No deal Down Under for Bolt

first_imgGOSFORD, Australia (AP):Usain Bolt’s bid to become a professional football player in Australia has ended with the Olympic sprinting great failing to agree on a contract with the Central Coast Mariners.The Mariners announced yesterday that Bolt’s indefinite training period with the club “has drawn to an end, effective immediately.”Central Coast reportedly offered Bolt a contract worth 150,000 Australian dollars (US$110,000) and hoped to get a third-party endorsement to increase the salary package into the millions, but management for the eight-time Olympic gold medallist rejected the offer.”It has been a pleasure to work with Usain as he pursued his desire to become a professional football player,” Mariners owner Mike Charlesworth said in a statement. “This has been a mutually beneficial partnership that brought an increased level of excitement and attention to both the Mariners and the A-League.”Bolt, who has never played football at an elite level, practiced with the Mariners squad in September and October but only played in some low-level, non-league matches. He stopped practicing with the club’s top team when contract negotiations intensified immediately before the A-League season started.Thankful”I would like to thank the Central Coast Mariners’ owners, management, staff, players and fans for making me feel so welcome during my time there,” Bolt said in a statement released by the club. “I wish the club success for the season ahead.”Bolt scored two goals in a trial game but wasn’t included in the squad for the A-League season opener on October 21, when Central Coast had a 1-1 draw in Brisbane. Mariners coach Mike Mulvey said after that match that he wasn’t aware the club had made an offer to Bolt.The 32-year-old Bolt retired from competitive track and field last year and has since explored options in Germany, South Africa, Norway, and Australia to gain a professional soccer contract.His first game for the Mariners, an exhibition against a selection of amateur players, attracted a much larger than average crowd, and Bolt’s bid to join the A-League has generated plenty of headlines. But critics questioned Bolt’s ability to play at an elite level and others wrote it off a publicity stunt.last_img read more

