Category: ulvauooa

‘Chief Justice Lewis Did Not Design Plan for Courthouses’

first_imgContrary to statements that former Chief Justice Johnnie N. Lewis was the one who designed the plan for the construction of the new courthouses throughout the country, and the modernization of the Temple of Justice, another former Chief Justice Gloria Musu Scott, claims it was her administration that designed the plan.Cllr. Scott, who served as chief justice during the regime of former President Charles G. Taylor, made the clarification to journalists last Monday at the Temple of Justice where she had gone to sign the book of condolence for the late Chief Justice Lewis.“We left the design for the construction of the courthouses and he followed it and constructed them. It was not he who designed them, we did,” the former Chief Justice explained.“Chief Justice Lewis even used the contractors that we had in our plan. He respected our plan and made it a reality,” the former Chief Justice and a former Maryland County Senator added.Madam Scott who is the current chairperson of the Constitution Review Commission (CRC) said she had great respect for the late Chief Justice because he was a man who believed in continuity. “What I can say is that he believed in continuity. This is what I respected and will miss him for. He did exactly what we had on the books for the improvement of the judiciary. He followed our plan and completed it,” she reiterated.Referring to Chief Justice Lewis’ impact on her life, she said,“I was blessed to have sat under him as a student when I was at the Law School because he opened my mind and gave me confidence in my profession.”She went on to say, “He was an intelligent man and exceptionally smart to the extent that at age 25, he served as a Circuit Judge, the youngest Circuit Judge ever in the history of the country. He left a good legacy for the judiciary and if we were to follow it, then we will be transforming the judiciary.”Share this:Click to share on Twitter (Opens in new window)Click to share on Facebook (Opens in new window)last_img read more

Zlatan rescues Man United in Liverpool draw

first_img0Shares0000Manchester United’s striker Zlatan Ibrahimovic (L) takes a free-kick during the English Premier League football match between Manchester United and Liverpool at Old Trafford in Manchester, north west England, on January 15, 2017 © AFP / Oli SCARFFMANCHESTER, United Kingdom, Jan 15 – Zlatan Ibrahimovic scored an 84th-minute header as Manchester United prevented historic foes Liverpool from recapturing second place in the Premier League table in a 1-1 draw on Sunday.Paul Pogba stood to be United’s fall guy at Old Trafford after conceding a soft first-half penalty for handball, which James Milner converted, only for Ibrahimovic to save his blushes. Ibrahimovic’s 19th goal of the season extended United’s unbeaten league run to seven games, but after winning the previous six, momentum has been lost.“When you’re losing and you score in the last part of the game, the team that concedes feels worse than the team that scores,” said United manager Jose Mourinho.“But in the end we lost the points because we were playing for three. They’re happy with a point, so they go home happy.”Manchester United’s striker Wayne Rooney (L) vies with Liverpool’s midfielder Trent Alexander-Arnold during the English Premier League football match between Manchester United and Liverpool on January 15, 2017 © AFP / Oli SCARFFMourinho’s side remain sixth, four points off the Champions League places, while Liverpool rose one place to third, seven points below leaders Chelsea and beneath Tottenham Hotspur on goal difference.After draws against Sunderland and Plymouth Argyle and a defeat at Southampton, Liverpool have gone four games without victory at the start of a calendar year for the first time since 1993.But with United five points below them, Jurgen Klopp’s men remain the more likely champions.“A lot of people before the game would have thought we would get a knock today because United look like a rolling beetle and everything goes in their direction,” Klopp said.“We know about our problems and situations, so seeing a performance like today was nice.”An abdominal injury to Nathaniel Clyne saw Liverpool’s 18-year-old right-back Trent Alexander-Arnold given a full league debut and he had the onerous task of handling the livewire Anthony Martial.Martial scored a memorable goal against Liverpool on his United debut last season and he fashioned the first opening with a deep cross for the leaping Ibrahimovic, who could only volley wide.– Rooney milestone –Ibrahimovic gave the visiting fans a heart-in-mouth moment when he chased down Dejan Lovren’s weak back-pass, with Simon Mignolet’s clearance striking him and looping onto the roof of the net.United appeared to be taking control and in the 19th minute Henrikh Mkhitaryan bisected the Liverpool defence with a neatly judged pass for Pogba, only for the Frenchman to scuff wide with his left foot.Manchester United’s midfielder Paul Pogba reacts after missing a chance to score during the English Premier League football match between Manchester United and Liverpool at Old Trafford in Manchester, north west England, on January 15, 2017 © AFP / Oli SCARFFLiverpool’s play had been more conspicuous for misplaced passes than anything else, but errors from Phil Jones and Pogba enabled them to take the lead in the 27th minute.Jones’s heavy touch allowed Roberto Firmino to rob him on the edge of the box, obliging Marcos Rojo to tidy up at the expense of a corner.Pogba inexplicably leapt with his hands above his head as he defended Milner’s set-piece and the Liverpool number seven tucked the ensuing spot-kick past David de Gea for his sixth penalty of the season.United twice threatened an equaliser before half-time, Ibrahimovic blasting a free-kick towards the bottom-left corner and Mkhitaryan taking aim from Ander Herrera’s pass, but Mignolet saved twice.Mourinho took remedial action at the interval, sending on Wayne Rooney for his 450th league appearance and withdrawing Michael Carrick.United spurned a great chance to equalise when, after robbing Alexander-Arnold on halfway, Martial sprinted into the box to meet Mkhitaryan’s low cross, only to miscue his attempt at a back-heel.But with Carrick off, United’s back four was exposed to counter-attacks.Divock Origi saw a shot deflected wide, a missed header by Jones allowed substitute Philippe Coutinho to slip in Firmino, obliging De Gea to block, and Georginio Wijnaldum headed Emre Can’s cross over.It was left to Ibrahimovic to ride to United’s rescue, the Swede steering a fine header over Mignolet from Antonio Valencia’s cross after Marouane Fellaini’s header came back off the post.The noise that Mourinho had called for after United’s mid-week League Cup semi-final first-leg win over Hull City duly arrived, but Liverpool withstood the late crescendo.0Shares0000(Visited 1 times, 1 visits today)last_img read more

