 4% (Appendix 4); Gabriel Zucman, 24 years later, in his June 2018 paper on corporate tax havens, also estimated Ireland's effective corporate tax to be 4% (Appendix 1).
The disconnect between the ETR of 12.5% claimed by the Irish State and its advisors, and the actual ETRs of 2.2–4.5% calculated by independent experts, is because the Irish tax code considers a high percentage of Irish income as not being subject to Irish taxation, due to various exclusions and deductions. The gap of 12.5% vs. 2.2–4.5% implies that well over two-thirds of corporate profits booked in Ireland are excluded from Irish corporate taxation (see Irish ETR).
The Irish State does not refer to QIAIFs (or L–QIAIFs), or Section 110 SPVs, which allow non-resident investors to hold Irish assets indefinitely without incurring Irish taxes, VAT or duties (e.g. permanent "base erosion" to the Irish exchequer as QIAIF units and SPV shares can be traded), and which can be combined with Irish BEPS tools to avoid all Irish corporate taxation (see ).
Salary taxes, VAT, and CGT for Irish residents are in line with rates of other EU–28 countries, and tend to be slightly higher than EU–28 averages in many cases. Because of this, Ireland has a special lower salary tax rate scheme, and other tax bonuses, for employees of foreign multinationals earning over €75,000 ("SARP").
The OECD's "Hierarchy of Taxes" pyramid (from the Department of Finance Tax Strategy Group's 2011 tax policy document) summarises Ireland's tax strategy.
OECD 1998 definition.
EU and U.S. studies that attempted to find a consensus on the definition of a tax haven, have concluded that there is no consensus (see tax haven definitions).
The Irish State, and its advisors, have refuted the tax haven label by invoking the 1998 OCED definition of a "tax haven" as the consensus definition:
Most Irish BEPS tools and QIAIFs are OECD–whitelisted (and can thus avail of Ireland's 70 bilateral tax treaties), and therefore while Ireland could meet the first OECD test, it fails the second and third OECD tests. The fourth OECD test (‡) was withdrawn by the OECD in 2002 on protest from the U.S., which indicates is a political dimension to the definition. In 2017, only one jurisdiction, Trinidad & Tobago, met the 1998 OECD definition of a tax haven (Trinidad & Tobago is not one of the 35 OECD member countries), and the definition has fallen into disrepute.
Tax haven academic James R. Hines Jr. notes that OECD tax haven lists never include the 35 OECD member countries (Ireland is a founding OECD member). The OECD definition was produced in 1998 as part of the OECD's investigation into "Harmful Tax Competition: An Emerging Global Issue". By 2000, when the OECD published their first list of 35 tax havens, it included no OECD member countries as they were now all considered to have engaged in the OECD's Global Forum on Transparency and Exchange of Information for Tax Purposes (see ). Because the OECD has never listed any of its 35 members as tax havens, Ireland, Luxembourg, the Netherlands and Switzerland are sometimes referred to as the "OECD tax havens".
Subsequent definitions of tax haven, and/or offshore financial centre/corporate tax haven (see definition of a "tax haven"), focus on effective taxes as the primary requirement, which Ireland would meet, and have entered the general lexicon. The Tax Justice Network, who places Ireland on its tax haven list, split the concept of "tax rates" from "tax transparency" by defining a secrecy jurisdiction and creating the Financial Secrecy Index. The OECD has never updated or amended its 1998 definition (apart from dropping the 4th criteria). The Tax Justice Network imply the U.S. may be the reason.
EU 2017 tax haven lists.
While by 2017, the OECD only considered Trinidad and Tobago to be a tax haven, in 2017 the EU produced a list of 17 tax havens, plus another 47 jurisdictions on the "grey list", however, as with the OECD lists above, the EU list did not include any EU-28 jurisdictions. Only one of the EU's 17 blacklisted tax havens, namely Samoa, appeared in the July 2017 Top 20 tax havens list from CORPNET.
The EU Commission was criticised for not including Ireland, Luxembourg, the Netherlands, Malta and Cyprus, and Pierre Moscovici, explicitly stated to an Irish State Oireachtas Finance Committee on 24 January 2017: "Ireland is not a tax haven", although he subsequently called Ireland and the Netherlands "tax black holes" on 18 January 2018.
On 27 March 2019, "RTÉ News" reported that the European Parliament had "overwhelmingly accepted" a new report that likened Ireland to a tax haven.
Hines–Rice 1994 definition.
The first major was James R. Hines Jr., who in 1994, published a paper with Eric M Rice, listing 41 tax havens, of which Ireland was one of their "major 7 tax havens". The 1994 Hines–Rice paper is recognised as the first important paper on tax havens, and is the most cited paper in the history of research on tax havens. The paper has been cited by all subsequent, "most cited", research papers on tax havens, by other , including Desai, Dharmapala, Slemrod, and Zucman. Hines expanded his original 1994 list to 45 countries in 2007, and to 52 countries in the Hines 2010 list, and used quantitative techniques to estimate that Ireland was the third largest global tax haven. Other major papers on tax havens by Dharmapala (2008, 2009), and Zucman (2015, 2018), cite the 1994 Hines–Rice paper, but create their own tax haven lists, all of which include Ireland (e.g., the June 2018, Zucman–Tørsløv–Wier 2018 list).
The 1994 Hines–Rice paper was one of the first to use the term" "profit shifting"". Hines–Rice also introduced the first quantitative tests of a tax haven, which Hines felt were needed as many tax havens had non-trivial "headline" tax rates. These two tests are still the most widely quoted proxy tests for tax havens in the academic literature. The first test, extreme distortion of national accounts by BEPS accounting flows, was used by the IMF in June 2000 when defining offshore financial centres ("OFCs"), a term the IMF used to capture both traditional tax havens and emerging modern corporate tax havens:
The Hines–Rice paper showed that "low foreign tax rates [from tax havens] ultimately enhance U.S. tax collections". Hines' insight that the U.S. is the largest beneficiary from tax havens was confirmed by others, and dictated U.S. policy towards tax havens, including the 1996 "check-the-box" rules, and U.S. hostility to OECD attempts in curbing Ireland's BEPS tools. Under the 2017 U.S. TCJA, U.S. multinationals paid a 15.5% repatriation tax on the circa $1 trillion in untaxed cash built up in global tax havens from 2004 to 2017. Had these U.S. multinationals paid foreign taxes, they would have built up sufficient foreign tax credits to avoid paying U.S. taxes. By allowing U.S. multinationals to use global tax havens, the U.S. exchequer received more taxes, at the expense of other countries, as Hines predicted in 1994.
Several of Hines' papers on tax havens, including the calculations of the Hines–Rice 1994 paper, were used in the final report by the U.S. President's Council of Economic Advisors that justified the U.S. Tax Cuts and Jobs Act of 2017, the largest U.S. tax reform in a generation.
The Irish State dismisses academic studies which list Ireland as a tax haven as being "out-of-date", because they cite the 1994 Hines–Rice paper. The Irish State ignores the fact that both Hines, and all the other academics, developed new lists; or that the Hines–Rice 1994 paper is still considered correct (e.g. per the 2017 U.S. TCJA legislation). In 2013, the Department of Finance (Ireland) co-wrote a paper with the Irish Revenue Commissioners, which they had published in the State-sponsored ESRI Quarterly, which found the only sources listing Ireland as a tax haven were:
This 2013 Irish State-written paper then invoked the of a tax haven, four years younger than Hines–Rice, and since discredited, to show that Ireland was not a tax haven.
The following is from a June 2018 Irish Independent article by the CEO of the key trade body that represents all U.S. multinationals in Ireland on the 1994 Hines–Rice paper:
Unique talent base.
In a less technical manner to the rebuttals by the Irish State, the labels have also drawn responses from leaders in the Irish business community who attribute the value of U.S. investment in Ireland to Ireland's unique talent base. At €334 billion, the value of U.S. investment in Ireland is larger than Ireland's 2016 GDP of €291 billion (or 2016 GNI* of €190 billion), and larger than total "aggregate" U.S. investment into all BRIC countries. This unique talent base is also noted by IDA Ireland, the State body responsible for attracting inward investment, but never defined beyond the broad concept.
Ireland has no university in the top 100. Irish education does not appear to be distinctive. Ireland has a high % of third-level graduates, but this is because it re-classified many technical colleges into degree-issuing institutions in 2005–08. This is believed to have contributed to the decline of its leading universities, of which there are barely two left in the top 200 (i.e. a quality over quantity issue). Ireland continues to pursue this strategy and is considering re-classifying the remaining Irish technical institutes as universities for 2019.