L.A. motorists avoid staying idle in traffic

first_img AD Quality Auto 360p 720p 1080p Top articles1/5READ MOREFrumpy Middle-aged Mom: My realistic 2020 New Year’s resolutions. Some involve doughnuts.The Los Angeles-based Reason Foundation predicts that by 2030, driving during rush hour will take twice as long as it would take during off-peak hours. Already, average speeds can slow to 13 mph during rush hour on the Ventura (101) Freeway through the San Fernando Valley. “L.A. has now set the mold that is being followed by Atlanta, Miami, Dallas, D.C. and Chicago,” said Robert Poole, director of transportation studies for the liber tarian think tank. “This \ really frightens me. There are accidents because of this. But it’s completely understandable. People are desperate to figure out something to do.” So Angelenos – who spend an average of 56.8 minutes commuting to work – are going to continue coping with the traffic in their own way. Stella Chalian, 31, blushes as she talks about her grinding, two-hour, round-trip commute on the 134 and 101 freeways. For all the griping about gridlock and predictions of traffic doom, Angelenos find a way to live their lives in bumper-to- bumper traffic: They apply makeup, pay their bills and even find love. “Some people complain about road rage. Well, I fell in love on the freeway,” said a giddy Felicia Montgomery, 40, who met her fiance while stuck in traffic on the San Bernardino (10) Freeway. For L.A. commuters, who spend 93 hours a year in rush-hour traffic – more than any other city in the U.S. – the precious moments sitting behind the wheel are often spent doing things authorities say they shouldn’t. And a new study finds they’l l be looking for even more diversions. “I do all t he calling – the doctor, the credit card companies,” Chalian said. “I write bills. Because it makes you feel good that you are not so stupid being stuck in traffic for so long.” And, of course, she does her makeup, sometimes in the rear-view mirror of her 2006 BMW 325. “I am just sitting there idle. I would go crazy if I didn’t do something. It saves me from insanity,” she said. Between the 134, 101 and 405 freeways, Officer Leland Tang, a spokesman fo r the California Highway Patrol, has seen it all – couples kissing while driving, men shaving and women flat-ironing their hair. “The whole multi-tasking while driving is a recipe for disaster,” Tang said. “Rear-end collisions are the No. 1 type of collision encountered in the Valley. A high number of them are from speeding and most of them may have an element of distraction, but \ are not going to admit it at the time.” But for all the finger-wagging a t commuters, even Tang was impressed by Montgomery’s commuter love connection. With no air conditioning and the radio on the fritz, the personnel clerk was just beginning to settle in to her daily, 45-minute commute from downtown to the San Gabriel Valley. Then, her future fiance called out, “Hey pretty lady! Hey pretty lady!” “I just kept saying to myself, `Don’t turn around, don’t look. You know how people get shot on the freeway.”‘ But after eight ca lls, she did. She gave Edward Bielucke her cell number, and three dates later, she started to fall in love. Most Angelenos aren’t that blessed. Though Poole points out that even dating patterns are determined by the couple’s proximity to one another, most use the time for more mundane activities, like singing or learning a language on tape. But for some, the car doubles as a board room or a rolling office. Garen Vartanyan, a 47-year- old gas station owner a nd Glendale real estate broker, stores his files in his trunk. “My car is a second office. I have everything I need here. I have my files, my suit, my appointment book,” he said, pointing to the trunk of his 2002 BMW X-5. But Poole said if Angelenos are going to live their lives outside their SUVs, convertibles and clunkers, transportation officials need to dedicate more money to freeway infrastructure – double-decker freeways and toll roads that would allow motorists to travel farther, faster, rather than investing in short-range public transit. Local and state officials say developing a balanced approach – making highway and public transit improvements as well as building transit-friendly development – is the best way to reduce congestion. The latest figures show that during the most congested time during the evening rush hour, the 405 near the 101 interchange slows to 16.7 mph. The 101 near the 405 interchange grinds to 13.2 mph. By 2030, with no infrastructure changes, the Southern California Association of Governments predicts that average rush-hour speeds along the same stretch of the 405 will slow to 4.1 mph and the 101 to 6.2 mph. (818) 713-3741160Want local news?Sign up for the Localist and stay informed Something went wrong. Please try again.subscribeCongratulations! You’re all set!last_img

Dream can’t be stolen by thieves

first_imgIt’s been working really well. Hundreds of people have dropped off their cars for a $5 wash – all the way up to a $25 detail job – and the Miller kids have made them shine. “Pride has always been one of the main things we’ve tried to teach our students, and they’re getting to see it firsthand now,” Moss said. “They spend hours detailing a car, take a step back, look at it in the sunlight and smile.” Besides the pride, the students earned a little paycheck at the end of the month. The rest of the carwash money goes for newer, better equipment to make the business grow. Someday, who knows, Moss says, maybe his kids will have a full-time job in a carwash or auto-detail shop. Yeah, everything was working great until the teacher walked into his workshop after summer break three weeks ago and found the lock on the equipment bin broken and hanging open. Gone were the water pressure sprayers, detail buffers, car vacuums and more than $800 in car-cleaning supplies. What the thieves missed the first time around, they went back and got Monday night. You should have seen the look on his students’ faces when they arrived at school Tuesday, Moss said. It would have broken your heart. “They were devastated and confused,” Moss said. “They couldn’t understand why anyone would do something like this to them. How do you answer that?” You don’t. All Moss could do was not let his kids give up. The thieves might have stolen all their equipment, but the teacher wasn’t about to let them steal their pride, too. “We’ll just have to start over and buy new equipment,” Moss told his kids. “In the meantime we’ll cut down on the cars we’re able to wash.” So that’s what they were doing Wednesday over at Miller. Letting their customers know it might be a little longer before they could wash and detail their cars this month. But please don’t give up on them. They’ll be back. If you want to help the Miller kids rebuild their business, give Moss a call at (818) 885-1646. Dennis McCarthy’s column appears Tuesday, Thursday, Friday and Sunday. (818) 713-3749160Want local news?Sign up for the Localist and stay informed Something went wrong. Please try again.subscribeCongratulations! You’re all set! AD Quality Auto 360p 720p 1080p Top articles1/5READ MOREThe Christmas Truce of 1914 proved that peace is possibleAcademics are important, sure, but it doesn’t amount to a hill of beans unless it leads to a job. And that’s always been the rub. No training, no jobs. “We knew we had to get them involved in classes leading to a possible career, and that’s where we put our focus,” Moss said. “It’s escalated and blossomed into something cool that the students love.” For the last five years, Miller High – just down the street from its big brother, Cleveland High – has been shifting over to classes in transitional employment, wisely teaching its special-ed kids skills that might lead to a job one day. One of the most popular and successful classes has been Moss’s carwash and detailing workshop. The Miller kids began putting fliers out in the community, asking neighbors and businesses for a chance to show what they could do. This one’s for the lowlifes who broke into Don Moss’s carwash and auto-detailing workshop at Miller High School in Reseda twice in the last three weeks. You did a heck of a job sidetracking the dreams of some great kids looking for a leg up in life. They’re all special education students with some tough emotional challenges they’ve been fighting hard to conquer. Moss has spent the last 32 years as a teacher helping them do just that. The old way of doing things – offering mainly academic instruction until they’re 22 and no longer a responsibility of the public school system – hasn’t worked real well, he says. last_img read more

