Abdul Rahman Hassan Azzam

Abdul Rahman Hassan Azzam () (8 March 1893 – 2 June 1976), also known as Azzam Pasha, was an Egyptian diplomat and politician. He was the first Secretary-General of the Arab League, from 22 March 1945 to September 1952.
Azzam also had a long career as an ambassador and parliamentarian. He was an Egyptian nationalist, one of the foremost proponents of pan-Arab idealism, and opposed the partition of Palestine.
Family and early life.
Abd al-Rahman Azzam's father, Hassan Bey, was born into an Arab family which became prominent during the first half of the nineteenth century in Shubak al-Gharbi, a village near Helwan (south of Cairo). His grandfather, Salim Ali Azzam, was one of the first Arabs to become director of the southern Giza Governorate; his father, Hassan Salim Azzam, was also active in many regional governing bodies. Azzam's mother, Nabiha, was also descended from a distinguished family. Her father, Khalaf al-Saudi, was a landowner and shaykh and her mother's family descended from several Arabian Peninsula tribes.
According to biographer Ralph Coury, scholars and others have concluded that Azzam's "Peninsular" origins explain his later assumption of Arab identity. As early as 1923, a British official wrote: "The Azzam family, though settled in Egypt for some generations, come of good old Arab stock, and have always clung tenaciously to Arab traditions and ideals of life", adding, "in estimating Abdul Rahman's character, his early up-bringing and his Arab blood must never be forgotten." However, Coury writes that the Azzams were completely assimilated into village life and did not see themselves as different from other Egyptians. Azzam once said, "We were not brought up with a strong consciousness of Bedouin descent. We were Arabs because we were 'sons' or 'children' of the Arabs in contrast to the Turks, but the term 'Arab' as such was used for the Bedouin and we would not apply it to one another."
Childhood and education.
Abd al-Rahman Azzam, the eighth of twelve children, was born on 8 March 1893, in Shubak al-Gharbi. His family were "fellahin dhwati" ("notable peasants"), whose position was determined by land, wealth, and political power. The Azzam household was frequently home to gatherings of the village elite, and he developed an interest in politics at an early age. According to his brother, Abd al-Aziz Azzam, Azzam was a "born politician" who would stand at the top of the stairs as a child and give political speeches to his siblings.
In 1903, the Azzam family moved to Helwan to facilitate Hassan Bey's attendance at government meetings in the city. The effendis who were frequent visitors to Shubak were now neighbors, and the friendships which quickly developed between the effendi children and Azzam led him to insist on attending a secular primary school ("ibtidaiyyah") instead of the Azhar. Azzam remained in Helwan through secondary school and, upon graduation, decided to study medicine. About his decision, he said: "I wanted to be active in politics and I thought that I could practice medicine wherever that struggle might lead." In 1912 Azzam left Egypt for London, where he enrolled in St. Thomas’ Hospital Medical School.
In London Azzam joined the Sphinx Society, a political group where he quickly became prominent. However, after his first year of study he grew concerned with developments in the Balkans and felt compelled to contribute to the Ottoman cause. Unsure of the form that contribution would take, Azzam decided to leave London for the Balkans and spent considerable time in Istanbul, Albania, and Anatolia. During his travels, Azzam connected with like-minded political activists and spoke with many non-Egyptian Arabs.
Back in Egypt, he was banned by occupation authorities from returning to England because of his nationalist activities there and in Egypt; arrangements were made for him to attend the Cairo Medical School of Qasr al-Ayni. While studying in Cairo, Azzam became disaffected with the British occupation; this revived his desire to leave the country and join the Ottomans.
Libyan resistance: 1915–1923.
Azzam actively participated in the Libyan resistance against the Italians from 1915 to 1923. In December 1915, he left Egypt to join Nuri Bey and a group of Ottoman officers who were leading a Senussi army against the British. After fighting ceased and Sayyid Idris and the British signed a peace treaty in 1917, Nuri Bey and Azzam moved to Tripolitania in the hope of developing a centralized authority. On 18 November 1918, leaders met at al-Qasabat and proclaimed the Tripolitanian Republic. After negotiations between the Italians and Tripolitanian chiefs, on 1 June 1919 the Fundamental Law of Tripolitania (granting the natives full Italian nationality) was enacted. Despite the agreement, the Italians refused to implement the law. This led to the formation of the National Reform Party, led by Azzam, to pressure the Italians to uphold the law. The Italians refused to concede, and in January 1923 Azzam accompanied Sayyid Idris into exile in Egypt. By 1924, opposition in Tripolitania had waned.
Azzam credited his tenure in the early Libyan resistance movement for his turn to Arabism. In 1970, he said: "When I was a boy, I was an Egyptian Muslim. Being an Egyptian and Muslim didn't change. But from 1919 on, with Syria and Iraq gone, I started talking of Arabism. Living with the bedouin, etc. worked gradually to make me a supporter for something Arabic. The Tripolitanian Republic decisively marked the shift to Arabism."
Wafd membership: 1923–1932.
Azzam's return to Egypt coincided with a number of debates by the Wafd, the palace and the British about the new constitution. Hoping to reestablish himself in the country, he ran for office in 1924 and was elected to parliament as a member of the Wafd. As a parliamentarian, Azzam became well-known through his articles for the party's newspaper.
Due to his time in Libya, the Wafd often chose him to represent the party at formal meetings and international conferences. Azzam's most important trip as an Egyptian Wafd representative was to the 1931 General Islamic Conference in Jerusalem. Because members of the Azhar and Sidqi ministry were strongly opposed to two of the conference's major agenda items–the creation of a new Islamic university in Jerusalem and restoration of the caliphate–the Egyptian government refused to send an official delegate to the meeting. However, Azzam and several other members of the Egyptian opposition attended the conference. Taking an active part in the proceedings, he was elected to the congress' executive committee and discussed Arab nationalism at length. This conference is one of the first instances in which Arab nationalists included Egypt in the pan-Arab nation.
In November 1932, Azzam and several other party members left the Wafd. Although he was viewed by some as a traitor, he maintained that changes in his opinions were the reason. Azzam's reputation for knowledge of Arab affairs was valued, and he soon became a member of the palace entourage surrounding King Faruq.
1932–1945.
After breaking with the Wafd, Azzam joined the elite ranks of liberals—all Wafd and Liberal Constitutionalist dissidents—who had supported Liberal proposals for a coalition government in 1932. In 1936, 'Ali Mahir appointed him Egyptian Minister to Iraq and Iran, and in 1937 the Nahhas ministry increased his diplomatic ministry to include Saudi Arabia.
Secretary-General of the Arab League 1945–1952.
In 1945, Azzam was selected as the first Secretary-General of the Arab League during World War II. One of his first acts as Secretary-General was to condemn the 2–3 November 1945 anti-Jewish rioting in Egypt in which Jewish- and other non-Muslim-owned shops were destroyed and the Ashkenazi synagogue in Cairo's Muski quarter was set ablaze.
In a 2 March 1946 address to the Anglo-American Committee of Inquiry into the problems of European Jewry and Palestine, Azzam explained the Arab League’s attitude towards Palestine and rejected the Zionist claim to the region:
Our brother has gone to Europe and to the West and come back something else. He has come back with a totally different conception of things, West and not Eastern. That doesn't mean that we are necessarily quarreling with anyone who comes from the West. But the Jew, our old cousin, coming back with imperialistic ideas, with materialistic ideas, with reactionary or revolutionary ideas and trying to implement them first by British pressure and then by American pressure, and then by terrorism on his own part – he is not the old cousin and we do not extend to him a very good welcome. The Zionist, the new Jew, wants to dominate and he pretends that he has got a particular civilizing mission with which he returns to a backward, degenerate race in order to put the elements of progress into an area which wants no progress. Well, that has been the pretension of every power that wanted to colonize and aimed at domination. The excuse has always been that the people are backward and that he has got a human mission to put them forward. The Arabs simply stand and say NO. We are not reactionary and we are not backward. Even if we are ignorant, the difference between ignorance and knowledge is ten years in school. We are a living, vitally strong nation, we are in our renaissance; we are producing as many children as any nation in the world. We still have our brains. We have a heritage of civilization and of spiritual life. We are not going to allow ourselves to be controlled either by great nations or small nations or dispersed nations.
Azzam attended an Arab League council meeting in Bloudan, Syria, between 12 and 18 June 1946, which discussed the dangers of a possible confrontation with the Zionist movement and the Arab support to the Palestinians. He later returned to Egypt where he met J. Rives Childs, and informed him of Arab decision to discuss Palestine with the United Kingdom which controlled the ground.
However, Azzam visited Paris twice in 1946 and 1951, where he discussed Tunisia, Algeria and Morocco issues which brought him criticism from the French journals.
On 11 May 1948, Azzam warned the Egyptian government that because of public pressure and strategic issues it would be difficult for Arab leaders to avoid intervention in the Palestine War and Egypt might find itself isolated if it did not act in concert with its neighbors. Azzam believed that King Abdullah of Jordan had decided to move his forces into Palestine on 15 May, regardless of what the other Arabs did, and would occupy the Arab part of Palestine (blaming other Arab states for failure). King Farouk resolved to contain Abdullah and prevent him from gaining further influence and power in the Arab arena. Six days after the Arab intervention in the conflict began, Azzam told reporters: "We are fighting for an Arab Palestine. Whatever the outcome the Arabs will stick to their offer of equal citizenship for Jews in Arab Palestine and let them be as Jewish as they like. In areas where they predominate they will have complete autonomy."
Controversy over "war of extermination" quote.
One day after the Israeli Declaration of Independence (14 May 1948), troops and volunteers from Syria, Iraq, Egypt and Transjordan entered Palestine and joined several thousand Palestinians. This marked the beginning of the 1948 Arab–Israeli War. Azzam reportedly said on that day (or on the eve of the war), "This will be a war of extermination and a momentous massacre which will be spoken of like the Mongolian massacres and the Crusades." The quotation was usually cited to a press conference in Cairo, broadcast (in some versions) by the BBC. In 1961, an Egyptian writer called the quotation "completely out of context": "Azzam actually said that he feared that if the people of Palestine were to be forcibly and against all right dispossessed, a tragedy comparable to the Mongol invasions and the Crusades might not be avoidable ... The reference to the Crusaders and the Mongols aptly describes the view of the foreign Zionist invaders shared by most Arabs."
In 2010, doubt of the quotation's source was voiced by Joffe and Romirowsky and Benny Morris. It was the subject of an article by David Barnett and Efraim Karsh. Azzam's quote was found to have originated in an 11 October 1947 interview for the Egyptian newspaper "Akhbar el-Yom": "Personally I hope the Jews do not force us into this war because it will be a war of elimination and it will be a dangerous massacre which history will record similarly to the Mongol massacre or the wars of the Crusades. I think the number of volunteers from outside Palestine will exceed the Palestinian population."
At the time of Azzam's interview, the United Nations Special Committee on Palestine had presented its report recommending that Palestine be partitioned into Arab and Jewish states and a "corpus separatum" around Jerusalem. However, no decision had yet been made by the UN and no Arab state had formally decided on military intervention in Palestine. After the partition resolution was passed, the comparison of the Zionists to the Mongols and crusaders was repeated when Azzam told a student rally in Cairo in early December 1947: "The Arabs conquered the Tartars and the Crusaders and they are now ready to defeat the new enemy", echoing what he had said to a journalist the previous day.
The "Akhbar el-Yom" quotation, without its initial caveat, appeared in English in a February 1948 Jewish Agency memorandum. Over the next few years, the same partial quotation appeared (with its correct 1947 source) in several books; however, by 1952 many publications (including one by the Israeli government) had moved its date to 1948. With this inaccurate source, it has appeared in hundreds of books and thousands of websites.
Views on Arab unity.
According to historians Israel Gershoni and James Jankowski, Azzam denied that the Egyptian nation was a continuation of Pharaonic Egypt. Instead, he believed that "modern Egypt had been shaped primarily by 'Arab religion, customs, language, and culture and asserted a linguistic basis for Egyptian identification with the Arabs.
Personal life.
One of Azzam's daughters married to Mohammed bin Faisal Al Saud.
Death.
He died on 2 June 1976 in Cairo, and was later buried at Azam Mosque in Helwan.
Writings.
In his introduction to "The Eternal Message of Muhammad" (published by Azzam in Arabic in 1938 as "The Hero of Heroes or the most Prominent Attribute of the Prophet Muhammad"), Vincent Sheean writes: "In Damascus as well as in Djakarta, Istanbul and Baghdad, this man is known for valour of spirit and elevation of mind ... he combines in the best Islamic mode, the aspects of thought and action, like the Muslim warriors of another time who are typified for us Westerners by the figure of Saladin." In the book Azzam extols Muhammad's virtues of bravery, love, the ability to forgive, and eloquence in pursuit of the diplomatic resolution of conflict, calling Islam incompatible with racism or fanatical attachment to "tribe, nation, color, language, or culture".
Malcolm X's reading of "The Eternal Message of Muhammad" and his meeting with Azzam are recounted in his autobiography. These events marked the point at which he turned towards orthodox, traditional Islam.