Ireland shows no apparent distinctiveness in any non-tax related metrics of business competitiveness including cost of living, league tables of favoured EU FDI locations, league tables of favoured EU destinations for London-based financials post–Brexit (which are linked to quality of talent), and the key World Economic Forum Global Competitiveness Report rankings.
Irish commentators provide a perspective on Ireland's "talent base". The State applies an "employment tax" to U.S. multinationals using Irish BEPs tools. To fulfil their Irish employment quotas, some U.S. technology firms perform low-grade localisation functions in Ireland which requires foreign employees speaking global languages (while many U.S. multinationals perform higher-value software engineering functions in Ireland, some do not). These employees must be sourced internationally. This is facilitated via a loose Irish work-visa programme. This Irish "employment tax" requirement for use of BEPS tools, and its fulfilment via foreign work-visas, is a driver of Dublin's housing crisis. This is consistent with a bias to property development-led economic growth, favoured by the main Irish political parties (see Abuse of QIAIFs).
Global "knowledge hub" for "selling into Europe".
In another less technical rebuttal, the State explains Ireland's high ranking in the established "proxy tests" for tax havens as a by–product of Ireland's position as preferred hub for global "knowledge economy" multinationals (e.g. technology and life sciences), "selling into EU–28 markets". When the Central Statistics Office (Ireland) suppressed its 2016–2017 data release to protect Apple's Q1 2015 BEPS action, it released a paper on "meeting the challenges of a modern globalised knowledge economy".
Ireland has no foreign corporates that are non–U.S./non–UK in its top 50 companies by revenue, and only one by employees (German Lidl who sells into Ireland). The UK multinationals in Ireland are either selling into Ireland (e.g. Tesco), or date pre–2009, after which the UK overhauled its tax system to a "territorial tax" model. Since 2009, the U.K has become a major tax haven (see U.K. transformation). Since this transformation, no major UK firms have moved to Ireland and most UK corporate tax inversions to Ireland returned; and Ireland has failed to win Brexit financial services firms.
In 2016, U.S. corporate tax expert, James R. Hines Jr., showed multinationals from "territorial" corporate taxation systems don't need tax havens, when researching behaviours of German multinationals with German academic tax experts.
U.S.–controlled multinationals are 25 of the top 50 Irish firms (including tax inversions), and 70% of top 50 revenue (see "Table 1"). U.S.–controlled multinations pay 80% of Irish corporate taxes (see "low tax economy"). Irish–based U.S. multinationals may be selling into Europe, however, the evidence is that they route all non–U.S. business through Ireland. Ireland is more accurately described as a "U.S. corporate tax haven". The U.S. multinationals in Ireland are from "knowledge industries" (see "Table 1"). This is because Ireland's BEPS tools (e.g. the double Irish, the single malt and the capital allowances for intangible assets) require intellectual property ("IP") to execute the BEPS actions, which technology and life sciences possess in quantity (see IP–Based BEPS tools).
Rather than a "global knowledge hub" for "selling into Europe", Ireland is a base for U.S. multinationals, with sufficient IP to use Ireland's BEPS tools, to shield non–U.S. revenues from U.S. taxation.
In 2018, the U.S. converted into a hybrid "territorial" tax system (the U.S. was one of the last remaining pure "worldwide" tax systems). Post this conversion, U.S. "effective" tax rates for IP–heavy U.S. multinationals are very similar to the "effective" tax rates they would incur if legally headquartered in Ireland, even net of full Irish BEPS tools like the double Irish. This represents a substantive challenge to the Irish economy (see effect of U.S. Tax Cuts and Jobs Act). However, mean some Irish BEPS tools, such as Apple's , have been enhanced.
Ireland's recent expansion into traditional tax haven services (e.g. Cayman Island and Luxembourg type ICAVs and L–QIAIFs) is a diversifier from U.S. corporate tax haven services. Brexit has been disappointing for Ireland in its failure to attract any London financial services firms, underlying Ireland's traditional weakness in non–U.S. corporates. Brexit has led to growth in UK centric tax-law firms (including offshore magic circle firms), setting up offices in Ireland to handle traditional tax haven services for clients.
From the above table:
Countermeasures.
Background.
Apparent contradictions.
While Ireland's development into traditional tax haven tools (e.g. ICAVs and L–QIAIFs) is more recent, Ireland's status as a corporate tax haven has been noted since 1994 (the first Hines–Rice tax haven paper), and discussed in the U.S. Congress for a decade. A lack of progress, and delays, in addressing Ireland's corporate tax BEPS tools is apparent:
Source of contradictions.
Tax haven experts explain these contradictions as resulting from the different agendas of the major OECD taxing authorities, and particularly the U.S., and Germany, who while not themselves considered tax havens or corporate tax havens, rank #2 and #7 respectively in the 2018 Financial Secrecy Index of tax secrecy jurisdictions:
Tax Cuts and Jobs Act.
Impact.
Before the passing of the TCJA in December 2017, the U.S. was one of eight remaining jurisdictions to run a "worldwide" taxation system, which was the principal obstacle to U.S. corporate tax reform, as it was not possible to differentiate between the source of income. The seven other "worldwide" tax systems, are: Chile, Greece, Ireland, Israel, Korea, Mexico, and Poland.
Tax experts expect the anti-BEPS provisions of the TCJA's new hybrid "territorial" taxation system, the GILTI and BEAT tax regimes, to neutralize some Irish BEPS tools (e.g. the double Irish and the single malt). In addition, the TCJA's FDII tax regime makes U.S.–controlled multinationals indifferent as to whether they charge-out their IP from the U.S. or from Ireland, as net effective tax rates on IP, under the FDII and GILTI regimes, are very similar. Post-TCJA, S&P500 IP–heavy U.S.–controlled multinationals, have guided 2019 tax rates that are similar, whether legally headquartered in Ireland or the U.S.
Tax academic, Mihir A. Desai, in a post-TCJA interview in the "Harvard Business Review" said that: "So, if you think about a lot of technology companies that are housed in Ireland and have massive operations there, they’re not going to maybe need those in the same way, and those can be relocated back to the U.S.
It is expected Washington will be less accommodating to U.S. multinationals using Irish BEPS tools and locating IP in tax havens. The EU Commission has also become less tolerant of U.S. multinational use of Irish BEPS tools, as evidenced by the €13 billion fine on Apple for Irish tax avoidance from 2004 to 2014. There is widespread unhappiness of Irish BEPS tools in Europe, even from other tax havens.
Technical issues.
While the Washington and EU political compromises tolerating Ireland as a corporate tax haven may be eroding, tax experts point to various technical flaws in the TCJA which, if not resolved, may actually enhance Ireland as a U.S. corporate tax haven:
A June 2018 IMF country report on Ireland, while noting the significant exposure of Ireland's economy to U.S. corporates, concluded that the TCJA may not be as effective as Washington expects in addressing Ireland as a U.S. corporate tax haven. In writing its report, the IMF conducted confidential anonymous interviews with Irish corporate tax experts.
Some tax experts, noting Google and Microsoft's actions in 2018, assert these flaws in the TCJA are deliberate, and part of the U.S. Administration's original strategy to reduce "aggregate" effective global tax rates for U.S. multinationals to circa 10–15% (i.e. 21% on U.S. income, and 2.5% on non–U.S. income, via Irish BEPS tools). There has been an increase in U.S. multinational use of Irish intangible capital allowances, and some tax experts believe that the next few years will see a boom in U.S. multinationals using the Irish "Green Jersey" BEPS tool and on-shoring their IP to Ireland (rather than the U.S.).
As discussed in and , the U.S. Treasury's corporation tax policy seeks to maximise long-term U.S. taxes paid by using corporate tax havens to minimise near-term foreign taxes paid. In this regard, it is possible that Ireland still has a long-term future as a U.S. corporate tax haven.
In February 2019, Brad Setser from the Council on Foreign Relations, wrote a "New York Times" article highlighting material issues with TCJA.
Sources.
Journals.
The following are the most cited papers on "tax havens", as ranked on the IDEAS/RePEc database of economic papers, at the Federal Reserve Bank of St. Louis.
Papers marked with (‡) were also cited by the EU Commission's 2017 summary as the most important research on tax havens.