Pedestrian Struck and Killed in Dearborn County Crash

first_imgPer state law, both Pyles and the juvenile submitted to blood tests although alcohol is not believed to be a factor in the crash.  It is unknown why Boone was walking in the middle of the road in that area. According to the initial investigation by the Indiana State Police Crash Reconstruction Team, Jason C. Boone, age 34, Lawrenceburg, Indiana was walking in the middle of the eastbound lane of Sunnyside Avenue when he was struck by an eastbound 2010 Chevrolet Cobalt being driven by Christopher M. Pyles, age 29, Aurora, Indiana.  Boone was then struck by a westbound 2011 Nissan Sentra being driven by a seventeen year old female from Dillsboro, Indiana. Last night, at approximately 10:00 pm, the Indiana State Police responded to a report of a pedestrian struck by a vehicle on Sunnyside Avenue near Woodlawn Avenue which resulted in the death of a Lawrenceburg, Indiana man. The Boone family has been notified.  The investigation is ongoing.center_img Trp. Korry Clark, Indiana State Police Crash Reconstruction Team, was assisted by the Aurora Police Department, Dearborn County Sheriff’s Department, Dearborn County Coroner’s Office, and Aurora Fire Department. Boone sustained massive injuries and was pronounced deceased at the scene by the Dearborn County Coroner’s Office.  Neither Pyles nor the seventeen year old juvenile were injured in the crash.last_img read more

A Guy Sprays Himself Down with Brake Cleaner to Deal with a Bug Infestation, and Blows Up His House

first_imgA spark from the vacuum ignited the fumes, causing an EXPLOSION that blew out a whole wall of his doublewide trailer. A guy outside Houston wanted to, quote, “decontaminate himself of bugs” that were crawling all over his body on Tuesday. He was seriously injured, and cops haven’t been able to ask him a lot of questions yet.  But they found a bunch of empty brake cleaner cans in his house.  And they think drugs or alcohol may have played a part in his decision-making. It’s not clear if the brake cleaner killed the bugs . . . or if they were really there to begin with.  But once he was coated in the stuff, he tried to vacuum the bugs off of his body. We don’t KNOW this person was on meth, but all signs point to yes . . .center_img And unfortunately, he didn’t realize the brake cleaner was extremely FLAMMABLE. But instead of a quick “how to” search on Google, he came up with his own ‘life hack’ idea that involved spraying himself down with brake-cleaning fluid. (KHOU)last_img read more