Anvar Saidenov

Anvar Saidenov (, born September 19, 1960) was the chairman of the National Bank of Kazakhstan from 2004 to 2009.
Saidenov was born in Moscow and attended Moscow State University, being graduated in 1982. From 1993-1996 he worked at the European Bank for Reconstruction and Development in London, during which time he also earned an MS in Economics and Finance at the University of London. He then returned to Kazakhstan, where from 1996-1998 he served as the deputy chairman of the National Bank of Kazakhstan. From 1998-2000 he held economic posts throughout the country, including a turn as Vice-Minister of Finance.
From 2000-2002 Saidenov served as the chairman of Halyk Bank. In 2002 he returned to the national National Bank to again serve as deputy chairman, and was appointed as chairman in 2004. He served until 2009.


Butterfield Overland Mail in Texas

In Texas, the Butterfield Overland Mail service created by Congress on March 3, 1857, operated until March 30, 1861. The route that was operated extended from San Francisco, California to Los Angeles, then across the Colorado Desert to Fort Yuma, then across New Mexico Territory via, Tucson and Mesilla, New Mexico to Franklin, Texas, midpoint on the route. The route through Texas followed first the northern route to the Pecos River and downstream to Horse Head Crossing. The route in West Texas was changed in 1859, in order to secure a better water supply on the route and to provide mail service to a more settled area, the stages between Franklin and the Pecos River followed the San Antonio-El Paso Road to Camp Stockton and then turned east to Horsehead Crossing. From Horsehead Crossing the route crossed Texas to the Red River and into Indian Territory. In 1860 the route was changed to another route from Jacksboro to Sherman via Decatur due to the building of a new toll bridge at Bridgeport, that avoided delays crossing the West Fork of the Trinity River when it was flooded. From Colberts Ferry the route went on to Fort Smith, then up across Arkansas and southwest Missouri to Tipton with the final leg by train to St. Louis. The Texas mail route was so long that the route there, like that in California, was divided into two divisions each under a superintendent.
5th Division Route.
At first the 5th Division route left Franklin to run due east thirty miles to Hueco Tanks, thirty six miles to Cornudas de Los Alamos then east northeast fifty-six miles to Pinery Station. Subsequently, stations were added between Hueco Tanks and Cornudas de Los Alamos at Ojos de los Alamos, and at Crow Springs between Cornudas de Los Alamos and Pinery. From Pinery, the route then ran twenty-four miles east to Delaware Springs Station, then forty miles down Delaware Creek nearly to its junction with the Pecos River, and across Pope's Crossing to Pope's Camp. It then ran sixty five miles down the east bank of the Pecos, to Emigrant Crossing Station and onward fifty-five miles to Horsehead Crossing. Sections of this route, including Pinery Station, are preserved as part of Guadalupe Mountains National Park, and have been listed on the National Register of Historic Places.
From Horsehead Crossing the trail ran seventy waterless miles east northeast across the Llano Estacado to the headwaters of the Middle Concho River, then northward, about thirty miles through the vicinity of modern Carlsbad, to a camp or station;, then twenty-two miles to Grape Creek Station near the south line of present Coke County; to Fort Chadbourne in what is now Coke County.
In August 1859, the route in West Texas was changed from the upper route in order to secure a better water supply on the route, with more security from the Army and to provide mail service to a more settled area, by using the San Antonio-El Paso Road from Franklin to Camp Stockton before cutting across to link up with the rest of the route at Horsehead Crossing. This entailed abandoning the investment in the well constructed stations on the old route, and building some on the new route. Although this was mitigated when an arraignment was made to use the stations of George H. Giddings' San Antonio-El Paso Mail along that route. Losses from this change and debt taken on from a delay of postal revenue, eventually led the investors in the Overland Mail Company to take control and dismiss John Warren Butterfield in 1860.
The stages between Franklin and the Pecos River now would follow the San Antonio-El Paso Road down the Rio Grande, 14 miles from Franklin to Ysleta, then passing 12 miles through Socorro to San Elizario, then on 10 miles to Camp Hawkins Station, 24  miles to Birchville Station, 15 miles to Camp Rice Station, then 18 miles to Fort Quitman. Moving eastward away from the river at Fargo Station 5 miles below Fort Quitman, the route traveled 25 miles to Eagle Spring, 19 miles to Van Horns Wells, then a waterless 33 miles to Deadman's Hole, 18 miles to Barrel Springs, another 18 miles to Fort Davis. From Fort Davis Station the route proceeded down through Limpia Canyon to Limpia Station, Barrilla Springs, then 34 miles to Leon Springs and 8 miles on to Camp Stockton. 11 miles east of Camp Stockton the route reached Camp Pleasant then crossed the plain 23 miles to Horsehead Crossing where a ferry carried the coaches across the Pecos River to Horsehead Crossing Station.
6th Division Route.
The 6th Division route ran from Fort Chadbourne, twelve miles to the north across Valley Creek to Station #1 then sixteen miles to Mountain Pass Station, then thirty miles, past the route of the Texas and Pacific Railway, a mile west of the site of present Tye, to Fort Phantom Hill, then twelve miles more to Smith's Station, twenty six miles to Clear Fork station, thirteen miles to Franz's Station and then twenty-two miles to Fort Belknap. From Fort Belknap the line turned eastward sixteen miles to Murphy's Station (near present Graham, Texas), then nineteen miles to Jacksboro, Texas, sixteen miles to Earhart's Station, twenty-four miles to Davidson's Station, then seventeen miles to Gainesville, Texas, fifteen miles to Diamond's station (one mile west of the site of present Whitesboro), fifteen miles to Sherman and across the Red River at Colbert's Ferry, eight miles below Preston, Texas to Indian Territory.