Valley’s Weiner Factory may make way for yogurt

first_img AD Quality Auto 360p 720p 1080p Top articles1/5READ MOREGame Center: Chargers at Kansas City Chiefs, Sunday, 10 a.m.Officials with Pinkberry, a nonfat frozen-yogurt chain, were expected to tell a Sherman Oaks Neighborhood Council panel Monday night that they wanted to raze the small hot-dog restaurant and build another Pinkberry store. “Historically, many things come and go. But we have good intentions, so we would like to build a beautiful Pinkberry that could be another landmark for the Valley,” said Young Lee, president and founder of Pinkberry. It would be the fourth Pinkberry to open on Ventura Boulevard after stores in Studio City, Tarzana and one in Encino expected to open in 2009. Lentz is on month-to-month rent at the site, which is owned by the Stanman Family Trust. Perry Hirsch, lawyer for the trust, did not return repeated calls Monday. A spokesman for the trust declined to comment at Monday’s meeting. But Dave Rand, a member of the Sherman Oaks Neighborhood Council and chairman of the land-use committee, said despite The Weiner Factory’s loyal customers, residents are looking forward to the possible debut of a Pinkberry. SHERMAN OAKS – For hot dog connoisseur Kevin Lentz, preparing the quintessential American snack is more than just a business. “I like to live my life by one philosophy: You are only as good as your last dog,” Lentz said. His philosophy has fueled the success of The Weiner Factory since it opened in 1971, with customers lining up daily at what some tout as the best hot dog place in the San Fernando Valley. But after 36 years, Lentz’s days of dishing the dogs may soon be numbered. “Needless to say, a lot of people are excited about Pinkberry coming to Ventura Boulevard,” Rand said. “Depending on your particular preferences – hot dogs or quality yogurt – some will be upset, some will be thrilled.” Still, Rand said some opposition could come over parking issues. “This is a tremendously popular yogurt shop,” he said. “In West Hollywood, on Olympic Boulevard and in Studio City they are often so busy their long lines stretch out the door and this could cause potential parking and traffic concerns,” Rand said. “We have to take a close look at whether that size of the location can accommodate that store.” Still, some are sad that their favorite hot-dog restaurant could be forced to close. Encino business owners Bob Edelman and Louis Trotta have been sharing chili-cheese dogs at The Weiner Factory for at least 35 years. “At one point we used to come here multiple times a week,” Trotta said. “But my doctor has told me to restrict myself – I now come once a week.” Mike Scott, a Burbank resident, said he discovered The Weiner Factory’s dogs and knishes 10 years ago and hasn’t been able to stay away. “I come two times a week and order the same thing – two beef dogs with brown mustard and red onions and a knish,” Scott said. And beyond the food, Scott said he keeps coming back because of the people who work there. “I fell in love with these people,” Scott said. “The food is incredible, but they are gracious, beautiful people.” For now, Lentz is uncertain what the future holds for his business. “This has been a wonderful place to do business,” Lentz said. “I haven’t decided yet what I am going to do … it’s hard to say at this time … but The Weiner Factory has had a really great run.” (818) 713-3634160Want local news?Sign up for the Localist and stay informed Something went wrong. Please try again.subscribeCongratulations! You’re all set!last_img read more