Fleeing Shoplift Suspect Shot by Police

first_imgPendleton, Oregon, police reported an officer shot a theft suspect Wednesday night near Walmart after he fled a confrontation. Pendleton Police Chief Stuart Roberts said an ambulance took the male victim to St. Anthony Hospital, Pendleton, where he underwent surgery and was flown to Oregon Health & Science University, Portland, for further treatment. No officers were injured and the condition of the victim is unknown. The officer who shot the man, who Roberts also did not immediately identify, is on an automatic 72-hour leave. Roberts said Oregon State Police would handle the investigation. The shooting occurred around 8:45 p.m. near the busy intersection of Southwest 20th Street and Court Avenue in Pendleton. In a written statement Thursday morning, Roberts said officers responded to Walmart for a theft in progress. Loss prevention employees described the suspect to officers. Police confronted him near the front of the store and he “failed to comply with verbal commands.” The man took off running through the parking lot. Officers caught up to him on Southwest 20th Street. Roberts said the officers saw what they perceived to be a dark colored pistol, and the officer fired when the suspect failed to drop it.Pendleton police, Umatilla County sheriff’s deputies and Oregon State Police troopers all responded to the scene, along with Pendleton ambulances. Medical supplies remained in the middle of the street just north of the access road to Taco Bell and the nearby Walmart on the west side and the parking lot of Walgreens on the east. Monte Ludington, deputy district attorney, went to the scene in place of District Attorney Dan Primus, who is at the Oregon District Attorneys Association conference in Gleneden Beach. Primus has made it a point to respond in person or send staff to officer-involved shootings in the county. Witnesses said they heard multiple shots, perhaps as many as seven or eight, but police haven’t released further details. Roberts said Thursday morning that police learn to shoot until they neutralize the threat. Contrary to movie portrayals of gunfire, he said, one bullet does not send a body flying. Roberts also addressed statements on social media criticizing police for shooting the suspect as he ran. “I’m not saying that was the circumstances here,” he stressed, but if it were, case law could be on the side of police. The U.S. Supreme Court in 1985 in the case of Tennessee v. Garner found police can use deadly force to stop a fleeing suspect if they believe the person poses a serious threat of death or injury to others. Roberts said evidence at the scene backed up what officers saw. Roberts also said any more information would come from the Umatilla County District Attorney’s Office. The last officer-involved shooting in Pendleton police was in 2012. Roberts lamented any police shootings.  [Source: East Oregonian] – Sponsor – Stay UpdatedGet critical information for loss prevention professionals, security and retail management delivered right to your inbox.  Sign up nowlast_img read more