John Dyke Acland

Colonel John Dyke Acland (18 February 1746 – 31 October 1778 ), of Tetton and Pixton in Somerset, was Tory Member of Parliament for Callington in Cornwall and fought in the American War of Independence in 1776.
Origins.
He was the eldest son and heir apparent of Sir Thomas Dyke Acland, 7th Baronet (1722-1785) of Killerton in Devon and Petherton Park in Somerset, by his wife Elizabeth Dyke (d.1753), daughter and heiress of Thomas Dyke of Tetton, Holnicote and Pixton in Somerset. The ancient Acland family, believed to be of Flemish origin, originated at the estate of Acland in the parish of Landkey in North Devon, where it is first recorded in 1155.
Career.
Acland was Colonel of the 1st Devon Militia, formed to protect Great Britain from a feared French invasion. In 1774 he was elected Member of Parliament for the rotten borough of Callington in Cornwall, and forcefully expressed his Tory views in parliament by virulently opposing the movement by the American colonists to obtain independence following their complaint of "No taxation without representation". He poured scorn on those fellow MP's who sought to appease the colonists and called their proposed concessions "nugatory and humiliating" and certain to result in "a total convulsion of the British Empire". His vehemence is said to have alarmed even King George III himself, no friend of the revolutionary colonists. In his capacity as a Colonel of Militia and bypassing parliament, he presented a loyal address to the king in person promising him aid whenever and wherever called upon to put down sedition and in which he portrayed the Whig opposition as rebels to the King's interests, akin to the American colonists. This action of his gained him the enmity of the Whig party. His wife's first cousin was the prominent Whig Charles James Fox, who criticised him savagely in Parliament. Whilst still a member of Parliament he purchased a commission as an officer in the 20th Regiment of Foot. At the State opening of Parliament in October 1774, the King spoke of a "rebellious war" which had been opened by the colonists who had fired shots at Lexington and Concord, and John Acland received the privilege of moving the formal vote of thanks to the King's Speech in the House of Commons. This he did in "fulsome and adulatory" terms, which were ill-received by the Whig opposition.
On 8 April 1776 and accompanied by his wife and his pet dog "Jack Ketch", he set sail in the "Kent" from Cork in Ireland for Canada as a major of Grenadiers in the 20th Foot, serving under his friend General John Burgoyne at the head of an army to reinforce the British troops. He was present with Burgoyne during his invasion of northern New York in 1777.
Prisoner of war.
On 7 October 1777 at the Battle of Bemis Heights, near Stillwater, New York he was shot through the legs by the Americans and was taken prisoner. His wife, Lady Harriet, was allowed to enter the American camp to nurse her husband and was well-treated by the American soldiers.
Acland was grateful for the treatment received when recuperating as a prisoner of war, so much so that following his return to England he challenged a certain Lieutenant Lloyd to a duel when the latter spoke poorly of Americans at a dinner party. Although he survived the duel, he caught a cold during it from which he died at Pixton Park in 1778.
Marriage and children.
In 1770 he married Lady Christian Henrietta Caroline Fox-Strangways (d.1815), (known as "Harriet") a daughter of Stephen Fox-Strangways, 1st Earl of Ilchester and his wife, the former Elizabeth Horner. Harriet was a first cousin of the leading Whig statesman Charles James Fox, a political opponent of her husband. She accompanied her husband on his military service in Canada, and displayed exceptionally courageous behaviour, for which she later became celebrated. Not only did she insist on following her husband as the campaigning progressed, but insisted on crossing over the Hudson River into enemy territory in order to nurse her prisoner-of-war husband for nine weeks. An oil painting, now at Killerton, was made illustrating her exploit of crossing the St Lawrence, and was exhibited at the Royal Academy in London, and was made into a widely published engraving.
Acland and his wife had the following children:
Death and succession.
He died aged 34 on 31 October 1778, and thus predeceased his father. He left an infant son born in 1778, aged only a few months old, who died 7 years later, having inherited the baronetcy from his grandfather, and a daughter Elizabeth "Kitty". His widow Harriet lived on at Pixton until 1796 when it was given to her daughter as part of her marriage settlement, and then at Tetton, until her death in 1815.


Democratic response to 2006 State of the Union address

The response to the 2006 State of the Union Address was delivered by Virginia Governor Tim Kaine on January 31, 2006, after United States President George W. Bush delivered his 2006 State of the Union address. The theme of Kaine's speech, "A Better Way", advocates the Democratic Party's policies and states' rights. Kaine delivered the speech from Virginia's historic Executive Mansion in Richmond and the speech was televised nationwide.
Introduction.
Kaine begins his speech by recalling his work as a Catholic missionary in Honduras where he learned the value of measuring one's "life by the difference [one] can make in someone else's life." Kaine mourns the loss of Coretta Scott King, as Bush did in the introduction of his speech, who "embodied that value."
Kaine's diction emphasizes the role of elected officials as public servants, portraying the duties of office as a "higher calling" and referring to the federal government's duty to "serve the American people" as a frustrated "mission" due to the Bush administration's "poor choices and bad management."
Criticism of government policies.
Kaine attacks the government's most controversial actions and positions; the Federal response to Hurricane Katrina ("See also:" Criticism of government response to Hurricane Katrina), "Families in the Gulf Coast see [the government's mistakes] as they wait to rebuild their lives", the United States economy, "Americans who lose their jobs see [the government's mistakes] as they look to rebuild their careers", the Iraq War, "and our soldiers in Iraq see that as they try to rebuild a nation".
Bipartisan cooperation.
Both Bush and Kaine emphasize the need for bipartisan cooperation.
Kaine, "As Americans, we do great things when we work together. Some of our leaders in Washington seem to have forgotten that."
Bush, "... even tough debates can be conducted in a civil tone... our differences cannot be allowed to harden into anger... we must act in a spirit of good will and respect for one another."
Kaine's theme: "A better way".
Kaine offers "good news", stating that "Virginia and other states" were succeeding "by focusing on service, competent management and results", the theme of his speech. He also points out that, under previous Governor Mark Warner, Virginia was voted "Best Managed State", in order to draw a stark contrast with the financial state of the nation, saying a citizen has "a right to expect that your government can deliver results".
He then poses a series of hypothetical situations, linked through the anaphoric repition of the word "When", invoking the September 11, 2001 attacks, Hurricane Katrina and attacking the quality of Education in the United States. He particularly criticizes the government's fiscal policy, insisting that citizens "have a right to expect [the] government to be fiscally responsible, pay the bills and live within its means", a criticism of governmental corruption and the trillion dollar "staggering national debt". Kaine accuses Bush mismanagement, citing his tax cuts, and paralleling the "huge surpluses" of the Clinton administration with the "massive deficits" of the Bush administration.
Kaine asks rhetorically, "Why should we allow this administration to pass down the bill for its reckless spending to our children and grandchildren?" and repeats his theme, "There's a better way."
Success in Virginia.
Kaine switches his focus from an international level to a state level, discussing the fiscally successful budget reached "Two years ago in Virginia" by Republican legislators and former Democratic Virginia governor Mark Warner. Kaine's first points attack inadequate "service... management and results." The second part of the speech is outlined by Kaine's success on a state level and Bush's mistakes on a national level, "By focusing on results we were able to... protect the essential services that families rely on: education, health care, law enforcement."
Education.
Kaine denounces the No Child Left Behind Act for "wreaking havoc on local school districts" and blames Bush for allegedly underfunding the act while "refusing to let states try innovative alternatives" and "cutting billions of dollars from the student loan programs."
He repeats his theme a third time and recalls how "governors from across the country worked together in a bipartisan fashion to reform the senior year of high school", a sentence that repeats the bipartisanship, working, and reform emphasized in his comment on the Virginia budget, "Democrats and Republicans worked together to reform our budget".
He notes how states "are working to make... pre-kindergarten accessible to every family."
Announcing a Democrat plan "to educate 100,000 new engineers, scientists and mathematicians in the next four years", Kaine proposes an alternative policy to the Bush administration. However, his statement remains vague as he never actually states the Democrat's plan. Instead, he points to "record investments in education... [resulting in] more accredited schools [and] better student test scores", and attributes this to Virginian bipartisan cooperation.
Political significance.
The success of Democrats in Virginia, notably Kaine's election as Governor, provided a success story for national Democrats to begin 2006, which was to be a year of a Congressional midterm election. The success of Kaine and Warner in rebuilding the Democratic Party in the Republican-leaning state was rewarded with Kaine's response to President Bush, which highlighted the competence of Virginia's Democratic administration with the perceived incompetence of the Bush Administration in the wake of Hurricane Katrina. The political success and strength of Virginia Democrats would be heightened the following January, when newly elected Virginia Senator Jim Webb would be chosen to deliver the Democratic response to the 2007 State of the Union address. In continuing the tradition of a Democrat from a red state delivering the Democratic response, Kansas Governor Kathleen Sebelius gave the response to the 2008 State of the Union address. Webb's election over incumbent Senator George Allen in the 2006 Virginia Senate election tipped control of the United States Senate to the Democratic Party for the first time in four years and, with the election of a Democratic majority in the US House of Representatives, resulted in the first Democratic-controlled Congress in twelve years.


Job-seeking expense tax deductions

Generally, expenses related to the carrying-on of a business or trade are deductible from a United States taxpayer's adjusted gross income. For many taxpayers, this means that expenses related to seeking new employment, including some relevant expenses incurred for the taxpayer's education, can be deducted, resulting in a tax break, as long as certain criteria are met.
First, such costs must qualify as expenses, as contemplated by the U.S. tax code, and not as capital expenditures (generally, a capital expenditure is a cost associated with producing a benefit with a useful life of more than one year, such as a long-term investment). Second, if the cost qualifies as an expense, it may be deductible if it can be characterized as an "ordinary and necessary expense paid or incurred during the taxable year in carrying on any trade or business..." For purposes of the average taxpayer looking to deduct expenses related to seeking new employment, the relevant inquiry is whether the new position sought can be deemed to be "carrying on" the prior business or trade of that taxpayer, as costs associated with starting up a new business or trade are not immediately deductible and are subject to a special form of amortization.
Whether seeking new employment, and the costs associated therewith, can be deemed as "carrying on" a prior business or trade is fact- and context-specific. However, the IRS, with approval of the courts, has insisted on a high degree of sameness between the new position sought and the previous means of employment. This means that if substantial differences exist between the duties, tasks, and activities of the taxpayer's prior job and those of the job he now seeks, then the expenses incurred will be deemed to be start-up costs, and not subject to immediate deduction. Similarly, if the taxpayer has undergone a significant hiatus between the prior position of employment and the one now sought, expenses will not be considered "carrying on" the business or trade. Again, whether a hiatus would be considered significant is highly fact- and context-specific. The relevant inquiry here should be whether there is a "substantial lack of continuity." If the taxpayer terminated his previous employment with little indication of seeking a new position in the same profession, it is likely that time spent unemployed or employed in a different field would prevent the taxpayer from claiming that he was "carrying on" his prior business or trade.
The ability to deduct the costs of seeking new employment is a distinct advantage for many taxpayers, but one likely to be overlooked. To recap, a taxpayer may only deduct the costs associated with seeking new employment when that taxpayer is searching for a new employer in substantially the same profession. Further, a significant hiatus between jobs may bar claiming this type of deduction.