Mohammed Kadhim al-Qazwini

Ayatollah Sayyid Muhammad-Kadhim al-Musawi al-Qazwini (; ; March 13, 1930 – November 17, 1994) was an Iraqi Shia scholar, poet and orator of Iranian descent. He was born in Karbala, Iraq and died in Qom, Iran.
He was a dubbed the 'master of Karbala's orators'. He authored a series of leading books on the biographies of the Ahl al-Bayt called "Min al-Mahd Ila al-Lahd" (From the Cradle to the Grave).
Biography.
Early life.
al-Qazwini was born to Sayyid Muhammad-Ibrahim al-Qazwini (d. 1941), the son of grand Ayatollah Sayyid Muhammad-Hashim al-Qazwini (d. 1908). His mother died when he was still very young, whilst his father died when he was only 11 years old. He was taken in by his cousin Sayyid Muhammad-Sadiq al-Qazwini, who took care of him and took him to the seminary of Karbala, to pursue a religious education.
Education.
al-Qazwini took the classes of scholars like Sheikh Jafar al-Rashti, Sayyid Muhammad-Hadi al-Milani, Mirza Mahdi al-Shirazi, Sheikh Yusuf al-Khurasani and Sheikh Muhammad al-Khatib. He studied oratory under, his third cousin, Sayyid Muhammad-Salih al-Qazwini (d. 1956; author of notable book, "al-Mawʿiḍa al-Ḥasana", a critique of Ali al-Wardi's "Wuʿaẓ al-Salaṭīn"), and excelled in his public speaking.
Emigration.
al-Qazwini immigrated twice. The first time was to Kuwait, in 1973, due to the pressures and prosecutions of the Baathist regime, where he practiced his religious activities from Masjid Bin Nakhi. He remained in Kuwait for seven years, and in 1980 travelled to Iran and took residence in Qom, until his death.
Religious career.
He founded the Islamic Publishing Association in Karbala, and managed to print and publish large amounts of Islamic books across various Arabian, African and European countries. He also founded the Kitab Wa al-Itra oratory school, which helped produce a generation of religious orators, under his supervision. The school was then closed down by the Baathist regime. He led the prayers in the Husayn shrine after his brother-in-law Muhammad al-Shirazi immigrated to Kuwait in 1970.
Personal life.
al-Qazwini was married to Fatima al-Shirazi, the daughter of grand Ayatollah Mirza Mahdi al-Shirazi. He has five sons, whom are all clerics, and three daughters.
His three son in laws were Sayyid Mehdi al-Kashafi, Sayyid Ali al-Qazwini and Sayyid Kamal al-Din al-Shahidi.
He is the second cousin, twice removed of the renowned Sayyid Ibrahim al-Qazwini (d. 1848), author of "al-Dhawabit".
Death.
Towards the end of his life, al-Qazwini suffered from a neurological disease that began to take a significant toll on his health, especially his speech, until he died because of it, in the evening of Thursday, November 17, 1994 in Qom. He was buried in Qom under the pulpit of the Hussainiya he frequently recited in.
However, he had declared in his will, that when it were possible, his corpse be transferred to Karbala, to be reburied, as that was his initial wish, but it was impossible due to the Baathis regime. It took the fall of the regime to allow for this to happen, and on May 8, 2011, his family decided to have his corpse exhumed and transferred to Karbala, and was buried in the Imam Husayn shrine. It is reported that when they took his corpse out in Qom, upon inspection, his body was fresh and as if he had just been buried.
Works.
al-Qazwini came to write scores of articles and books in religious beliefs including:


Tucker v. State

Tucker v. State of Indiana [218 Ind. 614, 35 NE2d 270 (1941)] was a landmark decision case by the Indiana Supreme Court that ruled that the Governor of Indiana is the chief executive of the State of Indiana and that the Indiana General Assembly has no authority to delegate or regulate authority that was granted to that office by the Constitution of Indiana. Until the decision by the court, it was held by the General Assembly that it could delegate and revoke executive authority at will.
Background.
The state of Indiana has historically had a weak executive branch and a strong legislature, from its original state constitution and the restrictions placed on the office by the anti-governor faction in the constitutional convention, which resented the powers of the territorial governors. The governorship remained a weak position until the American Civil War, when the governor suppressed the legislature and took on unconstitutional powers. In the years after the war, the legislature removed much of the authority and greatly weakened his position, by placing regulations on the office and removing its authority to appoint state officers and hire public employees.
The situation continued until 1933, when the Democratic-controlled legislature passed the Executive Reorganization Act to grant to governor expansive powers over the burgeoning Great Depression government bureaucracy. When Republicans resumed power in 1941, they immediately repealed the act and put in place the State Administration Act of 1941 to return the governor to his pre-Depression level of power. The act reorganized the government into five departments, under the control of commissioners.
Case.
Democratic Governor Henry F. Schricker filed a suit against the law after its passage and was able to have the law stayed. Republican Indiana Secretary of State James M. Tucker filed a countersuit claiming the circuit courts had no authority to stay an act of the legislature and appealed the decision to the Indiana Supreme Court.
Decision.
The court at that time had four Democrats and one Republican. The court ruled in favor of the governor in a 4-1 decision, along straight party lines. It decided that the governor is in fact the chief executive of the state, and the legislature could not revoke his powers or delegate them if they were expressly granted to him in the state constitution.
Significance.
The decision was noted because until then, the legislature had freely regulated the powers of the governor. The court created, for the first time, a legal basis for the governor to assume power in areas previously delegated to other officials. The decision remains an important factor in the state’s patronage system.
References.
Notes
Bibliography


Lawrence E. Gerosa

Lawrence Ettore Gerosa (August 10, 1894 Milan, Italy – June 24, 1972) was an Italian-American politician who served as New York City Comptroller from 1954–1961.
A resident of the Riverdale section of the Bronx, Gerosa was a conservative Democrat who had been in the trucking industry before entering politics. After being jettisoned from the Democratic ticket in 1961 in favor of Abe Beame, he challenged incumbent mayor Robert F. Wagner, Jr. in 1961 as an Independent, proffering a fiscally conservative, law and order platform. He garnered 13% percent of the vote against Wagner and liberal Republican Louis Lefkowitz. The Gerosa campaign would articulate many of the themes which would be used again in 1969, when another conservative Italian-American Democrat Mario Procaccino challenged John V. Lindsay for control of city hall. Gerosa died of lung cancer at Albert Einstein Hospital in the Bronx.


Michael C. Bonello

Michael C. Bonello is a Maltese economist, former governor of the Central Bank of Malta from 1999 to 2011.
Biography.
After obtaining a bachelor's degree in languages and economics from the University of Malta in 1965, Bonello pursued his studies as a Rhodes Scholar at the University of Oxford, where he took an honours degree in philosophy, politics and economics in 1969.
In 1969 he joined the Central Bank of Malta as a research assistant and later served as senior research officer from 1971 to 1978. Bonello was also president of the Malta branch of the Chartered Institute of Bankers. In 1978, he left the bank to join the private sector, where he held senior management positions and sat on the councils of the Chamber of Commerce and the Federation of Industry until he joined the United Nations Conference on Trade and Development (UNCTAD) in Geneva. Between 1983 and 1999 he served UNCTAD as senior economic affairs officer in the International Trade Division, chief of the Policy Clearance Unit, advisor in the office of the secretary-general and executive assistant to the deputy secretary-general.
He was initially appointed governor of the Central Bank of Malta on 1 October 1999 upon proposal of Prime Minister Eddie Fenech Adami. His appointment has been extended for five years by PM Lawrence Gonzi, with effect from 1 October 2008. He left the Central Bank in 2011.
Since 2013 Bonello is Chairman of Lombard Bank Malta plc.
Bonello is also a member of the governing and general councils of the European Central Bank, a fellow of the Institute of Financial Services and a member of the board of governors of the Malta Financial Services Authority.