5 Tools to Improve Your Idea Before You Write a Line of Code

first_img Another simple and relatively low cost way to get feedback from a critical mass of potential users is to use Ask Your Target Market. While there are a lot of online survey tools, the nice thing about this tool is it has developed a great network of respondents (or “panel” in market research parlance) who you can target for response. This allows you to get statistically meaningful feedback from a specific target audience. Build & Test Landing Pages A final obvious technique to testing and improving your idea is to build some landing pages to test out different value propositions. LaunchRock: We’ve covered them a few times before, but with tools like LaunchRock that have automated the process of developing these landing pages this is a great way to test interest and get signups. If you aren’t familiar with LaunchRock, see the video the team did for a demo with Robert Scoble: Related Posts Why Tech Companies Need Simpler Terms of Servic… A/B Testing Different Value Propositions: To take this approach to the next level, you can even use a solution like Optimizely, Google Website Optimizer or Sumo Optimizer. For a thorough review of these options check out this analysis on our SMB channel ReadWriteBiz of the tools. The general technique of optimizing your landing page is a practice most startups should do. But before you build out your solution you can actually see which value propositions and features are more compelling by testing which call to action – for example “find new sources of information” vs “filter the information you already read” – gets a higher percentage of requests from users. Conclusion As an entrepreneur, you have to figure out the right plan to test and build your product. However, locking yourself in a room and designing and then building your product is rarely optimal. Before opening your IDE of choice, maybe the best step next time is to launch one of the tools mentioned above and started getting some feedback? Do you have other techniques to test out your ideas? Let me know in the comments below. Test tube image from Horia Varlan Tags:#Gritty Entrepreneurs#How To#Software Guides#start A Web Developer’s New Best Friend is the AI Wai… In my last post on ReadWriteStart, I talked about how, in many cases, it wasn’t an advantage to build your start-up in stealth mode. As a continuation of that theme, I thought it would be interesting to explore five tools you can use to iterate and improve your startup idea before writing one line of code. There is nothing worse than building a tool no one is interested in, so I’d encourage you to consider these options before starting down the path of building your next startup. Specifically, these five tools can help you do three critical activities before starting to write a line of code: create a wireframe, get feedback from the target market and test value proposition through multiple landing pages. Editor’s note: This story is part of a series we call Redux, where we’re re-publishing some of our best posts of 2011. As we look back at the year – and ahead to what next year holds – we think these are the stories that deserve a second glance. It’s not just a best-of list, it’s also a collection of posts that examine the fundamental issues that continue to shape the Web. We hope you enjoy reading them again and we look forward to bringing you more Web products and trends analysis in 2012. Happy holidays from Team ReadWriteWeb! iMockups for Wireframing Concepts If a picture is worth 1,000 words, then a good mockup is worth 1,000 lines of code. If you own an iPad, iMockups is a killer solution to quickly and efficiently create wireframes. It’s been interesting to watch a number of the startups I advise shift from trying to use PowerPoint or Keynote to flesh out concepts, to using iMockups. The feedback from those startups has consistently been that the iMockups tool makes it so much faster to put wireframes together that the time savings was well worth the $10. Check out the video below to see iMockups in action: sean ammirati Top Reasons to Go With Managed WordPress Hosting Feedback on Concept from Target Market Once you’ve got a concept put together, it’s often valuable to get some early feedback from your target market. Obviously, in many cases this can be done by setting up meetings with your target customers and walking them through the idea. 8 Best WordPress Hosting Solutions on the Marketlast_img read more