European Exchange Rate Mechanism

The European Exchange Rate Mechanism (ERM) II is a system introduced by the European Economic Community on 1 January 1999 alongside the introduction of a single currency, the euro (replacing ERM 1 and the euro's predecessor, the ECU) as part of the European Monetary System (EMS), to reduce exchange rate variability and achieve monetary stability in Europe.
After the adoption of the euro, policy changed to linking currencies of EU countries outside the eurozone to the euro (having the common currency as a central point). The goal was to improve the stability of those currencies, as well as to gain an evaluation mechanism for potential eurozone members. As of January 2021, three currencies participate in ERM II: the Danish krone, the Croatian kuna and the Bulgarian lev.
Intent and operation of the ERM II.
The ERM is based on the concept of fixed currency exchange rate margins, but with exchange rates variable within those margins. This is also known as a semi-pegged system. Before the introduction of the euro, exchange rates were based on the European Currency Unit (ECU), the European unit of account, whose value was determined as a weighted average of the participating currencies.
A grid (known as the Parity Grid) of bilateral rates was calculated on the basis of these central rates expressed in ECUs, and currency fluctuations had to be contained within a margin of 2.25% on either side of the bilateral rates (with the exception of the Italian lira, the Spanish peseta, the Portuguese escudo and the pound sterling, which were allowed to fluctuate by ±6%). Determined intervention and loan arrangements protected the participating currencies from greater exchange rate fluctuations.
United Kingdom Chancellor of the Exchequer Denis Healey reportedly chose not to join the ERM in 1979 owing to concerns that it would benefit the German economy by preventing the Deutsche mark from appreciating, at the expense of the economies of other countries. The UK did join the ERM in October 1990 under Chancellor John Major, in a move which at the time was largely supported by business and the press, but was forced to leave again two years later on Black Wednesday.
Historical exchange-rate regimes for EU members.
The chart below provides a full summary of all applying exchange-rate regimes for EU members, since the European Monetary System with its Exchange Rate Mechanism and the related new common currency ECU came into being on 13 March 1979. The euro replaced the ECU 1:1 at the exchange rate markets, on 1 January 1999. Between 1979 and 1999 the D-Mark functioned as a "de facto" anchor for the ECU, meaning there was only a minor difference between pegging a currency against the ECU and pegging it against the D-mark.
The eurozone was established with its first 11 member states on 1 January 1999. The first enlargement of the eurozone, to Greece, took place on 1 January 2001, one year before the euro had physically entered into circulation. The zone's next enlargements were with states that joined the EU in 2004, and then joined the eurozone on 1 January in the mentioned year: Slovenia (2007), Cyprus (2008), Malta (2008), Slovakia (2009), Estonia (2011), Latvia (2014), and Lithuania (2015).
All new EU members having joined the bloc after the signing of the Maastricht Treaty in 1992 are obliged to adopt the euro under the terms of their accession treaties. However, the last of the five economic convergence criteria, which need to be complied with in order to qualify for euro adoption, is the exchange rate stability criterion. This requires having been a member of the ERM for a minimum of two years without the presence of "severe tensions" for the currency exchange rate.
Irish pound breaks parity with pound sterling.
To participate in the ERM, Ireland had to break the Irish pound's parity with the pound sterling in 1979, because the pound sterling, which was not an ERM currency, appreciated against all ERM currencies shortly after the launch of the ERM. The continued parity between the Irish pound and the pound sterling would have taken the Irish pound outside its agreed band. To fulfill the ERM conditions, the Irish government was required to break the parity of the Irish pound with the pound sterling.
Pound sterling's forced withdrawal from the ERM.
The United Kingdom entered the ERM in October 1990, but was forced to exit the programme within two years after the pound sterling came under major pressure from currency speculators. The ensuing crash of 16 September 1992 was subsequently dubbed "Black Wednesday". There was some revision of attitude towards this event given the UK's strong economic performance after 1992, with some commentators dubbing it "White Wednesday".
Some commentators, following Norman Tebbit, took to referring to ERM as an "Eternal Recession Mechanism", after the UK fell into recession in 1990. The UK spent over £6 billion trying to keep the currency within the narrow limits with reports at the time widely noting that the controversial Hungarian-American investor George Soros's individual profit of £1 billion equated to over £12 for each man, woman and child in Britain and dubbing Soros "the man who broke the Bank of England".
Britain's membership of the ERM was also blamed for prolonging the recession at the time, and Britain's exit from the ERM was seen as an economic failure which contributed significantly to the defeat of the Conservative government of John Major at the general election in May 1997, despite the strong economic recovery and significant fall in unemployment which that government had overseen after Black Wednesday.
Increase of margins.
In August 1993, the margin was expanded to 15% to accommodate speculation against the French franc and other currencies.
History of the ERM II.
On 31 December 1998, the European Currency Unit (ECU) exchange rates of the eurozone countries were frozen and the value of the euro, which then superseded the ECU at par, was thus established.
In 1999, ERM II replaced the original ERM. The Greek and Danish currencies were part of the new mechanism, but when Greece joined the euro in 2001, the Danish krone was left at that time as the only participant member. A currency in ERM II is allowed to float within a range of ±15% with respect to a central rate against the euro. In the case of the krone, Danmarks Nationalbank keeps the exchange rate within the narrower range of ± 2.25% against the central rate of EUR 1 = DKK 7.46038.
EU countries that have not adopted the euro are expected to participate for at least two years in ERM II before joining the eurozone.
New EU members.
On 1 May 2004, the ten national central banks (NCBs) of the new member countries became party to the ERM II Central Bank Agreement. The national currencies themselves were to become part of the ERM II at dates to be agreed.
The Estonian kroon, Lithuanian litas, and Slovenian tolar were included in the ERM II on 28 June 2004; the Cypriot pound, the Latvian lats and the Maltese lira on 2 May 2005; the Slovak koruna on 28 November 2005.
These states have all since joined the eurozone, and hence left ERM II: Slovenia (1 January 2007), Cyprus (1 January 2008), Malta (1 January 2008), Slovakia (1 January 2009), Estonia (1 January 2011), Latvia (1 January 2014), and Lithuania (1 January 2015).
On 10 July 2020 it was announced that the Bulgarian lev (which had joined the EU on 1 January 2007) and Croatian kuna (which had joined the EU on 1 July 2013) would be included in the ERM II.
Current status.
As of 2021, three currencies participate in ERM II: the Danish krone, the Croatian kuna and the Bulgarian lev. The currencies of Sweden (the Swedish krona), the three largest countries which joined the European Union on 1 May 2004 (the Polish złoty, the Czech koruna, and the Hungarian forint), and Romania which joined on 1 January 2007 (the Romanian leu), are required to join in accordance with the terms of the applicable treaties of accession.
Sweden has voted in a referendum to stay out of the mechanism, despite being expected to join by the ECB, since Sweden has no opt-out like Denmark. EU members are required to join the ERM by the Maastricht convergence criteria.
Exchange rate bands.
In theory, most of the currencies are allowed to fluctuate as much as 15% from their assigned value. In practice, however, the currency of Denmark deviates very little.
Historical reference.
The former members of ERM II are the Greek drachma, Slovenian tolar, Cypriot pound, Estonian kroon, Maltese lira, Slovak koruna, Lithuanian litas and Latvian lats.