Toldos Avrohom Yitzchok

Toldos Avrohom Yitzchok is a Hasidic group located in Jerusalem's Mea Shearim neighborhood. It is an offshoot of the Hasidic group Toldos Aharon, which is in turn an offshoot of Shomer Emunim. It is led by its Rebbe, Rabbi Shmuel Yaakov Kohn.
Toldos Avrohom Yitzchok is one of the groups that make up the Edah HaChareidis. Until his death in May 2009, Rabbi Meir Brandsdorfer served as both the halachic decisor of Toldos Avrohom Yitzchok and member of the Badatz of the Edah HaChareidis.
History.
Rabbi Aharon Roth was known to be very anti-Zionist, and his Hasidim today continue that tradition, particularly the Toldos Aharon and Toldos Avrohom Yitchok groups. They owe their strong opinions on Zionism to the literal reading of the Talmud's proclamation that Jews should not take over the Holy Land prior to the coming of the Messiah. (For more information about this subject, see Three Oaths; compare also Satmar's opposition to Zionism. While Rabbi Aharon's opposition to Zionism predated the publication of the Satmar Rav's book "Vayoel Moshe", the Satmar Rav's reasoning and Rabbi Aharon's reasoning for opposing Zionism are similar, if not identical.)
When Rabbi Aharon died, his son and his son-in-law both became rebbes in their own right. The dynastic chain being:
Rabbi Avrohom Yitzchok Kohn, the previous Toldos Aharon Rebbe, died during Hanukkah of 1996. Rabbi Kohn had many sons, two of whom are rebbes today. After Rabbi Kohn died, these two sons came to an agreement whereby the younger son Rabbi Duvid Kohn from Monsey, New York, a disciple of the Klausenburg Rebbe, inherited the title "Toldos Aharon Rebbe". The eldest son, Rabbi Shmuel Yaakov Kohn, a disciple of the Viznitzer Rebbe, became a rebbe as well, of a group that was entitled "Toldos Avrohom Yitzchok" named after his father, the previous rebbe of the group. The main beis medrash of Toldos Avrohom Yitzchok is also in Mea Shearim, one block away from the Toldos Aharon building. Both live in Jerusalem. Another son is a rosh yeshiva in Kiryas Joel, New York.
Dress and customs.
In Jerusalem, married men wear white and grey "Zebra" coats during the week and golden bekishes (coats) on Shabbos. Toldos Aharon and Toldos Avrohom Yitzchok are the only groups where boys aged 13 and older (bar mitzvah) wear the golden coat and a shtreimel, as married men do, although the single boys wear black socks and the married men wear white socks. In most other Hasidic groups, only married men wear a shtreimel. All boys and men wear a traditional Jerusalemite white yarmulke. Unmarried boys wear a regular black coat with attached belt on weekdays, unlike the married men, who wear the "Zebra" style coat.
Married women cover their hair with scarves, without wearing wigs, and the standards of tznius expected from them are the strictest among all Hasidic/Orthodox Jewish groups. As is customary in the traditional Jerusalemite community, unmarried girls have their hair in two braided pigtails, unlike most other Haredi communities, where the girls wear their hair in a simple ponytail.
The Shomrei Emunim are characterized by fervent and visibly emotional prayer, and by a rigid lifestyle controlled largely by ""takanos" - decrees written by the Rebbe. One such decree, for example, forbade wearing wool. (Jewish law forbids wearing anything that contains both wool and linen. Rabbi Aharon worried that it would be safest not to wear wool at all, in order to avoid the possibility of violating the law altogether.) A strong emphasis is placed on the importance of full-time Torah study, and daily immersion in ritual baths.
Hasidic books of the Shomer Emunim, Toldos Aharon, and Toldos Avrohom Yitzchok groups.
In addition to those books which are revered by all Hasidic Jews, the Toldos Aharon Hasidim particularly revere the books, "Shomer Emunim", "Shulchan HaTahor", and "Taharas HaKodesh", by Rebbe Aharon Roth, and "Divrei Emunoh" by Rebbe Avrohom Yitzchok Kahn. The version of the prayer book used by Toldos Aharon Hasidim is called "Brochoh u'Tehilloh". The version of the prayer book used by Toldos Avrohom Yitzchok Hasidim is called, "Tehillas Avrohom Yitzchok".
The previous Rebbe of Toldos Aharon, R' Avrohom Yitzchok, was said to have instructed his followers to learn the works of Rabbi Aharon HaLevi of Staroshelye (pronounced Strashelye), which include "Sha'arei HaYichud VeHaEmunoh"," ""Sha'arei Avoda"," and ""Avodas HaLevi"." The Staroselyer Rebbe was a follower of the first Rebbe of Chabad, Rabbi Shneur Zalman of Liadi. After the passing of R' Shneur Zalman, R' Aharon HaLevi started his own Chassidic following, an offshoot of Chabad, in Staroselye.


SEB banka

SEB banka (formerly - Latvijas Unibanka, then SEB Latvijas Unibanka) is one of the largest banks in Latvia. The bank was established by consolidating earlier financial structures such as Bank of Agricultural Industry after Latvia regained its independence from the USSR. Nowadays its main rivals in the Latvian banking market are Swedbank, Luminor and Citadele bank.
Patron of the University of Latvia.
SEB banka is a silver patron of the University of Latvia Foundation. Has supported LU since 2008 by donating to scholarships and forums.