first_imgIf you haven’t been involved in Donegal’s superb Relay for Life event then now is your chance.Last year’s Relay for LIfe event.An information evening for all those wondering about this year’s event takes place at the Mount Errigal Hotel this Monday, January 13th at 7.30pm.Twenty people each week are diagnosed with cancer in Donegal; that’s 1000 people every year, hence why we say there’s “1000 REASONS TO RELAY”. Relay gives individuals the opportunity to CELEBRATE the lives of people that have overcome cancer, to show SUPPORT to those currently undergoing treatment, to REMEMBER people lost to the disease, to offer support and strength to families that have lost their loved ones and to FIGHT BACK through inspiring people to take action against a disease that has taken too much.Relay for Life Donegal allows participants to develop friendships and support networks (e.g.) the Survivors Choir. It provides the opportunity to contribute and give something back to the local community. It reminds us how kind people can be and restores our faith in humanity.Schools participate in Relay for Life Donegal to highlight to their students the importance of contributing to society and to allow students to develop their skills and qualities.Businesses and organisations get involved with Relay for Life, Donegal in order to develop delegation, empowerment and co – operative relationships within the workplace. Families, friends and colleagues relay together to CELEBRATE, REMEMBER and FIGHT BACK (as previously mentioned).Hence why Relay for Life is suitable for everyone to participate at.Looking forward to seeing you there! DONEGAL’S RELAY FOR LIFE 2014 TO BE LAUNCHED THIS MONDAY was last modified: January 12th, 2014 by StephenShare this:Click to share on Facebook (Opens in new window)Click to share on Twitter (Opens in new window)Click to share on LinkedIn (Opens in new window)Click to share on Reddit (Opens in new window)Click to share on Pocket (Opens in new window)Click to share on Telegram (Opens in new window)Click to share on WhatsApp (Opens in new window)Click to share on Skype (Opens in new window)Click to print (Opens in new window) Tags:cancerinformation eveningMount Errigal HotelRelay for LifeTeamslast_img read more


first_imgDONEGAL Daily Weather Report, in association with The Mount Errigal Hotel, Letterkenny, Tel 07491 22700. It’s CupCake Thursday, Free Glass of Wine and Free Cupcake today.Today’s Weather: It was damp and mizzly overnight in most areas of Donegal before rain sweeps up from the south-east covering most of the county by around 8am and Inishowen and Fanad around 9am.Rain will be heaviest later in the north of the county, before clearing around lunchtime. Afternoon temperatures of around 11C or 12C today, slightly cooler on the coasts, with the sun trying to break through later, especially in the south and west. The west of the county could escape a new band of rain from the east, due to arrive around 6pm, and predicted to settle over the east and Inishowen. The rain will clear from all areas later tonight, with overnight temperatures of 6C or 7C.IT’S CupCake Thursday at the Mount Errigal Hotel. FREE Glass of Wine and a FREE CupCake for all the ladies when you order any Josper grill inspired main course at Dexters today. MILD, DRY & WET: THE DD WEATHER REPORT WITH THE MOUNT ERRIGAL HOTEL was last modified: April 2nd, 2014 by John2Share this:Click to share on Facebook (Opens in new window)Click to share on Twitter (Opens in new window)Click to share on LinkedIn (Opens in new window)Click to share on Reddit (Opens in new window)Click to share on Pocket (Opens in new window)Click to share on Telegram (Opens in new window)Click to share on WhatsApp (Opens in new window)Click to share on Skype (Opens in new window)Click to print (Opens in new window) Tags:Cupcake Thursdaysdonegal daily weatherletterkennyMount Errigal Hotellast_img read more