Ron Reagan

Ronald Prescott Reagan (born May 20, 1958) is an American liberal political commentator, writer, radio personality, television host, and dancer. He is a former radio host and political analyst for KIRO and Air America Radio, where he hosted his own daily three-hour show. He has also been a contributor to MSNBC. His liberal views contrast with those of his late father and conservative icon, President Ronald Reagan.
Early life.
Reagan was born and raised in Los Angeles, California, the son of Ronald Reagan and his second wife, Nancy Davis Reagan. The family lived in Sacramento while his father was governor, from 1967 His sister, Patti Davis, is five and a half years older. His elder brother Michael Reagan, adopted as an infant by Ronald Reagan and his first wife, Jane Wyman, is 13 years older. He also had two half-sisters born to Reagan and Wyman, Maureen Reagan (1941–2001) and Christine Reagan, who was born prematurely, on June 26, 1947, and died the same day. At an early age, his father, Ronald Reagan, often joked that they were related to every royal family with the name O'Regan in Europe. "Burke's Peerage" provided the Reagans with their family tree, which lacked any direct connection to European royalty.
Ron Reagan undertook a different philosophical and political path from his father at an early age. At 12, he told his parents that he would not be going to church anymore because he was an atheist.
Reagan attended and was expelled from The Webb School of California. He commented:
They [the school administration] thought I was a bad influence on the other kids. As I recall, the immediate reason was I went to a dance at a neighboring girl's school in a classmate's car. This was an infraction. They had been looking for an excuse. I didn't get caught at anything.
Reagan dropped out of Yale University in 1976 after one semester to become a ballet dancer. He joined the Joffrey Ballet in pursuit of his lifelong dream and participated in the Joffrey II Dancers, a troupe for beginning dancers, where he was mentored by Sally Brayley. "Time" wrote in 1980: "It is widely known that Ron's parents have not managed to see a single ballet performance of their son, who is clearly very good, having been selected to the Joffrey second company, and is their son nonetheless. Ron talks of his parents with much affection. But these absences are strange and go back a ways." Reagan and Nancy went to see Ron perform at the Lisner Auditorium on Monday, May 18, 1981. The elder Reagan commented in his White House diary on this day that Ron's performance was "darn good" and reminiscent of Fred Astaire.
Career.
In February 1986, Reagan hosted an episode of "Saturday Night Live".
Reagan became more politically active after his father left the White House in 1989. In contrast to his father, the younger Reagan's views were unabashedly liberal. In a 2009 "Vanity Fair" interview, Ron said that he did not speak out politically during his father's term because the press "never cared about my opinions "as such," only as they related to "him"", adding that he did not want to create the impression that he and his father were on bad terms because of political differences. In 1991, Reagan hosted "The Ron Reagan Show", a syndicated late-night talk show addressing political issues of the day, which was canceled after a brief run since it was unable to compete with the higher ratings of "The Arsenio Hall Show", "The Tonight Show Starring Johnny Carson", and "Nightline".
Reagan has worked in recent years as a magazine journalist, and has hosted talk shows on cable TV networks such as the Animal Planet network. In Britain, he is best known for having co-presented "Record Breakers" (based on "The Guinness Book of Records") for the BBC. Reagan presented a report from the United States each week.
He has served on the board of the Creative Coalition, an organization founded in 1989 by a group that included Susan Sarandon and Christopher Reeve, to politically mobilize entertainers and artists, generally for First Amendment rights, and causes such as arts advocacy and public education. From February to December 2005, Reagan co-hosted the talk show " with Monica Crowley" on MSNBC.
Until its demise in 2010, Air America Media aired "The Ron Reagan Show." The program made its debut on September 8, 2008.
In 2011, he published "My Father at 100: A Memoir". In interviews promoting the book, Reagan described noticing his father was having certain mental lapses which, in hindsight, caused the younger Reagan to speculate subsequently that his father may have already been in the early stages of Alzheimer's disease while still in office. This assertion was attacked by critics, including his brother, Michael Reagan. Ron Reagan subsequently clarified that he did not feel the lapses were evidence of "dementia."
Reagan, who was 22 and married by the time his father took office, never lived in the White House. He dropped his Secret Service protection one year and a half into his father's presidency.
Political activities.
In July 2004, Reagan spoke at the Democratic National Convention about his support for lifting Bush's restrictions on federally funded embryonic stem cell research, from which he expected a cure or new treatments for Alzheimer's disease, of which his father had recently died. "There are those who would stand in the way of this remarkable future, who would deny the federal funding so crucial to basic research. A few of these folks, needless to say, are just grinding a political axe and they should be ashamed of themselves," Ron Reagan said of the restrictions. "We can choose between the future and the past, between reason and ignorance, between true compassion and mere ideology." Reagan's mother Nancy also supported this position.
In September 2004, he told the "Sunday Herald" newspaper that the George W. Bush Administration had "cheated to get into the White House. It's not something Americans ever want to think about their government. My sense of these people is that they don't have any respect for the public at large. They have a revolutionary mindset. I think they feel that anything they can do to prevail — lie, cheat, whatever — is justified by their revolutionary aims" and that he feared Bush was "hijacking" his father's reputation.
Reagan later wrote the essay "The Case Against George W. Bush by Ron Reagan" for "Esquire". He voted for Democratic candidate John Kerry in the 2004 presidential election. Reagan endorsed Senator Barack Obama of Illinois for president in the 2008 presidential election. In November 2015, Reagan endorsed Vermont Senator Bernie Sanders for the Democratic Party nomination in the 2016 Democratic Party primaries.
In early 2020, Reagan stated that his father would've opposed Donald Trump, remarking to "The Daily Beast" that his "father would have been ashamed of this Republican Party" as well as "been embarrassed and ashamed that a president of the United States was as incompetent and traitorous as the man occupying the White House now."
Personal life.
Ron Reagan lives in Seattle. He married Doria Palmieri, a clinical psychologist, in 1980. She died in 2014 from neuromuscular disease. They had no children. He married Federica Basagni in July 2018.
Reagan stated, in a 2004 "New York Times" interview, that he did not claim any religion, but that his sympathies were with Buddhism and his wife was a Buddhist. In a June 23, 2004, interview on CNN show "Larry King Live", while discussing reasons why he would not run for political office, Ron Reagan stated "I'm an atheist. ... I can't be elected to anything because polls all say that people won't elect an atheist."
In February 2010, he was named to the Freedom From Religion Foundation's Honorary Board of distinguished achievers. In May 2014, Reagan appeared in an advertisement for broadcast on Comedy Central for the Freedom From Religion Foundation in which he declared himself "an unabashed atheist," and one who is not afraid of "burning" in Hell. The ad received renewed attention in October 2019 when it aired on CNN during the fourth 2020 Democratic Presidential Debate. The ad was also run during the CNN Democratic debates in January and March 2020.


Council on State Taxation

The Council on State Taxation (COST) is a state tax organization representing business taxpayers, noted by one prominent tax policy expert as the “most influential nongovernmental organization in the state tax policy arena.” COST is a non-profit trade association based in Washington, D.C. consisting of approximately 550 multistate corporations engaged in interstate and international business. COST was formed in 1969 as the "Committee on State Taxation" by a handful of companies under the sponsorship of the Council of State Chambers of Commerce, an organization with which COST remains associated. In 2000, the organization changed its name to "Council on State Taxation". COST’s objective is to preserve and promote equitable and nondiscriminatory state and local taxation of multijurisdictional business entities.
Membership.
COST membership is exclusive, only multistate businesses that are not engaged in tax advising or consulting may apply for membership. As a member of COST, a business will have access to the following benefits:
Education.
COST offers education opportunities. COST events include:
All COST programs qualify with state boards of accountancy and state bar associations for continuing education credits.
Advocacy.
COST's advocacy program is oriented toward active involvement on state tax issues of broad importance to the membership. COST advocates on behalf of its membership in the legislative, judicial and administrative arenas. State and local government policymakers rely heavily on COST staff in formulating, implementing, and changing the state tax landscape. COST's reputation as the nationwide voice of corporate taxpayers has garnered respect from the leadership of the National Conference of State Legislatures, the Federation of Tax Administrators, the National Governors Association, and even the Multistate Tax Commission. COST's involvement in an issue on behalf of its corporate membership signals to state leaders that the issue is one of importance. COST also serves as a resource on business tax issues to other organizations, including State Chambers of Commerce and state taxpayer associations, as those groups develop strategies to address complex state tax matters.
COST disseminates information on pertinent legislative, judicial and regulatory developments through regular publications, and coordinates advocacy activities with members and other sympathetic parties. COST files amicus briefs with state and federal courts, provides testimony (oral and written) before legislative and administrative bodies, meets regularly with state policymakers, and brings together interested members to enhance advocacy activities on targeted issues.
Publications.
COST utilizes electronic broadcast email to keep members informed of the most important issues. COST newsletters are distributed to COST members for free on a weekly basis. Those newsletters include:


Salem Abdulaziz Al Sabah

Salem Abdulaziz Al Sabah is a Kuwaiti politician who served as deputy prime minister and minister of finance from 4 August 2013 to January 2014. He is a member of the ruling family, Al Sabah.
Education.
Sabah graduated from the American University of Beirut.
Career and views.
Sabah was the governor of the Central Bank of Kuwait from 1986 to February 2012. During his tenure he adopted reformist policies, and held the following positions: chair of Institute of Banking Studies, deputy governor at the Arab Monetary Fund and board member of Kuwait Investment Authority. He resigned from the post due to his objections in regard to the Kuwaiti government's spending policies. Mohammad Al Hashel succeeded Sabah as governor in March 2012.
On 4 August 2013, Sabah was appointed both deputy prime minister and finance minister. He replaced Mustafa Al Shamali as finance minister. As finance minister, Sabah headed the Kuwait Investment Authority.
In October 2013, Sabah stated that the economy of Kuwait could grow only if administrative reforms were realized. His tenure ended in January 2014 when Anas Khalid Al Saleh was appointed finance minister.


Nanjing Iron and Steel Company

Nanjing Iron and Steel Co., Ltd. ( NISCO) is a publicly traded steel maker based in Nanjing, Jiangsu Province, China. The parent company of NISCO is Nanjing Nangang Iron and Steel United Co., Ltd. (), a joint venture of Hong Kong listed company Fosun International (the stake was jointly held by Fosun International and its subsidiaries) and Chinese state-owned enterprise Nanjing Iron and Steel Group in a 60–40 ratio.
NISCO involves the pressing and smelting of ferrous metals and sales of steel materials.
NISCO was a constituent of small cap SSE 380 Index from December 2015 to December 2017.
According to World Steel Association (Chinese companies data was provided by China Iron and Steel Association), the corporation was ranked the 45th in 2015 the world ranking by production volume (8.590 million metric tons).
History.
The steel plant in Nanjing was founded in 1958. In 1999 Nanjing Iron and Steel Group spin-off some of the assembly line of the steel plant, incorporating Nanjing Iron and Steel Co., Ltd. (NISCO).
The company became a publicly traded company in 2000 on the Shanghai Stock Exchange, despite the parent company still owned 70.95% shares. However, after several disinvestment, it no longer the controlling shareholder of the listed company. Instead, the controlling shareholder was replaced by joint ventures of Nanjing Iron and Steel Group in 2003 and again in 2009 under another legal person. The direct parent company also received the unlisted steel manufacturing assets from Nanjing Iron and Steel Group.
In 2010, NISCO acquired some assets (themselves were incorporated as , in short ) from the direct parent company, Nangang United, as those businesses were classified as related parties but the listed company had business relation with them. NISCO paid the direct parent company in an all-share deal for nominal value, making Nangang United owned 83.78% shares of the listed company.
According to the public filings, after the acquisition, , the listed company had a total assets (in consolidated financial statement) of , comparing to parent company Nangang United's . The net assets (excluding minority interests) were and respectively.
NISCO also had a long business partnership with Hong Kong listed company for trading iron ore. In 2011, NISCO acquired 10% shares of a company, All Wealthy Capital, from the chairman of Prosperity International, , for US$50 million. The shares were sold back to Wong for US$50 million plus interests, as the initial public offering of All Wealthy Capital had failed, trigging the initial purchase condition. Since December 2014, Prosperity International became a related parties of NISCO, as Nanjing Iron and Steel Group owned more than 10% shares of Prosperity International.
Circa 2016, NISCO signed an agreement with banks for debt-to-equity swap. The capital increase of the subsidiary by the bank and other parties, was completed in 2017. In the same year NISCO also issued new shares via private placement.
Shareholders.
In 2003 the parent company of the listed company formed a joint venture "Nanjing Iron and Steel United" () with a consortium of civilian-run enterprises: Fosun High Technology and its parent company Guangxin Technology (). The stake of NISCO that held by Nanjing Iron and Steel Group was injected to Nanjing Iron and Steel United as capital. After the deal, Nanjing Iron and Steel Group owned 40% stake of Nanjing Iron and Steel United, Fosun High Technology (and its subsidiary) owned 50% and Guangxin Technology owned 10%. The parent company of Fosun High Technology was later changed to Hong Kong listed company Fosun International, which also acquired the stake from Guangxin Technology. However, Fosun International was still controlled by the shareholder of Guangxin Technology as of 2018.
In 2009, a new intermediate holding company, "Nanjing Nangang Iron and Steel United Co., Ltd." (, known as Nanjing Nangang or ()) was incorporated, Nanjing Iron and Steel United became its wholly owned subsidiary, while Nanjing Iron and Steel United owned 62.69% stake of NISCO at that time. Baosteel Group was the second largest shareholder of the listed company for just 2.42% shares at that time.
As at 31 December 2015, Nangang United had disinvested NISCO to just 48.19%. On 31 December 2015, Fosun International also appointed Nanjing Iron and Steel Group as its proxy for 10% stake of Nangang United, making Nangang United was classified as a joint venture and not consolidated in Fosun International's consolidated financial statements, while Nanjing Iron and Steel Group regained the joint-controlling status on the publicly traded company.