Getting into the Game: Social Gaming in the Google+ Era

first_img5 Outdoor Activities for Beating Office Burnout Tags:#Facebook#gaming#Google#web 4 Keys to a Kid-Safe App brian doll Social gaming has come a long way since your friend asked you to check out her farm on Facebook. Some estimates suggest that over a million developers worldwide are busily adding to the more than 50,000 games and applications already available on Facebook alone.In 1994, the gaming world was taken by storm when Blizzard Entertainment launched World of Warcraft, which not only became their best-selling PC game but ballooned into 11 million active players in just 14 years. However, this is a drop in the bucket compared to what the current popular social games see on a regular basis. Zynga’s CityVille has been reported to have nearly 76 million active monthly players and there are at least 30 other games with over 10 million active monthly users right behind it.Brian Doll has been building things on the web for over 14 years and has extensive experience in retail, media, technology and financial service industries in both start-up and large enterprise environments. Currently, he is the principal performance analyst for New Relic, a company specializing in web application performance management. Today, the scale of social gaming is staggering, and gaming companies and non-gaming companies alike are doing anything they can to get in on the social gaming craze. But there are significant, although nuanced, differences between the two most popular gaming platforms, Facebook and new entrant Google+. Before jumping into the fray, gaming companies should understand how these two platforms have evolved and the best ways to take advantage of their existing technologies/capabilities. Key players in the social gaming realmSo far Facebook has carved out its place as the most popular social gaming platform — until Google debuted its own social network, Google+, earlier this year. Unsurprisingly, Google quickly announced the availability of games on Google+, marking the start of a heated battle for user attention and dollars in the social gaming space.Google has not fully released APIs or announced its plans for virtual currency or revenue share on its new platform. So in the meantime, developers need to consider not only the new different technology and capabilities offered by Google+, but also the nature of this new audience. Both of these aspects may play an important role in attracting developers beyond the sheer size of the potential Google audience.When Google introduced games to Google+, they also drew the line where games would and wouldn’t appear on their platform. Most notably, games on the site will not appear in users’ streams, and they are only visible when browsing the Games tab. This is in stark contrast to the early days of Facebook, where games quickly filled nearly everyone’s wall, regardless of their interest in playing them. It may be common sense now to keep games off in their own corner, but this move may have a big impact on the success of viral games on this new platform.Strategies for game developersBy being separated from the rest of the Google+ experience, gaming companies will need to find new ways to attract non-gamers. Many companies with popular Facebook games indicate that very few of their players come from gaming backgrounds. By bringing non-gamers into social games, Facebook has expanded the pie for [any gaming company who uses their platform], which may prove difficult for Google+ to match. However, while there is still much to be revealed about the nature of the Google+ APIs and monetization processes, developers should go back to their roots and focus on game-play rather than attracting players. The best initial strategy for companies looking at Google+ is to focus on creating games that are worth playing, and therefore games that both gamers and non-gamers will seek out without the help of viral promotion through the Google+ streams. While first and foremost, companies need to deliver a seamless gaming experience that gives people a reason to play, arguably the most important part of social games is the social part. Game makers need to make good use of the API provided by social networks to lure in new players, add more interactivity into their games, and keep players coming back for more. Successful social games take first-time players and quickly reward them for every tiny achievement. Then the games gradually ramp up their complexity and the rewards. Within a few minutes, players will have learned their way around the game and have been rewarded enough to keep them engaged and looking for more. It takes large and highly scalable systems to support tens of millions of users with such short attention spans and a high thirst for action. Social games spread virally, and a successful game may reach millions of users in just a day or two. To support applications at web-scale, developers for both Facebook and Google+ games need to be very aware of the resources required to support their users. With modern cloud providers, adding thousands of new servers is no longer difficult. Building an application that scales linearly to that degree, however, still is. While first and foremost, companies need to deliver a seamless gaming experience that gives people a reason to play, arguably the most important part of social games is the social part. Game makers need to make good use of the API provided by social networks to lure in new players, add more interactivity into their games, and keep players coming back for more. One example of this on the Facebook platform is the use of special free gifts within the games that can then be shared with friends. Enabling players to share in-game gifts with friends who may not otherwise be playing that game is a perfect example of the ubiquity of social games. The player gets the “karmic” reward for having given the gift, the friend receives a free gift, and the game maker likely just attracted one more player. Google+ game developers will be faced with similar challenges once more is known about the APIs and should consider what types of in-game rewards might be leveraged to encourage players to continue playing. For now, we may see Google+ games focus more on time spent in-game instead of the number of new players. Innovation drives successSo what does this mean for the future of social gaming? Much like the rest of the web, the only constant is change. Companies will be wise to learn the ways of the ever-evolving face of social gaming. Getting and keeping the attention of the millions playing online games isn’t easy, but missing this opportunity will likely lead to nothing but regret.What, then, is the right strategy for companies looking to make waves in the social web? It’s easy to get caught up in all the buzzwords like gamification, monetization, shareability and engagement, but we need to remember that the engine that drives the social web is providing experiences that are worth sharing in the first place.Pinball machine photo by James Brookscenter_img Related Posts 9 Books That Make Perfect Gifts for Industry Ex… 12 Unique Gifts for the Hard-to-Shop-for People…last_img read more