List of children of the vice presidents of the United States

Vice presidents of the United States since 1961 have had 43 children among them.
Aaron Burr and Theodosia Bartow Prevost.
Their first child, and the only one to survive to adulthood, was born on June 21, 1783, and also named Theodosia.
Elbridge and Ann Gerry.
The couple had ten children between 1787 and 1801 (three died young).
Daniel and Hannah Tompkins.
On February 20, 1798, Daniel Tompkins, 23, married 16-year-old Hannah Minthorne, the daughter of Mangle Minthorne, an Assistant Alderman of New York City.
The couple had eight children, including
Arietta Minthorn Tompkins (born July 31, 1800), who married a son of Smith Thompson in 1818,
and (Mangle) Minthorne Tompkins (December 26, 1807 – June 5, 1881), who was the Free Soil Party candidate for Governor of New York in 1852.
The Tompkins also fostered Henry Brewerton (1801-1879), who was orphaned at a young age. Brewerton entered West Point in 1813, served as an engineer officer during the American Civil War and retired from the Army in 1867.
John and Floride Calhoun.
The couple had 10 children over 18 years:
Andrew Pickens Calhoun,
Floride Pure (died in infancy),
Jane (died in infancy),
Anna Maria (who married Thomas Green Clemson, who later founded Clemson University in South Carolina).
Elizabeth (died in infancy),
Patrick,
John Caldwell Jr.,
Martha Cornelia,
James Edward, &
William Lowndes Calhoun.
Richard Mentor and Julia Chinn Johnson.
They had two daughters together and she later became manager of his plantation.
George M. and Sophia Dallas.
They had 8 children.
John C. and Mary Cyrene Burch Breckinridge.
They had 7 children, including Clinton Breckinridge.
https://en.m.wikipedia.org/wiki/Clifton_R._Breckinridge
Hannibal Hamlin.
with Ellen Hamlin.
They had 2 children together.
Henry and Harriet Wilson.
They had 2 children.
On October 28, 1840, Wilson married Harriet Malvina Howe (1824–1870).[5] They were the parents of a son, Henry Hamilton Wilson (1846–1866), who attended the Highland Military Academy in Worcester, Massachusetts.
During the Civil War, the younger Wilson attended the United States Naval Academy, but left before graduating in order to accept a commission in the Union Army. He attained success in the 31st and 104th Regiments of United States Colored Troops, and was promoted to lieutenant colonel and second-in-command of the 104th in July 1865. After the war he accepted a commission as a second lieutenant in the regular Army's 6th Cavalry Regiment, and served until his death from a ruptured appendix in 1866. Camp Wilson, an Army post in Texas was named for Henry H. Wilson; it was later renamed Fort Griffin.
In 1869 Henry and Harriet Wilson also became the de facto adoptive parents of a girl, Evangelina, who was born between 1864 and 1866, and took the name Eva Wilson. In a complicated series of events, in 1869 a woman named Caroline Vreeland met Wilson's sister-in-law Nancy Colbath, wife of his brother Samuel. Vreeland allowed Nancy Colbath to adopt the child, with the understanding that she would be raised by Henry Wilson and his wife. The child lived with the Wilsons until shortly before Mrs. Wilson's death. Nancy Colbath then kept the child, and received monthly payments from Henry Wilson for her support. Details later emerged which indicated the likelihood that Vreeland had obtained a baby girl from an unknown parent or parents in Boston in 1866 so that her sister could use the baby in an attempt to extort a man with whom she had had an affair. Vreeland went to prison for a stabbing in the early 1870s. The child continued to live with Wilson, and by 1874 he had asked Nancy Colbath to again be responsible for her. Wilson agreed to provide them a suitable home and financial support, but had not followed through by the time of his death.
Wilson requested that the executor of his will, nephew William Leander Coolidge, use most of Wilson's estate to ensure that Wilson's mother in law was cared for, and that Eva receive an education and financial support. Wilson had given Coolidge verbal instructions and letters in addition to his will, and the situation became complicated because Wilson's death occurred before he had incorporated these additional instructions into his will. Coolidge acted as a trustee for Eva, and by 1889, when she was more than 21 years old, she claimed she was entitled to the remainder of Wilson's estate. Other Wilson family members disagreed; because of the complexity of the details, Coolidge petitioned the Massachusetts courts for guidance. The courts found in favor of Eva, by then married and known as Eva Carpenter, and she received the bulk of the residue of the estate.
Thomas A. and Eliza Hendricks.
Hendricks married Eliza Carol Morgan of North Bend, Ohio, on September 26, 1845, after a two-year courtship. The couple met when Eliza was visiting her married sister, Mrs. Daniel West, in Shelbyville. The couple's only child, a son named Morgan, was born on January 16, 1848, and died in 1851, at the age of three. Thomas and Eliza Hendricks moved to Indianapolis in 1860 and resided from 1865 to 1872 at 1526 South New Jersey Street, now known as the Bates-Hendricks House.
Levi P. Morton.
with Lucy Morton.
On October 15, 1856, Morton married Lucy Young Kimball (1836–1871), the daughter of Elijah Huntingdon Kimball and Sarah Wetmore Hinsdale, in Flatlands, Brooklyn.[38] They had one child, daughter Carrie, who died in infancy in 1857.
with Anna Morton.
After his first wife's death in 1871 & the death of their only daughter Carrie in 1857, Morton married Anna Livingston Reade Street in 1873. They were the parents of five daughters and a son who died in infancy.
Edith Livingston Morton (1874–1964), who married William Corcoran Eustis (1862–1921) in 1900.
Lena Kearney Morton (1875–1904), who did not marry.
Helen Stuyvesant Morton (1876–1952), who married the Duke of Valençay, a son of Boson de Talleyrand-Périgord. They divorced in 1904.
Lewis Parsons Morton (1877–1878).
Alice Morton (1879–1917), who married Winthrop Rutherfurd, a son of Lewis Morris Rutherfurd, in 1902.
Mary Morton (1881–1932), who did not marry but who adopted two children, Lewis Peter Morton and Mirian Morton.
In 1902, Alice Morton founded "Holiday Farm" as a convalescent home for children. Children who attended were picked up at Grand Central Station and brought to the farm in Rhinebeck. Train fare, board and clothing were provided free. In 1917, Vincent Astor served as President, with Helen Dinsmore Huntington as Secretary. Holiday Farm later developed into the Astor Home for Children.
Adlai and Letitia Stevenson.
They had 4 children.
In 1866, he married Letitia Green. They had three daughters, Mary, Julia and Letitia, and a son, Lewis Stevenson. Letitia helped establish the Daughters of the American Revolution as a way of healing the divisions between the North and South after the Civil War, and succeeded the wife of Benjamin Harrison as the DAR's second president-general.
Garret and Jennie Tuttle Hobart.
They had four children, two of whom died in childhood. The other two were Garret Jr. and Fannie, who died in 1895
Charles W. and Cornelia Cole Fairbanks.
They had four sons and one daughter:
Robert Fairbanks (who attended Yale),
Richard M. Fairbanks (who attended Yale and served as a captain in World War I),
Adelaide Fairbanks (who married Horace Allen, a doctor),
Warren Charles Fairbanks, and Frederick Cole Fairbanks.
James S. and Carrie Babcock Sherman.
The couple had three sons: Sherrill B. Sherman (1883–1962), Richard U. Sherman (1884–1951) & Thomas M. Sherman (1885–1944).
Thomas R. and Lois Irene Marshall.
They had one foster child called Morrison.
Marshall and his wife, Lois, never officially adopted Morrison, whose legal name was Clarence Ignatius Morrison.
Charles and Caro Dawes.
They had 2 biological and 2 adopted children.
Charles and Annie Baird Curtis.
On November 27, 1884, Curtis married Annie Elizabeth Baird[9] (1860–1924). They had three children: Permelia Jeannette Curtis (1886–1955), Henry "Harry" King Curtis (1890–1946), and Leona Virginia Curtis (1892–1965). He and his wife also provided a home in Topeka for his paternal sister Dolly Curtis before her marriage. His wife died in 1924.
Henry and Ilo Wallace.
They had 3 children.
Alben W. and Dorothy Barkley.
They had 3 children.
Kamala Harris and Doug Emhoff.
Kamala Harris is a stepmother to Doug Emhoff's two children from his previous marriage to the film producer Kerstin Emhoff. The two Emhoff children call Harris 'Momala'.
Living vice presidential children.
In order of their ages, they are:
The most recent vice presidential child to die was Robert Andrew Humphrey, the second son and third child of Hubert Humphrey, who died on April 6, 2018 at the age of 74.


Gateway Eastern Railway

The Gateway Eastern Railway is a railroad subsidiary of the Kansas City Southern Railway (KCS), owning a main line between East Alton and East St. Louis, Illinois, United States. Originally created in 1994 as a subsidiary of the Gateway Western Railway, which acquired the East St. Louis-Kansas City line of the Chicago, Missouri and Western Railway in 1990, it was acquired by KCS along with its parent in 1997.
History.
The line between East St. Louis and East Alton was completed by the Belleville and Illinoistown Railroad in 1856, as an extension of its Belleville-East St. Louis (Illinoistown) line. Ownership passed to the St. Louis, Alton and Terre Haute Railroad, a predecessor of the Illinois Central Railroad, but in 1890 that company sold that segment to the Cairo, Vincennes and Chicago Railway, which became part of the Cleveland, Cincinnati, Chicago and St. Louis Railway (Big Four) and eventually the New York Central Railroad and Conrail. By 1906, the parallel Big Four and Chicago and Alton Railroad lines between Bridge Junction (East St. Louis) and Wann (near East Alton), the former just east of the latter, were being operated as a double-track line by both companies through reciprocal trackage rights.
In July 1993, the Interstate Commerce Commission approved purchase by Gateway Eastern of this line from Conrail, as well as a segment of the ex-Pennsylvania Railroad Main Line (Pittsburgh to St. Louis) from the Mississippi River just north of the Eads Bridge to Conrail's Rose Lake Yard at Willows. A short segment of trackage rights over the Terminal Railroad Association of St. Louis's (TRRA's) Eads Subdivision, also acquired from Conrail, connected the two lines. Gateway Eastern also had access to CSX Transportation's Cone Yard, west of Willows. Operations began January 28, 1994.
In order to connect its sections without trackage rights, Gateway Western bought a strip of land from CSX Transportation on which it planned to build the "Q Connection", crossing the TRRA north of "Q Tower". After a seven-year legal battle with the TRRA, during which Gateway Western placed the line in service in May 1995 through a temporary injunction, the courts ruled in favor of Gateway Western, then part of KCS, in 1998.
Operations.
Gateway Eastern's primary business was switching ex-Conrail customers in the Alton area from Conrail's Rose Lake Yard (now CSX). It had one locomotive, a 1969 EMD GP38, and operated one scheduled train per day, five days per week. Interchange was with its parent Gateway Western, Conrail, and the Southern Pacific Transportation Company subsidiary SPCSL. The reciprocal trackage rights agreement from 1906 with the Alton continues to this day, now between Gateway Eastern and the Union Pacific Railroad (successor to SPCSL, purchaser of the ex-Alton main line).


Y. S. Rajan

Yagnaswami Sundara Rajan or Y. S. Rajan (born 10 April 1943) is an Indian professor, scientist and administrator. He is Honorary Distinguished Professor in Indian Space Research Organisation. He has made major contributions to various aspects of management of Science, Technology and Innovation. In 2012, he was awarded with Padma Shri for his contribution in Science and Engineering. He is one of the well known scientists, who has closely worked with Abdul Kalam, former President of India.
Early life.
Y. S. Rajan was born into a Karnataka Brahmin family on 10 April 1943 in Kottaram near Tirunelveli. His grandfather, Sundara Ganapadigal was a great Vedic scholar. His mother's name is Visalakshi and father's name is S Yagnaswami. His parents moved to Mumbai, and Dr. Y S Rajan went on to do his schooling and later college education here. He received his master's degree in Physics from the University of Bombay in 1964. He started his career as a research scholar at Physical Research Laboratory.
Career.
He went on to hold several positions including scientific secretary positions in Department of Space, Indian Space Research Organisation. He contributed in areas like STI administration, institution building, diplomacy, strategic studies, environmental technologies, and natural resources management. He was elected as Member of International Academy of Astronautics (IAA) (1986). He was the first Executive Director of Technology Information and Forecasting and Assessment Council (TIFAC), since (1988-2002) and executed Mission REACH, an initiative of TIFAC. He has held several senior positions in National Natural Resources Management System, Confederation of Indian Industry. He also served as Vice-Chancellor in Punjab Technical University (PTU), Scientific Adviser to Punjab Chief Minister, Chairman of the Board in Nalanda University and Adjunct Professor in Birla Institute of Technology & Science (BITS), Pilani.
Books and works.
He is a coauthor of the popular and path breaking book "India 2020: A Vision for the New Millennium" with A P J Abdul Kalam. Hindi version as Bharat 2020 aur uske baad. He has authored many books including "Discover Your Power Quotient" and more than 200 articles and papers, which have also been published in international journals.
Honours.
He has been honored with many awards including Padma Shri(2012), Fellow of the Indian National Academy of Engineering (1998), Fellow of World Academy of Art and Science (WAAS) (2010), Honorary Degree of Doctor of Letters (D.Litt.) from Jain Vishva Bharati University, Ladnun, Rajasthan (2005)
He has also been honored with new raga named after him as “Rajasadhaka” created by Music Composer Mahesh Mahadev with a song composition “Transforming the” A poem from Y S Rajan’s Jumping Genes book sung by Priyadarshini in the presence of Padmabhushan Tarun Das, Former Director General of Confederation of Indian Industry & Dr. M.R.Jayaram, Chancellor, Ramaiah University of Applied Sciences & Chairman, Gokula Education Foundation.