Juan Nepomuceno de Quesada

Juan Nepomuceno de Quesada y Barnuevo Arrocha (1738–1798) was a military officer who served as Governor and intendant of Honduras between 1783 and 1789, and Governor of East Florida from July 1790 to March 1796.
Early life.
De Quesada was born in 1738 at Jaén, Spain. He joined the Spanish Royal Army in his youth, attaining the ranks of Brigadier of the Infantry of the Royal Armies and Commander General of the "presidio" of St. Augustine.
Political career.
De Quesada was appointed Governor and intendant of Honduras in 1783, and remained in this office until 1789, when he was replaced in the Honduran government by Alejo García Conde.
In 1790 De Quesada was appointed Governor of East Florida by Charles IV of Spain, to replace Vicente Manuel de Céspedes. He assumed the governorship in July 1790, during the Nootka Sound Crisis. Upon his appointment, De Quesada wrote to George Washington informing the president of his new position in Florida and offering his diplomatic friendship to the United States.
After his arrival at Saint Augustine, as a consequence of the Nootka Crisis, De Quesada revamped the defenses of the city, which were not extensive enough, according to him and his engineer, Mariano de la Roque. The garrison was small and dispirited, as the Spanish royal subsidy ("situado") had not arrived in Florida since 1787.
In the course of his service as governor of the province, De Quesada also obtained the titles of Vice Royal Patron, and Subdelegate of St. Augustine and the province. Construction of the Cathedral was begun in 1793 under his administration and finished in 1797, a year after he left his post.
Slavery.
De Quesada banned the recognition of runaway slaves who had fled from the American South to Florida seeking freedom. He had corresponded with Thomas Jefferson in 1791 on the matter of fugitive slaves coming from the southern United States. Through commissioner James Seagrove of Georgia, De Quesada wrote a letter initiating the agreement that stated any American slaveowner immigrating to Florida simply had to swear that they were the legitimate owners of the enslaved person for their ownership to be recognized.
Death.
He became ill in February 1796, and continued to serve as governor of East Florida only until March of that year, when he was succeeded by Bartolomé Morales. He died in 1798.


Grass by the Home

Grass by the Home () is a 1983 song by former Soviet and Russian music group Zemlyane. The lyrics were written by Anatoly Poperechny and music by Vladimir Migulya. The song tells about cosmonauts in the space longing for Earth, their homes and grass near it. In 2009, the Russian Federal Space Agency named "Grass by the Home" the official anthem of Russian cosmonauts.
The song was the finalist of the 1983 edition of Song of the Year. In 1984, it was used in the 14th episode of Well, Just You Wait! (Nu, pogodi).


Prince David of Georgia

David Bagrationi (, ), also known as David the Regent (, ) (1 July 1767 in Tbilisi, Georgia – 13 May 1819 in Saint Petersburg, Russia), was a Georgian royal prince (batonishvili), writer and scholar, was a regent of the Kingdom of Kartl-Kakheti, eastern Georgia, from December 28, 1800 to January 18, 1801.
The eldest son of the last Kartli-Kakhetian, King George XII by his first wife Ketevan Andronikashvili, he was educated in Russia (1787–1789), and served there as a colonel of the Russian army from 1797 to 1798. He was proclaimed as Heir Apparent by his father on February 22, 1799 and confirmed by the Russian Tsar Paul I, an official protector of Georgia, on 18 April 1799. In 1800, he attempted to modernize the law and administration. He became a lieutenant general the same year.
On his father's death in December 1800, David became the head of the Royal House of Bagrationi but was not allowed to ascend the throne of Kartli-Kakheti. David ruled briefly between the time of his father's death (December 28, 1800) and the arrival of General Knorring (May 24, 1801). In November 1800 the Russian Tsar had prohibited him from doing that without Russian consent. On January 18, 1801 he was surprised by a decree of Paul I declaring the annexation of the Kingdom to the Russian Empire. He tried to remain in power as de facto head of state. In May 1801 Russian General Carl Heinrich Knorring removed him from power and established a provisional government headed by General Ivan Petrovich Lasarev. Prince David was brought to St Petersburg under a military escort on February 18, 1803. From 1812 to 1819, he held a seat in the Senate of the Russian Empire.
He married in 1800 Princess Elene Abamelik (1770—1836), and died childless in 1819. He was buried at the Alexander Nevsky Monastery.
Influenced by the ideas of French Enlightenment, he was the first Georgian translator of Voltaire. He was also an author of a research on Georgian history (Georgian, 1814), "Review of the Georgian Law" (Russian, 1811—1816), "Abridged Manual of Physics" (Georgian, 1818), and several poems.


Five-Year Plans of Argentina

The Five Year Plan was an Argentine state-planning strategy, during the first government of President Juan Domingo Perón.
First Five Year Plan (1947–1951).
Preparations.
Early in the second half of 1946, the Technical Secretariat of the Presidency began to prepare a Plan of Government for the five-year period from 1947 to 1951. The Five Year Plan was first announced as a bill to be sent to the Congress, in the presidential message of October 19, 1946 (the Article 1º consisted of the "Achievements and Investment Plan", and developed a number of other bills).
The plan addressed the need to anticipate and encode in a single body all the measures affecting the exports and imports, regulating the classification, packaging and quality certification of the exportable products, and establishing a customs procedure tailored to the current situation at that time. It decentralized and diversified industry, forming new productive areas, and placing them properly in terms of natural energy sources, means of communication, transportation and consumer markets. A minimum of five years was established for works and investment needed to ensure an adequate supply of raw materials, fuel and mechanical equipment, and rationally develop industry and agriculture in the country. Moreover, in order to expedite customs and port services, it was proposed to unify in each office those functions under the direction, coordination and oversight of a central body to be known as the General Administration of Customs and Ports of the Nation which would replace -with more powers- to the hitherto General Directorate of Customs.
In its article 2 º, it authorized the Executive to fund the plan with the issue of Public Debt Securities in the amount required and / or any other appropriate means, rendering annually to Congress.
The making knowledge was new: both houses of the Congress were convened, not formally as House, but as an invitation to national senators and representatives to join the exposure of the President. The event took place in the floor of the House of Deputies on October 21, 1946, with full attendance for the ruling bloc, however the opposition failed to attend. The event was opened by the Senate President and Vice President of the Nation, Dr. Juan Hortensio Quijano; and later Perón and the Technical Secretary, barcelonan Dr. José Figuerola.
The government opened an outreach campaign, beginning with talks of President Juan Perón in the Teatro Colón, first with workers, and then with employers of the Argentine Industrial Union and the newly created Argentine Association of Production, Industry and Trade.
Second Five Year Plan (1951–1955).
The Second Five Year Plan was based on encouraging the growth of the heavy industry. It was held in 1952, during the second term of Juan Domingo Perón (1951–1955).
Measures.
During this period, Perón stressed primarily to promote foreign investment in the Argentine trade. The main measurements were:
Economy.
The state took over the tasks of selling the exportable surpluses of domestic production, and purchasing fuel, raw materials and capital goods required for agricultural, industrial and mining development in the country.
Argentine Institute for the Promotion of Trade.
The Argentine Institute for the Promotion of Trade (IAPI) was an Argentine public body created by the decree nº 15350 on May 28, 1946, that, although it was signed by President Edelmiro Farrell, it was part of the package that Colonel Juan Domingo Perón and his team of advisers had projected, operating under the aegis of the Central Bank, in order to centralize foreign trade and transfer resources between different sectors of the economy. Its director was the economist Miguel Miranda, chairman of the Central Bank.
Objectives.
The objective that guided the creation of this agency was the need to have an agency specialized in trade issues, a better external integration through the conquest of new markets, and the consolidation of Argentina's presence in those already obtained. It also sought to promote the quality and diversity of local products and create strategies to defend their prices in the international market against the eventual deterioration of the terms of trade; protecting domestic producers against the changes in international prices, and against the action of international monopolies and importing countries of Argentine products.
Features.
The body had different functions. At the commercial level, it was responsible for buying cereals and meat to the producers, and then export them when international prices were favorable. Also met financial functions, providing funds to certain public agencies, provincial governments and even to the private sector for the acquisition of capital goods.
When the Institute acquired processed products which failed placement, it provided the profit margin for the industrial sector, creating a special joint committee to resolve the crisis in certain productive sectors, acquiring raw materials to give it to manufacturers.
Also developed promotion and development functions, as determined which production activities were a priority and therefore should receive special treatment, for example, the granting of credits without obligation to repay. On the other hand, it subsidized the production of certain consumer goods in order to maintain the level of real wages.
Results.
Trade agreements were reached with several countries. Between 1947 and 1949 reached trade agreements with Switzerland, Hungary, Italy, the Netherlands, Norway, Finland, Denmark, Brazil and Sweden. Despite the efforts made by the body to expand the portfolio of buyers of Argentine products, the United Kingdom continued to rank first as an importer, followed by the United States.
Concerning imports, the importance of IAPI was significantly lower. The major purchases were recorded in the areas of metallurgy, building materials, machinery and textiles, standing out as sellers United States and Great Britain, while trade with the Soviet Union reported a significant increase since 1953.
Decline.
The international decline in agricultural prices that followed the post-war European recovery, largely cut off the genuine source of income of the IAPI.
Since 1949 the institute's activities dwindled, leading to the private sector take over much of the exchange. In its relations with the private sector, the large subsidies granted IAPI: between 1947 and 1954 agricultural subsidies amounted to 5,063,011 pesos, while the livestock sector amounted 4,567,590 pesos.
Finally, the deficit turned out to be important enough to motivate the redesign of its convenience (in its latest report the agency's operating deficit amounted to 20,000 million pesos or 3% of the GDP of that time).