Proposed Regulations Reduce Section 956 Income Inclusions (NPRM REG-114540-18; IR-2018-210)

first_imgProposed regulations will reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The proposed regulations are intended to ensure that Code Sec. 956 is applied consistently with the new participation exemption system under Code Sec. 245A.Subpart F RulesUnder the subpart F rules, U.S. shareholders of CFC are currently taxed on their pro rata shares of the CFC’s subpart F income without regard to whether the income is distributed to the shareholders (Code Sec. 951(a)). Subpart F income generally includes passive income and other income that is readily movable from one taxing jurisdiction to another (Code Sec. 952). A U.S. shareholder is a United States person (e.g., individual citizen, domestic corporation, etc.) that owns or is treated as owning 10 percent or more of the voting power or value of a foreign corporation (Code Sec. 951(b)).The U.S. shareholders of a CFC are taxed on their pro rata share of the CFC’s earnings that are invested in U.S. property during the tax year and not distributed or otherwise taxed (the “Section 956 amount”). U.S. shareholders are effectively taxed on foreign source earnings brought back into the United States, on the theory that the returned earnings are substantially the same as a dividend. This rule is intended to create symmetry by taxing effective repatriations of earnings in the same manner as actual repatriations of earnings are taxed.Participation DRDThe Tax Cuts and Jobs Act (TCJA) (P.L. 115-97) added Code Sec. 245A, which allows a 100-percent participation exemption deduction—a participation dividends-received deduction (DRD)—for the foreign-source portion of dividends received from a specified 10-percent owned foreign corporation by a domestic corporation that is a U.S. shareholder of the foreign corporation. A specified 10-percent owned foreign corporation is any foreign corporation (other than certain passive foreign investment companies) in which a domestic corporation is a U.S. shareholder.However, a domestic corporation cannot claim a participation DRD for a dividend on any share of the foreign corporation’s stock:that the domestic corporation holds for 365 days or less during the 731-day period that begins on the date that is 365 days before the date when the share becomes ex-dividend with respect to the dividend; orto the extent the domestic corporation is obligated to make related payments on positions in substantially similar or related property (Code Sec. 246(c)).Under the TCJA rules, a Section 956 inclusion in the gross income of a corporate U.S. shareholder is not eligible for the participation DRD because it is not a dividend.Tax Treatment SymmetryThe new participation DRD exemption system has made the current broad application of Code Sec. 956 to corporate U.S. shareholders inconsistent with the Code section’s purposes and the scope of the transactions it is meant to address. In response, the proposed regulations:exclude corporate U.S. shareholders from the application of Code Sec. 956 to the extent necessary to maintain symmetry between the taxation of actual repatriations and the taxation of effective repatriations, so that neither an actual dividend to a corporate U.S. shareholder nor the shareholder’s Section 956 amount will result in additional U.S. tax; andreduce the Section 956 amount otherwise determined regarding a U.S. shareholder for a CFC’s tax year, to the extent that the shareholder would be allowed a participation DRD had the shareholder received a distribution from the CFC equal to the Section 956 amount otherwise determined.Under the proposed regulations, in many cases a corporate U.S. shareholder will not have a Section 956 inclusion as a result of a CFC holding U.S. property.Code Sec. 956 will still apply without modification to noncorporate U.S. shareholders such as individuals, to ensure that amounts substantially equivalent to a dividend are treated similarly to actual dividends. This treatment will apply regardless of whether individuals elect under Code Sec. 962 to be taxed at corporate rates.Further, Code Sec. 956 will still apply without reduction to regulated investment companies (RICs) and real estate investment trusts (REITs), because they are not allowed to claim the participation DRD.Applicability DateThe proposed regulations will apply to:a CFC’s tax years beginning on or after the date that the Treasury decision adopting these rules as final is published in the Federal Register (“finalization date”); anda U.S. shareholder’s tax years in or with which the CFC’s tax years end.Further, for a CFC’s tax years beginning before the finalization date, if a taxpayer and U.S. persons related to the taxpayer consistently apply the proposed regulations for all CFCs in which they are U.S. shareholders, then the taxpayer can rely on the proposed regulations for:a CFC’s tax years beginning after December 31, 2017; anda U.S. shareholder’s tax years in or with which the CFC’s tax years end.CommentsWritten or electronic comments and requests for a public hearing must be received by 30 days after the notice of proposed rulemaking is published in the Federal Register. Send submissions to: CC:PA:LPD:PR (REG-114540-18), Internal Revenue Service, Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered between the hours of 8:00 a.m. and 4:00 p.m. to CC:PA:LPD:PR (REG-114540-18), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue N.W., Washington, DC, or sent via the Federal eRulemaking Portal at (REG-114540-18).Proposed Regulations, NPRM REG-114540-18IR-2018-210Other References:Code Sec. 956CCH Reference – 2018FED ¶28,571DTax Research ConsultantCCH Reference – TRC INTLOUT: 9,250Login 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