Disney Is Doing a Gender-Swapped “Splash” Remake with Channing Tatum

first_imgDisney is re-making the 1984 comedy “Splash” . . . the movie where TOM HANKS is a man who got saved by a mermaid played by DARRYL HANNAH when he was a kid, and then later meets up with her as an adult.After like four days of getting to know her, he commits to living underwater with her for the rest of his life . . . even though he has to leave everyone and everything behind forever.It’s arguably the BEST movie about irrationally rushing into a relationship.CHANNING TATUM will star in the new version, but there’s a new wrinkle.  He’s NOT the human . . . he’s the MERMAN.  And there will be a human woman played by JILLIAN BELL from “Workaholics” and “Eastbound & Down”.She was also in “22 Jump Steeet” with Channing.last_img read more

Guests Can Participate in “Speak Like a Whale Day” at Disney Parks This June

first_imgShare This! ©DisneyI am not ashamed to admit it. I am really looking forward to Finding Dory. Finding Nemo was always a favorite of mine, so I’m excited to head back into the Big Blue World with Dory, Marlin, Nemo, Crush, Squirt, alongside brand new characters.To celebrate the upcoming film, Guests will be able to participate in “Speak Like a Whale Day” on June 11 at both Walt Disney World and the Disneyland Resorts. Here’s how: In addition, for those who didn’t know, you can now find Dory and some of her new friends from the upcoming film at the Turtle Talk with Crush attraction in Epcot’s The Seas with Nemo & Friends Pavilion and at Disney California Adventure park.Finding Dory swims into theaters on June 17, 2016. Guests at Disneyland Resort and the Walt Disney World Resort will receive a complimentary button to celebrate the day.At the Downtown Disney District at Disneyland Resort and Disney Springs at Walt Disney World, families can take part in unique themed activities, jam out to a live DJ, and participate in games and giveaways. Young guests can also attend “Whale Speak University” and give speaking the language that Dory seemed to master a try.At The Seas with Nemo & Friends in Epcot, guests can learn about the real-life versions of the characters from the film and see them in their aquarium home. In addition, experts from Disney’s Animals, Science and Environment Team will be on hand throughout the day to help guests find Dory and her friends, as well as give them a closer look at their world.last_img read more