International taxation

International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income. The manner of limitation generally takes the form of a territorial, residence-based, or exclusionary system. Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more.
Many governments tax individuals and/or enterprises on income. Such systems of taxation vary widely, and there are no broad general rules. These variations create the potential for double taxation (where the same income is taxed by different countries) and no taxation (where income is not taxed by any country). Income tax systems may impose tax on local income only or on worldwide income. Generally, where worldwide income is taxed, reductions of tax or foreign credits are provided for taxes paid to other jurisdictions. Limits are almost universally imposed on such credits. Multinational corporations usually employ international tax specialists, a specialty among both lawyers and accountants, to decrease their worldwide tax liabilities.
With any system of taxation, it is possible to shift or recharacterize income in a manner that reduces taxation. Jurisdictions often impose rules relating to shifting income among commonly controlled parties, often referred to as transfer pricing rules. Residency-based systems are subject to taxpayer attempts to defer recognition of income through use of related parties. A few jurisdictions impose rules limiting such deferral ("anti-deferral" regimes). Deferral is also specifically authorized by some governments for particular social purposes or other grounds. Agreements among governments (treaties) often attempt to determine who should be entitled to tax what. Most tax treaties provide for at least a skeleton mechanism for resolution of disputes between the parties.
Introduction.
Systems of taxation vary among governments, making generalization difficult. Specifics are intended as examples, and relate to particular governments and not broadly recognized multinational rules. Taxes may be levied on varying measures of income, including but not limited to net income under local accounting concepts (in many countries this is referred to as 'profit'), gross receipts, gross margins (sales less costs of sale), or specific categories of receipts less specific categories of reductions. Unless otherwise specified, the term "income" should be read broadly.
Jurisdictions often impose different income-based levies on enterprises than on individuals. Entities are often taxed in a unified manner on all types of income while individuals are taxed in differing manners depending on the nature or source of the income. Many jurisdictions impose tax at both an entity level and at the owner level on one or more types of enterprises. These jurisdictions often rely on the company law of that jurisdiction or other jurisdictions in determining whether an entity's owners are to be taxed directly on the entity income. However, there are notable exceptions, including U.S. rules characterizing entities independently of legal form.
In order to simplify administration or for other agendas, some governments have imposed "deemed" income regimes. These regimes tax some class of taxpayers according to tax system applicable to other taxpayers but based on a deemed level of income, as if received by the taxpayer. Disputes can arise regarding what levy is proper. Procedures for dispute resolution vary widely and enforcement issues are far more complicated in the international arena. The ultimate dispute resolution for a taxpayer is to leave the jurisdiction, taking all property that could be seized. For governments, the ultimate resolution may be confiscation of property, incarceration or dissolution of the entity.
Other major conceptual differences can exist between tax systems. These include, but are not limited to, assessment vs. self-assessment means of determining and collecting tax; methods of imposing sanctions for violation; sanctions unique to international aspects of the system; mechanisms for enforcement and collection of tax; and reporting mechanisms.
Taxation systems.
Countries that tax income generally use one of two systems: territorial or residence-based. In the territorial system, only local income – income from a source inside the country – is taxed. In the residence-based system, residents of the country are taxed on their worldwide (local and foreign) income, while nonresidents are taxed only on their local income. In addition, a small number of countries also tax the worldwide income of their nonresident citizens in some cases.
Countries with a residence-based system of taxation usually allow deductions or credits for the tax that residents already pay to other countries on their foreign income. Many countries also sign tax treaties with each other to eliminate or reduce double taxation. In the case of corporate income tax, some countries allow an exclusion or deferment of specific items of foreign income from the base of taxation.
Individuals.
The following table summarizes the taxation of local and foreign income of individuals, depending on their residence or citizenship in the country. It includes 244 entries: 194 sovereign countries, their 40 inhabited dependent territories (most of which have separate tax systems), and 10 countries with limited recognition. In the table, "income" includes any type of income received by individuals, such as work or investment income, and "yes" means that the country taxes at least one of these types.
Residency.
Taxing regimes are generally classified as either residence-based or territorial. Most jurisdictions tax income on a residency basis. They need to define "resident" and characterize the income of nonresidents. Such definitions vary by country and type of taxpayer, but usually involve the location of the person's main home and number of days the person is physically present in the country. Examples include:
Territorial systems usually tax local income regardless of the residence of the taxpayer. The key problem argued for this type of system is the ability to avoid taxation on portable income by moving it outside of the country. This has led governments to enact hybrid systems to recover lost revenue.
Citizenship.
In the vast majority of countries, citizenship is completely irrelevant for taxation. Very few countries tax the foreign income of nonresident citizens in general:
A few countries tax based on citizenship only in limited situations:
A few other countries used to tax the foreign income of nonresident citizens, but have abolished this practice:
In Iran, Iraq, North Korea, the Philippines and Saudi Arabia, citizenship is relevant for the taxation of residents but not for nonresidents.
Other.
There are some arrangements for international taxation that are not based on residency or citizenship:
Corporations.
Countries do not necessarily use the same system of taxation for individuals and corporations. For example, France uses a residence-based system for individuals but a territorial system for corporations, while Singapore does the opposite, and Brunei and Monaco taxes corporate but not personal income.
Exclusion.
Many systems provide for specific exclusions from taxable (chargeable) income. For example, several countries, notably the United States, Cyprus, Luxembourg, Netherlands and Spain, have enacted holding company regimes that exclude from income dividends from certain foreign subsidiaries of corporations. These systems generally impose tax on other sorts of income, such as interest or royalties, from the same subsidiaries. They also typically have requirements for portion and time of ownership in order to qualify for exclusion. The United States excludes dividends received by U.S. corporations from non-U.S. subsidiaries, as well as 50% of the deemed remittance of aggregate income of non-U.S. subsidiaries in excess of an aggregate 10% return on tangible depreciable assets. The Netherlands offers a "participation exemption" for dividends from subsidiaries of Netherlands companies. Dividends from all Dutch subsidiaries automatically qualify. For other dividends to qualify, the Dutch shareholder or affiliates must own at least 5% and the subsidiary must be subject to a certain level of income tax locally.
Some countries, such as Singapore, allow deferment of tax on foreign income of resident corporations until it is remitted to the country.
Individuals versus enterprises.
Many tax systems tax individuals in one manner and entities that are not considered fiscally transparent in another. The differences may be as simple as differences in tax rates, and are often motivated by concerns unique to either individuals or corporations. For example, many systems allow taxable income of an individual to be reduced by a fixed amount allowance for other persons supported by the individual (dependents). Such a concept is not relevant for enterprises.
Many systems allow for fiscal transparency of certain forms of enterprise. For example, most countries tax partners of a partnership, rather than the partnership itself, on income of the partnership. A common feature of income taxation is imposition of a levy on certain enterprises in certain forms followed by an additional levy on owners of the enterprise upon distribution of such income. For example, the U.S. imposes two levels of tax on foreign individuals or foreign corporations who own a U.S. corporation. First, the U.S. corporation is subject to the regular income tax on its profits, then subject to an additional 30% tax on the dividends paid to foreign shareholders (the branch profits tax). The foreign corporation will be subject to U.S. income tax on its effectively connected income, and will also be subject to the branch profits tax on any of its profits not reinvested in the U.S. Thus, many countries tax corporations under company tax rules and tax individual shareholders upon corporate distributions. Various countries have tried (and some still maintain) attempts at partial or full "integration" of the enterprise and owner taxation. Where a two level system is present but allows for fiscal transparency of some entities, definitional issues become very important.
Source of income.
Determining the source of income is of critical importance in a territorial system, as source often determines whether or not the income is taxed. For example, Hong Kong does not tax residents on dividend income received from a non-Hong Kong corporation. Source of income is also important in residency systems that grant credits for taxes of other jurisdictions. Such credit is often limited either by jurisdiction or to the local tax on overall income from other jurisdictions.
Source of income is where the income is considered to arise under the relevant tax system. The manner of determining the source of income is generally dependent on the nature of income. Income from the performance of services (e.g., wages) is generally treated as arising where the services are performed. Financing income (e.g., interest, dividends) is generally treated as arising where the user of the financing resides. Income related to use of tangible property (e.g., rents) is generally treated as arising where the property is situated. Income related to use of intangible property (e.g., royalties) is generally treated as arising where the property is used. Gains on sale of realty are generally treated as arising where the property is situated.
Gains from sale of tangible personal property are sourced differently in different jurisdictions. The U.S. treats such gains in three distinct manners: a) gain from sale of purchased inventory is sourced based on where title to the goods passes; b) gain from sale of inventory produced by the person (or certain related persons) is sourced 50% based on title passage and 50% based on location of production and certain assets; c) other gains are sourced based on the residence of the seller.
In specific cases, the tax system may diverge for different categories of individuals. U.S. citizen and resident alien decedents are subject to estate tax on all of their assets, wherever situated. The nonresident aliens are subject to estate tax only on that part of the gross estate which at the time of death is situated in the U.S. Another significant distinction between U.S. citizens/RAs and NRAs is in the exemptions allowed in computing the tax liability.
Where differing characterizations of an item of income can result in differing tax results, it is necessary to determine the characterization. Some systems have rules for resolving characterization issues, but in many cases resolution requires judicial intervention. Note that some systems which allow a credit for foreign taxes source income by reference to foreign law.
Definitions of income.
Some jurisdictions tax net income as determined under financial accounting concepts of that jurisdiction, with few, if any, modifications. Other jurisdictions determine taxable income without regard to income reported in financial statements. Some jurisdictions compute taxable income by reference to financial statement income with specific categories of adjustments, which can be significant.