Minister of External Affairs (India)

The Minister of External Affairs (or simply, the Foreign Minister, in Hindi Videsh Mantri) is the head of the Ministry of External Affairs of the Government of India. One of the senior-most offices in the Union Cabinet, the chief responsibility of the Foreign Minister is to represent India and its government in the international community. The Foreign Minister also plays an important role in determining Indian foreign policy. Occasionally, the Foreign Minister is assisted by a Minister of State for External Affairs or the lower-ranked Deputy Minister of External Affairs.
India's first Prime Minister, Jawaharlal Nehru, also held the Foreign Minister post throughout his 17-year premiership of the country; he remains the country's longest-serving Foreign Minister. Several other Prime Ministers have since held the additional charge of foreign minister, but never has any other cabinet minister held additional charge of the office. There have been a number of Foreign Ministers who went on to become the Prime Minister like Atal Bihari Vajpayee, P. V. Narasimha Rao and I. K. Gujral.
The current Minister of External Affairs is Subrahmanyam Jaishankar, succeeding Sushma Swaraj of the Bharatiya Janata Party on 30 May 2019.


BasicNeeds

BasicNeeds is a global mental health organization, working to improve the lives of people living with mental illness and or epilepsy. It was merged into the Christian disability charity CBM UK in July 2017.
By working in partnership with local partners and people, BasicNeeds has built an innovative and effective model for recovery and sustained good mental health that uses meaningful work and community support, as well as treatment, to help those living with mental illness in resource-poor settings.
BasicNeeds is predominately focused on low and middle income countries.
BasicNeeds was established in 2000 by Chris Underhill MBE, who had worked with mental health organizations in Africa for over 25 years and arrived on the continent in the early 1970s with Voluntary Service Overseas (VSO). BasicNeeds was a response to the lack of real mental health care in lower and middle income countries. Since its foundation, BasicNeeds has helped over 657,000 people with mental illness or epilepsy as well as their families and carers in India, Sri Lanka, Ghana, Tanzania, Kenya, Uganda, Laos, Vietnam, Nepal, China, Pakistan and South Sudan.
Background.
According to the World Health Organization (WHO) more than 450 million people suffer from mental disorders. Depression alone is one of the leading causes of disability worldwide. The cost to the world economy is some US$2.5 trillion per year in reduced economic productivity and physical ill-health, yet resources are scarce, with mental health being allocated less than 2% of health spending in most low and middle income countries.
Poverty brings with it heightened stress, social exclusion, malnutrition, violence and trauma, all of which contribute to mental illness. It is a vicious cycle: people living with mental illness experience widespread stigma and discrimination, suffer violence and abuse, and find it harder to get work, get an education or contribute to their family and community. They are more prone to other forms of illness and disease, and find it harder to access health care.
Approach.
BasicNeeds was set up because of the factors which the WHO report highlighted, and through its programs attempts to ensure that mental health is given due attention. BasicNeeds' mission is to enable people living with mental illness and epilepsy and their families to live and work successfully in their communities by combining health, socio-economic and community oriented solutions with changes in policy, practice and resource allocation.
BasicNeeds' innovative Model for Mental Health and Development takes a holistic approach to community-based mental health care and consists of five inter-linking modules:
Awards.
In 2014, Chris Underhill was recognized for his contribution to the field of mental health by being selected as a Schwab Foundation Social Entrepreneur of the year. The award gives entrepreneurs the opportunity to participate in various events and initiatives of the World Economic Forum.
In 2013, Underhill also received the esteemed Skoll Award for Social Entrepreneurship. Each year the Skoll Foundation presents the Skoll Award for Social Entrepreneurship to a highly selective group of outstanding individuals from hundreds of applications. The award marked the significant contribution made by Underhill to the field of global mental health through BasicNeeds.
In 2012, Underhill was elected as a Senior Ashoka Fellow
In 2011, elected Mayor of Leamington Spa, Alan Wilkinson, chose BasicNeeds as one of his three official charities for his year in office. BasicNeeds was also "highly commended" by the Charity Awards in 2011.


Hanna Gronkiewicz-Waltz

Hanna Beata Gronkiewicz-Waltz (, born 4 November 1952) is a Polish politician and lawyer, Professor of Jurisprudence and politician who served as the Mayor of Warsaw between 2006 and 2018. She is the first woman to hold this position.
Life and career.
Between 1992 and 2000, she was the Chairman of the National Bank of Poland, the central bank of Poland. She resigned to take the position of the Deputy Chairman of European Bank for Reconstruction and Development, a position she held between 2001 and 2004.
Gronkiewicz-Waltz was elected to the Sejm on 25 September 2005 after receiving 137,280 votes in the 19th Warsaw district, running on the Civic Platform list.
In the 2006 municipal elections, Gronkiewicz-Waltz served as Civic Platform's nominee for mayor of Warsaw. On 12 November she gained 34.23%, finishing next to Law and Justice candidate, former Prime Minister Kazimierz Marcinkiewicz. As neither received 50 percent of the vote, a second round election was held on 26 November, where Gronkiewicz-Waltz received 53.18% of the votes, winning the election.
In January 2007, just a few weeks into her term, Gronkiewicz-Waltz was at the center of a controversy that could have cost her the office. A law enacted in 2005 obliged the mayors of Polish municipalities to publicly disclose their own as well as their spouse's financial circumstances. The law requires the successful candidate's disclosure statement to be provided within 30 days after the inauguration, whereas the statement regarding the candidate's spouse is to be submitted within 30 days after the actual election. Gronkiewicz-Waltz submitted her own and her husband's statements on 2 January 2007, exactly 30 days after her inauguration. On 20 January, the newspaper "Dziennik" reported that Mr Waltz's documents had been two days past the deadline, which in his case had been on 28 December 2006. Based on this, Prime Minister Jarosław Kaczyński of the governing Law and Justice (PiS) party maintained that Gronkiewicz-Waltz's mandate had expired on 28 December 2006, and announced that the local elections would be repeated. Gronkiewicz-Waltz's party Civic Platform argued that the Prime Minister did not have the authority to make this decision, and that the case would need to be examined in court instead. Polish legal experts maintained that by submitting their statements on the same day, Gronkiewicz-Waltz had observed the spirit, if not the letter of the law. Also, having two different deadlines for the statements could be considered as an unconstitutional legal trap. In the meantime, Civic Platform announced that it would nominate Gronkiewicz-Waltz again, should the elections need to be repeated. On 13 March 2007, Poland's Constitutional Tribunal ruled against the governing Law and Justice party and struck down the controversial law that threatened her and many other public officials with the loss of their positions solely because they did not file paperwork on time.
Regarding the Equality Parade for LGBT rights in the capital, Gronkiewicz-Waltz has taken the opposite stand to her predecessor, approving it. Though equality marches have been officially allowed in the past, they had always met with strong resistance during the term of Lech Kaczyński as Mayor of Warsaw, particularly from the All-Polish Youth movement. Gronkiewicz-Waltz said the parade would pose no threat to morals and pointed to the "Bączkowski v Poland" ruling by the European Court of Human Rights that Kaczyński had acted illegally and discriminatory in banning the 2005 Equality Parade.
In the November 2010 municipal elections, Gronkiewicz-Waltz was re-elected as the mayor (or "president") of Warsaw, winning 53.67% of the votes outright in the first round, making a second round unnecessary.
Hanna Gronkiewicz-Waltz was along with Monika Olejnik, an influential journalist, a murder target of Brunon K., who was arrested in November 2012 in connection with the preparation of a terrorist attack on Sejm.
Gronkiewicz-Waltz is a Fellow of Collegium Invisibile as a Professor of Economics.