You Can’t Make This Stuff Up – June 2017

first_imgCalifornia woman flung from golf cart, dies after falling on wine glassesA 58-year-old San Jose resident died on Friday after being flung from a golf cart and falling on the shards of two wine glasses she was holding, according to the California Highway Patrol. Debra Debard was being driven by her partner, 57-year-old Richard Clarke, in an E-Z-GO golf cart on a private olive orchard in Wallace,  a small town southeast of Sacramento, California. After Clarke made a left turn near the end of the orchard, Debard was unable to “stabilize herself” and was thrown from the cart. The two wine glasses she was holding shattered and Debard fell upon the fragments. She died at the scene, and Clarke was arrested on suspicion of driving under the influence.  [Source: SF Gate] Shoplifter hid 15-quarts of motor oil, DVDs in pants, [Video]A Lakeland, Florida, man has been arrested after authorities say he hid 15 quarts of motor oil and several DVDs into his pants at a 7-Eleven store. Polk County Sheriff’s Detective Phil Ryan was parked in his unmarked patrol car outside the 7-Eleven on Duff Road on Thursday when he observed William Jason Hall enter the store wearing baggy blue jeans, according to a report from the Sheriff’s Office. Ryan watched Hall walk into an aisle of the store and hide 15 quart-sized bottles of Pennzoil into his pants, he then dropped several movie DVDs from a shelf onto the floor, bent down and slid them into his pants. Hall then left the store and started to get into his vehicle when Ryan approached him. Hall was arrested and booked into the Polk County Jail on charges of petty theft. Surveillance video shows the detective recovering the merchandise. Bail was set at $1,000. [Source: The Legend]911, lemonade emergency! Officers visit wannabe cop’s standDozens of thirsty police officers responded to an “emergency” call to visit a lemonade stand run by a 3-year-old aspiring cop in Kansas City, Missouri. The Kansas City Star reports that Hannah Pasley set up her lemonade stand last Friday and Saturday to raise money to buy her own police uniform. After buying the uniform Saturday morning, Hannah returned to her stand, wearing police coat and hat, that afternoon. When the flow of customers thinned, Hannah’s aunt, Ashly Rooks, and her friend Sierra Moore took to Facebook to encourage officers to visit. Rooks says the street was soon packed with squad cars. Moore says “50 plus” officers responded, and a police helicopter buzzed overhead. They gave Hannah a Kansas City Police Department patch and a Clay County Junior Deputy badge.  [Source: The Kansas City Star]Man dons Home Depot apron to steal air conditionersPolice say a man donned an orange Home Depot apron and posed as an employee to steal air conditioners in New Hampshire. But a manager noticed the name on the garment didn’t match that of any worker at the store. Police arrested 53-year-old Bernardo Calana, of Haverhill, Massachusetts, on Saturday. Calana loaded two air conditioners into his pickup truck in Plaistow and went back inside. A manager noticed the apron with the name “Shannon” with flowers drawn on it and called police. Calana later told police he didn’t know anything about the air conditioners, but a Home Depot apron was found in his back pocket. Calana was released on bail. The voice mailbox for a listed phone number for him was full.  [Source: Napa Valley Register]- Sponsor – Florida man flashing money on Facebook Live arrested on drug chargeA Florida man joyfully flashing money live on the internet got a sudden surprise when police officers barged in and arrested him for allegedly selling drugs. A man identified by the Jacksonville Sheriff’s Office as 22-year-old Breon Hollings went on Facebook Live to show friends a handful of money, saying, “It don’t stop, man, it don’t stop.” He then retrieves more money from another room and starts shuffling it when he hears Jacksonville officers warning over a loudspeaker they are about to raid the house. A stunned Hollings runs out of the room. Seconds later, officers barge in. Hollings was arrested off camera. Hollings faces numerous drug charges and was being held on $425,000 bail Saturday. It could not be determined if he has an attorney.  [Source: DunyaNews]Meet the world’s first robot policemanThe “world’s first operational Robocop” has been unveiled in Dubai as part of the emirate’s planned robot police force. Robocop started work on Sunday and is already making a name for itself. At 5ft 5in tall and weighing 100kg, it can speak six languages and is designed to read facial expressions. It had an easy start to working life, being unveiled at the three-day long Gulf Information Security Expo and Conference. But when the Expo draws to a close, it will be released into the wider world and tackle real life issues. The machine has a built-in tablet so people can use it pay fines or report crimes, and can also transmit and receive messages from police headquarters.Brigadier-General Khalid Nasser Al Razzouqi, Director-General of Smart Services with the Dubai Police said: The launch of the world’s first operational Robocop is a significant milestone for the Emirate and a step towards realizing Dubai’s vision to be a global leader in smart cities technology adoption. With an aim to assist and help people in the malls or on the streets, the Robocop is the latest smart addition to the force and has been designed to help us fight crime, keep the city safe and improve happiness levels,” he added. “He can chat and interact, respond to public queries, shake hands and offer a military salute.”   [Source: Mirror UK]Californian accused in theft of $1M worth of beehivesThe bee industry is buzzing over the arrest of a man accused of stealing thousands of hives worth nearly $1 million from California’s almond orchards in one of the biggest such thefts on record. The case has thrown a spotlight on a business many city slickers probably never knew existed: Beekeepers in the US move their colonies around the country by truck and rent them out to farmers to pollinate their flowering crops. In California, which relies on bees brought in from such places as Missouri, Montana and North Dakota to produce more almonds than any other place in the world, hives began to vanish overnight across several counties three years ago. The break in the case came in late April, when a tip led authorities to a ramshackle “chop shop” of stolen beehives on a corner lot outside Fresno. They arrested 51-year-old Pavel Tveretinov, a beekeeper-turned-criminal from suburban Sacramento, on suspicion of possessing stolen property, investigators said “Bees are big money,” Sgt. Arley Terrence of the Fresno County Sheriff’s Office agriculture crimes unit said Tuesday. “There’s a lot of motive to steal.”The unexplained mass die-offs of bees in recent years and booming demand for almonds have helped drive up the value of hives. Almonds have increased in popularity amid a marketing push urging health-conscious Americans to eat them in energy bars, crunch on them raw, sprinkle slivers on their salads or pour almond milk on their cereal. Almond growers rent hives for a few weeks when their trees blossom, allowing the bees to pollinate the flowers as they fly from tree to tree. The blossoms then turn into nuts. Investigators say Tveretinov, the prime suspect in the thefts, went to work at night, removing the hives when the bees are dormant. In total, Tveretinov is alleged to be responsible for stealing 2,500 hives and equipment worth $875,000, investigators say.  [Source: The Augusta Chronicle] Stay UpdatedGet critical information for loss prevention professionals, security and retail management delivered right to your inbox.  Sign up nowlast_img read more