A jurisdiction relying on financial statement income tends to place reliance on the judgment of local accountants for determinations of income under locally accepted accounting principles. Often such jurisdictions have a requirement that financial statements be audited by registered accountants who must opine thereon. Some jurisdictions extend the audit requirements to include opining on such tax issues as transfer pricing. Jurisdictions not relying on financial statement income must attempt to define principles of income and expense recognition, asset cost recovery, matching, and other concepts within the tax law. These definitional issues can become very complex. Some jurisdictions following this approach also require business taxpayers to provide a reconciliation of financial statement and taxable incomes.
Deductions.
Systems that allow a tax deduction of expenses in computing taxable income must provide for rules for allocating such expenses between classes of income. Such classes may be taxable versus non-taxable, or may relate to computations of credits for taxes of other systems (foreign taxes). A system which does not provide such rules is subject to manipulation by potential taxpayers. The manner of allocation of expenses varies. U.S. rules provide for allocation of an expense to a class of income if the expense directly relates to such class, and apportionment of an expense related to multiple classes. Specific rules are provided for certain categories of more fungible expenses, such as interest. By their nature, rules for allocation and apportionment of expenses may become complex. They may incorporate cost accounting or branch accounting principles, or may define new principles.
Thin capitalization.
Most jurisdictions provide that taxable income may be reduced by amounts expended as interest on loans. By contrast, most do not provide tax relief for distributions to owners. Thus, an enterprise is motivated to finance its subsidiary enterprises through loans rather than capital. Many jurisdictions have adopted "thin capitalization" rules to limit such charges. Various approaches include limiting deductibility of interest expense to a portion of cash flow, disallowing interest expense on debt in excess of a certain ratio, and other mechanisms.
Enterprise restructure.
The organization or reorganization of portions of a multinational enterprise often gives rise to events that, absent rules to the contrary, may be taxable in a particular system. Most systems contain rules preventing recognition of income or loss from certain types of such events. In the simplest form, contribution of business assets to a subsidiary enterprise may, in certain circumstances, be treated as a nontaxable event. Rules on structuring and restructuring tend to be highly complex.
Credits for taxes of other jurisdictions.
Systems that tax income from outside the system's jurisdiction tend to provide for a unilateral credit or offset for taxes paid to other jurisdictions. Such other jurisdiction taxes are generally referred to within the system as "foreign" taxes. Tax treaties often require this credit. A credit for foreign taxes is subject to manipulation by planners if there are no limits, or weak limits, on such credit. Generally, the credit is at least limited to the tax within the system that the taxpayer would pay on income from outside the jurisdiction. The credit may be limited by category of income, by other jurisdiction or country, based on an effective tax rate, or otherwise. Where the foreign tax credit is limited, such limitation may involve computation of taxable income from other jurisdictions. Such computations tend to rely heavily on the source of income and allocation of expense rules of the system.
Withholding tax.
Many jurisdictions require persons paying amounts to nonresidents to collect tax due from a nonresident with respect to certain income by withholding such tax from such payments and remitting the tax to the government. Such levies are generally referred to as withholding taxes. These requirements are induced because of potential difficulties in collection of the tax from nonresidents. Withholding taxes are often imposed at rates differing from the prevailing income tax rates. Further, the rate of withholding may vary by type of income or type of recipient. Generally, withholding taxes are reduced or eliminated under income tax treaties (see below). Generally, withholding taxes are imposed on the gross amount of income, unreduced by expenses. Such taxation provides for great simplicity of administration but can also reduce the taxpayer's awareness of the amount of tax being collected.
Treaties.
Tax treaties exist between many countries on a bilateral basis to prevent double taxation (taxes levied twice on the same income, profit, capital gain, inheritance or other item). In some countries they are also known as double taxation agreements, double tax treaties, or "tax information exchange agreements" (TIEA).
Most developed countries have a large number of tax treaties, while developing countries are less well represented in the worldwide tax treaty network. The United Kingdom has treaties with more than 110 countries and territories. The United States has treaties with 56 countries (as of February 2007). Tax treaties tend not to exist, or to be of limited application, when either party regards the other as a tax haven. There are a number of model tax treaties published by various national and international bodies, such as the United Nations and the OECD.
Treaties tend to provide reduced rates of taxation on dividends, interest, and royalties. They tend to impose limits on each treaty country in taxing business profits, permitting taxation only in the presence of a permanent establishment in the country. Treaties tend to impose limits on taxation of salaries and other income for performance of services. They also tend to have "tie breaker" clauses for resolving conflicts between residency rules. Nearly all treaties have at least skeletal mechanisms for resolving disputes, generally negotiated between the "competent authority" section of each country's taxing authority.
Anti-deferral measures.
Residency systems may provide that residents are not subject to tax on income outside the jurisdiction until that income is remitted to the jurisdiction. Taxpayers in such systems have significant incentives to shift income outside its borders. Depending on the rules of the system, the shifting may occur by changing the location of activities generating income or by shifting income to separate enterprises owned by the taxpayer. Most residency systems have avoided rules which permit deferring income from outside its borders without shifting it to a subsidiary enterprise due to the potential for manipulation of such rules. Where owners of an enterprise are taxed separately from the enterprise, portable income may be shifted from a taxpayer to a subsidiary enterprise to accomplish deferral or elimination of tax. Such systems tend to have rules to limit such deferral through controlled foreign corporations. Several different approaches have been used by countries for their anti-deferral rules.
In the United States, rules provides that U.S. shareholders of a Controlled Foreign Corporation (CFC) must include their shares of income or investment of E&P by the CFC in U.S. property. U.S. shareholders are U.S. persons owning 10% or more (after the application of complex attribution of ownership rules) of a foreign corporation. Such persons may include individuals, corporations, partnerships, trusts, estates, and other juridical persons. A CFC is a foreign corporation more than 50% owned by U.S. shareholders. This income includes several categories of portable income, including most investment income, certain resale income, and certain services income. Certain exceptions apply, including the exclusion from Subpart F income of CFC income subject to an effective foreign tax rate of 90% or more of the top U.S. tax rate.
The United Kingdom provides that a UK company is taxed currently on the income of its controlled subsidiary companies managed and controlled outside the UK which are subject to "low" foreign taxes. Low tax is determined as actual tax of less than three-fourths of the corresponding UK tax that would be due on the income determined under UK principles. Complexities arise in computing the corresponding UK tax. Further, there are certain exceptions which may permit deferral, including a "white list" of permitted countries and a 90% earnings distribution policy of the controlled company. Further, anti-deferral does not apply where there is no tax avoidance motive.
Rules in Germany provide that a German individual or company shareholder of a foreign corporation may be subject to current German tax on certain passive income received by the foreign corporation. This provision applies if the foreign corporation is taxed at less than 25% of the passive income, as defined. Japan and some other countries have followed a "black list" approach, where income of subsidiaries in countries identified as tax havens is subject to current tax to the shareholder. Sweden has adopted a "white list" of countries in which subsidiaries may be organized so that the shareholder is not subject to current tax.
Transfer pricing.
The setting of the amount of related party charges is commonly referred to as transfer pricing. Many jurisdictions have become sensitive to the potential for shifting profits with transfer pricing, and have adopted rules regulating setting or testing of prices or allowance of deductions or inclusion of income for related party transactions. Many jurisdictions have adopted broadly similar transfer pricing rules. The OECD has adopted (subject to specific country reservations) fairly comprehensive guidelines. These guidelines have been adopted with little modification by many countries. Notably, the U.S. and Canada have adopted rules which depart in some material respects from OECD guidelines, generally by providing more detailed rules.
Arm's length principle: It is a key concept of most transfer pricing rules, that prices charged between related enterprises should be those which would be charged between unrelated parties dealing at arm's length. Most sets of rules prescribe methods for testing whether prices charged should be considered to meet this standard. Such rules generally involve comparison of related party transactions to similar transactions of unrelated parties (comparable prices or transactions). Various surrogates for such transactions may be allowed. Most guidelines allow the following methods for testing prices: Comparable uncontrolled transaction prices, resale prices based on comparable markups, cost plus a markup, and an enterprise profitability method.
Tax avoidance.
Tax avoidance schemes may take advantage of low or no-income tax countries known as tax havens. Corporations may choose to move their headquarters to a country with more favorable tax environments. In countries where movement has been restricted by legislation, it might be necessary to reincorporate into a low-tax company through reversing a merger with a foreign corporation ("inversion" similar to a reverse merger). In addition, transfer pricing may allow for "earnings stripping" as profits are attributed to subsidiaries in low-tax countries.
For individuals tax avoidance has become a major issue for governments worldwide since the 2008 recession. These tax directives began when the United States introduced the Foreign Account Tax Compliance Act (FATCA) in 2010, and were greatly expanded by the work of The Organisation for Economic Co-operation and Development (OECD). The OECD introduced a new international system for the automatic exchange of tax information – known as the Common Reporting Standard (CRS) – to which around 100 countries have committed. For some taxpayers, the CRS is already “live”; for others it is imminent. The goal of this worldwide exchange of tax information is tax transparency, and has aroused concerns about privacy and data breaches due to the sheer volume of information that is going to be exchanged.
Expanded Worldwide Planning (EWP) is an element of international taxation created in the wake of tax directives from government tax authorities after the worldwide recession beginning in 2008. At the heart of EWP is a properly constructed Private placement life insurance (PPLI) policy that allows taxpayers to use the regulatory framework of life insurance to structure their assets. These assets can be located anywhere in the world and at the same time can be brought into compliance with tax authorities worldwide. EWP also brings asset protection and privacy benefits that are set forward in the six principals of EWP.