Diego Hurtado de Mendoza y de la Cerda

Diego Hurtado de Mendoza y de la Cerda, 1st Duke of Francavilla (November 3, 1489, Madrid – March 19, 1578, Toledo) was a Spanish nobleman.
He became viceroy of Aragon in 1553 or 1554 – 1564, Chairman of the Council of Italy in 1558, and viceroy of Catalonia. He was the grandson of Cardinal Mendoza and son of Diego Hurtado de Mendoza y Lemos and Ana de la Cerda y Castro.
He was the 1st Duke of Francavilla.


Levin Rauch

Baron Levin Rauch de Nyék (6 October 1819 – 25 August 1890) was an Austrian-Hungarian politician and appointed Ban of Croatia-Slavonia between 1867 and 1871. He is most notable for securing victory of the Unionist Party through changing the election law and terrorising those who were able to vote.
Life.
His father was Dániel "Freiherr" Rauch de Nyék (1778–1831), while his mother was Erzsébet Farkas de Nagyjóka (1787–1858). His grandfather was Pál "Freiherr" Rauch de Nyék (c.1739–1815), colonel, who received on 6 April 1763 from Queen Maria Theresia the title of "Freiherr" (or Baron). His paternal grandmother was Anna Szegedy de Mezőszeged.
Rauch was a member of the unionist party that advocated an integration of Croatia and Kingdom of Hungary. After the Revolutions of 1848, Croatia became a Habsburg crown territory separate from Hungary, but when the Austrian-Hungarian Ausgleich was signed, Austria-Hungary was created and Rauch was appointed as the acting "ban" (or viceroy) of Croatia on 27 June 1867. By this, the Croatian autonomy within the Hungarian kingdom was automatically abolished. During this time a new Croatian–Hungarian Settlement was negotiated and put in effect by which Croatia reinstated some of its earlier , but also lost some other rights. Rauch was made the official ban on December 8, 1868 and remained in office until 26 January 1871.
His heritage spawns from the noble house of "Rauch", literally meaning ‘Smoke’. The daughter of General Gustav Rauch, Rosalie von Rauch (1820–1879), married Prince Albert of Prussia (1809–1872). At this time, Princess Rosalie assumed the title of "Gräfin von Hohenau".


Welsh Water

Dŵr Cymru Welsh Water is a not-for-profit company which supplies drinking water and wastewater services to most of Wales and parts of western England that border Wales. In total, it serves around 1.4 million households and businesses and around three million people - and supplies nearly 830 million litres of drinking water per day.
It is regulated under the Water Industry Act 1991 as amended by the Water Act 2014.
History.
Welsh Water originated from the privatisation in 1989 of water supply and waste water arms of the Welsh Water Authority which itself had its origins in the Welsh National Water Development Authority that was created by the 1973 restructuring of the water industry in England and Wales.
Welsh Water Authority was privatised by stock market flotation in 1989, along with the other nine regional water authorities, which provided the company with a substantial cash surplus for some years, which it used to diversify in a wide range of sectors including leisure (Hotels, Fishing etc.). It renamed itself Hyder in 1996 after taking over a local electricity company (SWALEC) and becoming a water and electricity multi-utility.
However, in 1999/2000, following the Windfall Tax on utility profits and the 1999 Ofwat price review, Hyder got into financial difficulties which led to its breakup following a takeover battle. Western Power Distribution purchased Hyder on 15 September 2000 with a view to acquiring its electricity distribution business, and rapidly sold off Hyder's other assets. Dŵr Cymru Welsh Water was sold, along with £1.85 billion of Hyder debt, for £1 by WPD to Glas Cymru, a company set up by Nigel Annett and Chris Jones with the support of the company's first chairman Lord Burns to run the company for public benefit. Under the terms of its licence, Glas Cymru, a company limited by guarantee, may not operate in sectors other than water.
Business.
Measured by turnover, Welsh Water is the fifth-largest company based in Wales and employs more than 3,500 people.
Its asset base is valued at more than £26 billion - and includes:
Coverage.
In general, it provides services and operates across Wales from the catchments of the River Dee, River Clwyd in the north, round to the River Usk and River Wye in the south, and everything to the west of these catchments. This means that it includes part of the Wirral and Cheshire, and also parts of Gloucestershire, and Herefordshire, particularly Hereford. It excludes the area of Wales drained by the River Severn, which is instead served by Severn Trent. It also excludes those areas that were supplied by private water utilities such as Dee Valley Water which operated in the River Dee catchment supplying the Chester and Wrexham areas with water but is now a subsidiary of Severn Trent.
Not-for-profit status.
In 2001, Welsh Water became a not-for-profit organisation with no shareholders. This differentiates it from all the other Water companies operating in England and restores it to the same organisational status as water supply utilities in Scotland and the pre-privatisation water supply undertakings in England.
Under Glas Cymru’s ownership, the company's assets and capital investment are financed by bonds and retained financial surpluses. The Glas Cymru business model aims to reduce Welsh Water’s asset financing cost, the water industry’s single biggest cost. Financing efficiency savings to date have largely been used to build up reserves to insulate Welsh Water and its customers from any unexpected costs and also to improve credit quality. As of 2019, the company has the strongest credit ratings among the England and Wales-based water and sewerage companies Water industry.
When it was established as a not-for-profit company, Welsh Water had a gearing level (the ratio of net debt to Regulatory Capital Value) of around 93%. Since 2001, the company has reduced this level to around 60% in 2019-2020.
Not-for-profit 'dividends'.
Part of Welsh Water's not-for-profit model means any surplus money is reinvested back into the business or into customer services, or to reduce customer bills. To date, around £450 million has been reinvested in such ways.
Visitor attractions and reservoirs.
Welsh Water owns more than 90 dams and reservoirs across its areas of operation - including a number of flagship visitor attractions. These generally provide access to the reservoir and surrounding land, but also provide visitor centres, leisure facilities, walking routes, and cafes. Their main visitor attraction sites are:
In January 2016, following the scrapping of Western Power Distribution plans to redevelop Llanishen Reservoir for housing, Welsh Water acquired both Llanishen and Lisvane Reservoirs from steel company CELSA Group on a 999-year lease, which allows the company to use them for water supply and recreational purposes while also allowing CELSA to continue to take its water supply from the Lisvane Reservoir.
It has also submitted plans for the re-development of Llanishen reservoir, and its adjacent Lisvane reservoir, in the north of Cardiff in November 2020. If accepted, the redevelopment would include the construction of a visitor centre, watersports centre, biodiversity facilities, and education hub.


Eduard Aule

Eduard Georg Aule (28 December 1878 – 7 March 1947) was an Estonian banker and politician.
Born in the Kabala manor in Viljandi County on 28 December 1878 (16 December OS), Aule attended Tartu Reaalkool and studied commerce at Riga Polytechnical Institute.
He later worked as a banker.
He was elected to the Estonian Provincial Assembly, which governed the Autonomous Governorate of Estonia between 1917 and 1919; he served until 20 November 1918, when he stepped down and was replaced by Jüri Parik. He was also elected to the Asutav Kogu (Constituent Assembly) as a member for the Estonian Rural People's Union (; EMRL) party, but stepped down on 23 April 1919, and was replaced by Jaan Raamot. In the meantime, Aule briefly served as Minister of Food, between 6 February 1919 and 9 May 1919.
Aule was President of the Bank of Estonia between 1921 and 1925 and sat on the board of other banks. Between 1923 and 1940, he was treasurer of the Estonian Olympic Committee, and in 1941 moved to Germany before returning to Tallinn to serve in the municipality's Economic and Finance Directorate between 1942 and 1944. He left Estonia that year, and died on 7 March 1947 in Goslar, West Germany.