IRS Proposes to Remove Section 385 Documentation Regulations

first_imgThe IRS has proposed removing the Section 385 documentation regulations provided in Reg. §1.385-2. However, taxpayers may rely on this proposed removal until final regulations are published.The documentation regulations provide minimum documentation requirements for treating certain related-party instruments as debt for federal tax purposes. They are part of final and temporary Section 385 regulations adopted with T.D. 9790, I.R.B. 2016-45, 540.In addition to the documentation requirements, the Section 385 regulations also include debt recharacterization rules. These rules recharacterize as equity certain debt issued in connection with distributions and acquisitions that do not result in new investment in the operations of the issuer.The Section 385 regulations apply generally to debt instruments that are:issued by a domestic corporation or its disregarded entity, andheld by members of the domestic corporation’s expanded group.Overview of Section 385 Documentation RegulationsThe documentation rules generally require large corporations to document related-party loans, just as all businesses do when they borrow from unrelated lenders. Reg. §1.385-2 prescribes the nature of the documentation necessary to substantiate the tax treatment of related-party instruments as debt. Under these rules, taxpayers must be able to provide written evidence of four indebtedness factors analogous to those found in third-party loans.However, compliance with the documentation rules does not establish that an interest is debt. Instead, it serves only to satisfy the minimum documentation for making the determination under general federal tax principles. Moreover, if a debt instrument is reclassified as stock due to a failure to meet the documentation requirements, it is treated as stock for all federal tax purposes.In addition, corporations that belong to an expanded affiliated group must document relevant transactions under these rules if:stock of any member of the group is publicly traded;one or more members have total assets that exceed $100 million on any applicable financial statement or combination of applicable financial statements; orone or more members have annual total revenue that exceeds $50 million on any applicable financial statement or combination of applicable financial statements.However, the documentation regulations apply to relevant intercompany debt issued beginning in 2019. They also require the taxpayer to prepare its documentation for a given tax year by the time the borrower’s return is filed.Executive Order 13789The president issued Executive Order 13789 on April 21, 2017 (E.O. 13789). It instructs the Treasury Secretary to identify significant tax regulations issued on or after January 1, 2016, that:impose an undue financial burden on U.S. taxpayers;add undue complexity to the federal tax laws; orexceed the statutory authority of the IRS.The order also instructs the Treasury Secretary to take concrete actions to alleviate the burdens of such regulations.Treasury Reports Regarding Section 385 RegulationsUnder the Executive Order, the Treasury Department identified the Section 385 regulations adopted with T.D. 9790 as significant tax regulations that impose an undue financial burden on U.S. taxpayers and/or add undue complexity to the federal tax laws (Notice 2017-38, I.R.B. 2017-30, 147).The IRS responded by delaying the applicability date of the documentation regulations for 12 months. As a result, the documentation requirements apply to interests issued or deemed issued on or after January 1, 2019. As originally adopted, the final documentation regulations applied to interests issued or deemed issued on or after January 1, 2018 (Notice 2017-36, I.R.B. 2017-33, 208).In a later report, the Treasury proposed to revoke the current documentation rules and replace them with substantially simplified and streamlined documentation rules (Treasury Department News Release, TDNR SM-0172, October 4, 2017; U.S. Department of the Treasury, Second Report to the President on Identifying and Reducing Tax Regulatory Burdens (Executive Order 13789), October 2, 2017).Proposed Removal of Section 385 Documentation RulesNow the IRS has proposed the complete removal of the documentation regulations. However, the IRS will continue to study the issues addressed by the documentation regulations. When the study is complete, the IRS may propose a modified version of the documentation regulations. Moreover, these revised documentation rules would:be substantially simplified and streamlined to reduce the burden on U.S. corporations;still require sufficient documentation and other information for tax administration purposes; andbe proposed with a prospective effective date to allow sufficient lead-time for taxpayers to design and implement systems to comply with the revised documentation requirements.CommentsIn addition, members of the public may comment on these proposed changes. The IRS must receive the comments by December 23, 2018.Proposed Regulations, NPRM REG-130244-17Login to read more tax news on CCH® AnswerConnect or CCH® Intelliconnect®.Not a subscriber? Sign up for a free trial or contact us for a representative.last_img read more