5G Is a Huge Opportunity for TEMs

first_imgBy Caroline Chan, Wireless access segment manager, Network Platform Group, IntelNo matter where you fit in the wireless food chain, expect the transition to 5G to be exhilarating. The demand for new devices and mobile infrastructure will be incredible, making the coming years a very busy time for telecommunications equipment manufacturers (TEMs). First deployments in 2020 is a realistic objective, according to a panel of industry leaders hosted by Frost & Sullivan.15G VisionAlthough final requirements haven’t been ironed out yet, major industry players already have high aspirations for 5G. This includes major performance improvements such as an order of magnitude reduction in latency (both air and end-to-end) and more than a ten times increase in peak data rate. There will also be provisions for critical service assurance for connected cars and very low-rate services for the billions of Internet of Things (IoT) devices that come online.Along these lines, the Next Generation Mobile Networks (NGMN) Alliance recently released a 5G white paper proposing requirements around system performance, user experience, devices, business models, management and operation, and enhanced services.25G Technology at MWC 2015To no one’s surprise, 5G was a key theme at this year’s Mobile World Congress. “Huawei, Ericsson, and Nokia Networks demonstrated technology that forms the basis of their 5G road maps; and some leading operators, such as Deutsche Telekom, also spoke about how developments, including network functions virtualization (NFV) and software defined networks (SDN), are making 5G possible,” wrote Monica Alleven, editor of FierceWirelessTech.3Sky-High ForecastsOver time, 5G infrastructure is expected to serve around ten thousand times more devices than are currently connected to mobile networks, with IoT devices and cars accounting for a large part of the growth. This trend will ultimately generate a tremendous amount of business for TEMs per Intel’s 5G vision reflected in the following:Radio access network (RAN) capacity expands by 1,000 times to increase mobility and coverage for subscribers, IoT devices, and cars. This includes more radio towers, smart cells, and remote radio heads (RHHs) supporting Cloud-RAN (C-RAN) deployments.Mobile core adds 100 times more capacity to meet the growing traffic demand. This is primarily evolved packet core (EPC) equipment, which today is represented by various LTE network elements:Serving Gateway (Serving GW)PDN Gateway (PDN GW)Mobility Management Entity (MME)Policy and Charging Rules Function (PCRF) ServerHome Subscriber Server (HSS)Backhaul capacity is expected to increase ten-fold. It is the infrastructure, like routers, switches, fiber, and microwave, that connects a cell site to the mobile core.Virtualized InfrastructureThe momentum behind virtualized equipment will grow stronger with 5G, as SDN and NFV advancements continue and spread to the RAN, customer-premises equipment (CPE), and other devices. Look for new services based on big data to influence the way networks are being constructed and monetized.5G is looking like a wonderful opportunity for TEMs, perhaps even better than the first four generations of mobile networks. Read more about Intel’s 5G vision at Source: Jessy Cavazos, Frost & Sullivan, “5 insights about 5G that may surprise you,” March 17, 2105, Source: Next Generation Mobile Networks (NGMN) Alliance, “NGMM 5G White Paper,’ February 17, 2015, in a new windownews/NGMN5GWhitePaperV10.pdf.3 Source: Monica Alleven, FierceWirelessTech, “MWC 2015: NGMN Alliance, Huawei, Ericsson, Nokia talk 5G and more,” March 9, 2015,© 2015, Intel Corporation. All rights reserved. Intel and the Intel logo are trademarks of Intel Corporation in the U.S. and/or other countries. *Other names and brands may be claimed as the property of others.last_img read more