George Blowers

George Blowers (March 5, 1906 – October 19, 1969) was an American banker. A Harvard graduate, he became governor of the state banks of Liberia, Ethiopia and Saudi Arabia. During his career he was responsible for introducing two new currencies and represented Ethiopia at the Bretton Woods Conference.
Early career and Liberia.
Born on March 5, 1906 in Pineville, Kentucky, Blowers graduated from Harvard University before gaining a job at the National City Bank in New York City in 1928. In 1938 he became general manager of the Bank of Monrovia in Liberia, during which time he was responsible for changing the country's currency from the British West African pound (pegged to the Pound Sterling) to the Liberian dollar (pegged to the US dollar). The Smithsonian Institution's 1940 National Zoological Park expedition to Monrovia met with Blowers and he presented his household pets, a red forest duiker, a civet cat and a West African linsang, to them for use as zoo exhibits. British Foreign Office staff writing to Anthony Eden in March 1942 noted that Blowers adhered strictly to the American policy of neutrality, opposing attempts to enforce British control of capital in Liberia. Blowers, who could speak German, was known to have transferred German funds through Liberia to the United States.
State Bank of Ethiopia.
Blowers was appointed governor of the State Bank of Ethiopia in 1943 following a request by Emperor Haile Selassie for more American advisers to replace the British staff that predominated in his court. The 1942 Anglo-Ethiopian Agreement required Selassie to seek British approval prior to the appointment of any foreign staff. The British were not informed of the new appointments and the arrival of Blowers in Ethiopia came as something of an embarrassment to his British predecessor, who was still in post. Ethiopia formally renounced the treaty with Britain in 1944.
Blowers, in addition to his duties as governor, also acted as adviser to the Ethiopian Minister of Commerce, who preferred him over his official British adviser. Blowers attended the July 1944 Bretton Woods Conference that resulted in the introduction of the Bretton Woods system of foreign exchange. In 1945 he was responsible for the reintroduction of the Ethiopian birr to replace the East African Shilling.
Later career.
Blowers became deputy director of the Economic Cooperation Administration, set up to administer the US Marshall Plan for economic rejuvenation in Europe, in 1948. He became known as an expert of African economics and was appointed head of a UN mission to Libya, looking into its currency and banking system, in 1950. He later worked with the International Monetary Fund and in 1952 was appointed governor of the Saudi Arabian Monetary Agency (which functioned as the central bank but couldn't be described as such under Islamic law), having been recommended to the position by Arthur N Young, the director of Harry Truman's Point Four Program in the country. The bank started off with a fund of $10 million that was developed into billions of dollars of capital. During his time as governor he revised the Saudi riyal.
Blowers became director of the Export–Import Bank of the United States in Washington, DC in 1954. He became well known to Latin American governments, travelling to Peru, Ecuador and Bolivia on special missions. He retired from the bank in 1961 and died at Hempstead, Long Island, New York, on October 19, 1969.


Mohammed Said Nabulsi

Mohammed Said Nabulsi (November 1928 – 23 July 2013) was a Jordanian banker, economist and politician. He served as Governor of the Central Bank of Jordan two times, first from 1973–1985, and secondly from 1989–1995.
Career.
Nabulsi was born in November 1928 in November 1928 in Jaffa, Mandatory Palestine. He studied law at Damascus University between 1948 and 1952 and received a Ph.D. in Economics from Georgetown University after studying there between 1954 and 1956 and 1959 and 1960. Between 1958 and 1959 he studied at University of California, Berkeley.
From 1952 to 1968 Nabulsi worked for the Central Bank of Syria. After his time in Syria Nabulsi moved to Jordan, where he went to work at the Central Bank of Jordan. While at the same working as a lecturer for the University of Amman. In 1972 he joined the government of Prime Minister Ahmad al-Lawzi as Minister of National Economy. He served for one year, when he became Governor of the Central Bank of Jordan, at this time he also stopped working as a lecturer at the university. After Zaid al-Rifai became prime minister in 1985, Nabulsi left his position and started working as an adviser to the International Monetary Fund. During this time he also headed the United Nations Economic and Social Commission for Western Asia, and was an Under Secretary General. In 1989 he once more became the Governor of the Central Bank of Jordan after being appointed by Premier Zaid ibn Shaker. When Nabulsi was appointed as governor upon the request of King Hussein, his mission was to try to make an end to the economic bad times for Jordan. He tried to do so by strengthening Jordan's currency, the dinar. As the Central Bank lacked foreign currency Nabulsi ordered all banks to stash 35% of their foreign currency at the Central Bank. The Petra Bank, chaired by Iraqi Ahmed Chalabi, failed to do so. An investigation into the situation at Petra Bank uncovered that some of the bank's assets not really existed, leading to accusations of false accounting and embezzlement. The bank failed, resulting in a bail-out operation by the central bank worth $350 million in 1989. Chalabi was later sentenced to 22 years imprisonment with hard labour in absentia. Nabulsi's five-year term ended in 1994 and he was reappointed for another term. He resigned as of 1 January 1996.
During his career Nabulsi also worked for the United Nations Industrial Development Organization as a financial expert, and as a professor for the Syrian Private University.
Personal life.
Nabulsi married in September 1957 in Damascus to Naila Nabulsi. The couple had three children.
He died on 23 July 2013.


Willson v. Black-Bird Creek Marsh Co.

Willson v. Black-Bird Creek Marsh Co., 27 U.S. (2 Pet.) 245 (1829), was a significant United States Supreme Court case regarding the definition of the Commerce Clause in Article 1 sec. 8, cl. 3 of the U.S. Constitution. Willson, the owner of a sloop who was licensed under federal navigation laws, the Sally, broke through a dam that blocked his passage which was built by the Black-Bird Creek Marsh Co. and had been authorized to do so by Delaware law. The company brought a case against Willson, claiming Delaware authorized the building of the dam through a law which was passed under the police power of the state in order to clean up a health hazard and there was no legislation by Congress dealing with the same subject matter. Willson claimed that the law authorizing the building of the dam was a violation of the commerce clause. He believed he had a constitutional right to navigating coastal streams and Delaware's actions were motivated by private profits. Chief Justice John Marshall affirmed the lower court's decision, that because no federal law dealt specifically with the situation, and the state law did not violate Congress' Dormant Commerce Clause power, the state law was valid. He did note, however, that the dam might interfere with interstate commerce.


Shahqoli Khan Zanganeh

Shahqoli Khan Zanganeh (, died 1716), was a Kurdish nobleman, who served as the "vizier" of the Safavid king ("shah") Sultan Husayn (r. 1694–1722) from 1707 to 1716.
Family.
Shahqoli was the third son of Shaykh Ali Khan Zanganeh, who also served as "vizier" from 1669 to 1689, whose other sons were: Hossein Ali Khan Zanganeh, Suleiman Khan Zanganeh, Ismail Beg Zanganeh, Abbas Beg Zanganeh, and Abbas Qoli Beg Zanganeh. The family belonged to the Zanganeh tribe, a Sunni Kurdish tribe native to the Kermanshah Province.
Biography.
Shahqoli is first mentioned in 1680s, as being appointed the governor of Kermanshah Province. In 1689, his father died due to illness. One year later, a powerful and high-ranking aristocrat named Saru Khan Sahandlu, had 40 members of the Zanganeh tribe killed, which made Shahqoli protest to shah Suleiman I, stating that Saru Khan had humiliated the name of his deceased father by doing so. Suleiman forgave Saru Khan, due to the good relation they had. However, this was soon to end: in 1691, Suleiman had Saru Khan beheaded due to having an love relationship with Maryam Begum, the aunt of Suleiman.
The shah then appointed Shahqoli as the head of the royal bodyguard ("qurchi-bashi"), thus succeeding Saru Khan. After having been appointed to such as high-ranking office, a rivalry with the recently appointed "vizier" Mohammad Taher Vahid Qazvini followed. In 1694, Suleiman died and was succeeded by his son Sultan Husayn, who later in 1699, appointed a Turkoman member of the Shamlu tribe named Mohammad Mo'men Khan Shamlu, as the new "vizier".
In 1707, Shahqoli Khan was appointed as the new "vizier" of the empire. Shahqoli Khan died in 1716, and was succeeded by his son-in-law Fath-Ali Khan Daghestani. Shahqoli had a son, also named Shaykh Ali Khan, who although did not reach the same height of power as his father and grandfather, still served in high-office under the Safavids.


BLIPS

BLIPS is an acronym for "Bond Linked Issue Premium Structure", or "Bond Linked Investment Premium Strategy". It is a type of tax shelter involving investors who take out bank loans that the government considers illegitimate. These loans are then shifted to partnerships to claim tax losses.
BLIPS are invalid in the eyes of the Internal Revenue Service (IRS).
History.
BLIPS represent one of four abusive tax shelters that the Senate Permanent Subcommittee on Investigations investigated in 2003. The Subcommittee found that KPMG had sold to at least 350 people from 1997 to 2001, earning fees of $124 million. Those shelters cost the Treasury at least $1.4 billion in unpaid taxes, according to the subcommittee. In the investigation, KPMG argued that investors knew they were taking a risk that the IRS might not accept the claims.