Safe Harbor Lets Real Estate Rent and Lease Income Qualify for 199A Deduction

first_imgUnder a new safe harbor, rent and lease income may qualify for the Section 199A passthrough deduction. The safe harbor in Notice 2019-7 is especially good news for relatively small rental operations.What Does the 199A Rental Real Estate Safe Harbor Do?Qualified business income (QBI) under Section 199A normally must come from a “trade or business” that is eligible to deduct business expenses under IRC §162. A Section 162 business must be:considerable, regular and continuous, andintended to make a profit.The safe harbor for rental real estate replaces the Section 162 business test. This means that a rental real estate enterprise that doesn’t rise to the level of a Section 162 business can still produce qualified business income, as long as it satisfies the other QBI requirements.However, the safe harbor applies only to the Section 199A deduction. It does not qualify the rental enterprise as a trade or business for any other purpose.Of course, the safe harbor is not the only way a rental enterprise can produce QBI. If the rental activity satisfies the usual tests for a qualified business, including the IRC §162 business test, it does not need to qualify for the safe harbor.Rental Real Estate Businesses Eligible for the 199A Safe HarborThe safe harbor applies if:separate books and records are maintained to reflect income and expenses for each rental real estate enterprise;at least 250 hours of rental services are performed per year; andthe taxpayer maintains sufficient contemporaneous records.Both individuals and pass-through entities can use the safe harbor, as long as they hold the real property interest directly or through a disregarded entity.What is a 199A Rental Real Estate Enterprise?A rental real estate enterprise is an interest in real property held for the production of rents. In other words, it is the ownership of real estate for renting or leasing. The rental enterprise may consist of an interest in multiple properties. The owner must:treat each property as a separate enterprise, ortreat all similar properties as a single enterprise.Commercial vs. Residential Real EstateHowever, commercial and residential real estate cannot be in the same enterprise. In addition, the taxpayer cannot change the treatment of an enterprise from year to year unless there is a significant change in facts and circumstances.Rental Real Estate Excluded from the Section 199A Safe HarborReal estate does not qualify for the safe harbor if an owner uses the property as a residence during the year. Owners include:individuals who own the property, andowners and beneficiaries of an entity that owns the property.The safe harbor also does not apply to property that is rented or leased under a triple net lease. A triple net lease includes a lease that requires the tenant or lessee to:pay any taxes, fees, and insurance; andbe responsible for maintenance activities for the property, including maintenance allocable to the leased portion of the property, in addition to rent and utilities.250 Hours of Annual Rental Services Required for Safe HarborTo qualify for the safe harbor, the property owner must perform at least 250 hours of rental services per year. This includes rental services performed by the owner’s employees, agents, and independent contractors.What are Safe Harbor Rental Services?Rental services include:advertising to rent or lease the real estate;negotiating and executing leases;verifying information contained in prospective tenant applications;collection of rent;daily operation, maintenance, and repair of the property;management of the real estate;purchase of materials; andsupervision of employees and independent contractors.For tax years beginning after 2022, the owner must satisfy the 250-hour rental service requirement in any three of the last five consecutive tax years.Excluded from Rental ServicesRental services do not include:financial or investment management activities, such as arranging financing;procuring property;studying and reviewing financial statements or reports on operations;planning, managing, or constructing long-term capital improvements; orhours spent traveling to and from the real estate.How to Claim the 199A Rental Real Estate Safe HarborThe taxpayer must attach the following safe harbor statement to a tax return that claims the 199A deduction for safe harbor income:Under penalties of perjury, I (we) declare that I (we) have examined the statement, and, to the best of my (our) knowledge and belief, the statement contains all the relevant facts relating to the revenue procedure, and such facts are true, correct, and complete.The signers of the statement must have personal knowledge of the facts and circumstances.IRS Seeks Comments on 199A Rental Real Estate Safe HarborThe 199A rental real estate safe harbor applies to tax years ending after 2017. However, the IRS has invited public comments before it finalizes the safe harbor rules. Comments may be mailed or hand-delivered to the IRS, or submitted electronically through the Federal eRulemaking Portal at (indicate IRS and NOT-133582-18).By Kelley Wolf, JD, LL.MLogin to read more on CCHAnswerConnect.Not a subscriber? Sign up for a free trial or contact us for a representative.last_img read more

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