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It was a pleasure meeting with Chief Minister Fabian Picardo and his team today for the seventh JMC GEN. We spoke at length about the key issues facing both the UK and Gibraltar as we leave the EU and reaffirmed the continued commitment of the UK Government to represent the best interests of the entire UK family, including our friends in Gibraltar. We look forward to continuing our constructive partnership over the coming months, years and beyond. Chief Minister of Gibraltar, Fabian Picardo said: The UK and Gibraltar have confirmed their commitment to continue to work together to achieve a Brexit deal that fully recognises the priorities of the Rock.At the latest Joint Ministerial Council (Gibraltar EU Negotiations) in London today, which was chaired by Minister at the Department for Exiting the EU, Robin Walker, and attended by the Chief Minister for Gibraltar Fabian Picardo and his team, Ministers agreed to continue to fully involve Gibraltar in the UK’s negotiations with the EU.They discussed the practical implications of our EU Withdrawal for Gibraltar. Officials from across Government provided an update on developments in the reciprocal package announced at the 8 March JMC, including on the issue of access to higher education and on further building on existing health cooperation.Following the meeting, Minister Robin Walker said: It is a genuine pleasure to continue working with Robin Walker on the Brexit issues that he has responsibility for at the Department for Exiting the European Union and which are relevant to Gibraltar. Through DExEU we are engaging with the whole of Whitehall on matters which will have a positive impact in Gibraltar in coming years and which affect all parts of our economic activity as we prepare to leave the European Union with the United Kingdom next March.
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Embed from Getty ImagesWalter Mazzarri played down an apparent confrontation between Watford team-mates Stefano Okaka and Troy Deeney after his side’s 4-3 defeat at Chelsea.Hornets boss Mazzarri said he was unaware of the incident but insisted he was not concerned.“They are friends. They are always together and joking with each other,” Mazzarri said.“You want players with character who talk to each other on the pitch. Tomorrow I will investigate but I think it was nothing.” Ads by Revcontent Trending Articles Urologists: Men, Forget the Blue Pill! This “Destroys” ED x ‘Genius Pill’ Used By Rich Americans Now Available In Netherlands! x What She Did to Lose Weight Stuns Doctors: Do This Daily Before Bed! x One Cup of This (Before Bed) Burns Belly Fat Like Crazy! x Men, You Don’t Need the Blue Pill if You Do This x Do This Immediately if You Have Diabetes (Watch) x Follow West London Sport on TwitterFind us on Facebook
As reported here numerous times (e.g., 06/14/2004, 12/04/2003, 04/14/2003, 03/28/2003, 02/25/2003, 12/17/2002, 09/26/2002, 03/26/2002, 02/01/2002, 12/06/2001, 08/17/2001, 06/19/2001, 02/21/2001), cells have an elaborate interstate highway system with molecular trucks hauling cargo back and forth. Scientists have known that the cellular highways have polarities labeled plus and minus, and that molecular motors typically go one way. Some motors, like kinesin, drive only in the plus direction, while others, like dynein, go in the minus direction. Now, it is becoming apparent that most pieces of cargo have at least one of each kind of motor, with a stickshift that allows it to drive in forward or reverse. The state of our knowledge about bidirectional transport is explored by Michael Welte in the July 13 issue of Current Biology.1 Welte examines the evidence that many, maybe all, moving cargoes have bidirectional ability. In the microscope, certain organelles like mitochondria and melanosomes are seen to move back and forth rapidly, eventually making it to their target. Why is this, and how is it done? Does the organelle grab motors out of the cytoplasm? Are both motors working in a tug-o’war? Welte cites evidence against these possibilities, and suggests (although hard evidence needs to be found), that the cargo carries both motors, and a “complex coordination machinery … ensures that when one motor is actively engaged with the microtubule, the other motor is turned off.” Moreover, this coordination machinery, whatever it is, may be under the influence of regulatory enzymes. “If the coordination machinery can attach to cargo independent of the motors,” he surmises, “distinct variants of the coordination machinery could be targeted to different cargoes, thus allowing cargo-specific coordination and regulation.” It seems odd, though, that cargoes would undergo a back-and-forth random walk instead of making a beeline to the target. Welte figures there must be biological justification for this behavior, so he examines some possibilities:Economy: “If cargoes always carry motors for both directions, net transport can easily be adjusted or even reversed by simply tweaking the relative activity of the two motors. This is likely to be much quicker than assembling a new set of motors on a cargo, and also allows transport to be abruptly altered depending on cellular needs. It even makes it possible to tune the overall speed of transport by altering the relative contribution of trips in the non-dominant direction.”Setting Up Polarized Distributions: “Sometimes it is necessary to set up a distribution rather than to confine the organelles to a single point …. Even if cargoes accumulate at a certain point (e.g. near plus-ends when motion is biased in the plus-end direction), trips in the non-dominant direction will tend to spread the cargoes out along the tracks, away from the point of accumulation. Modeling shows that by altering the relative contributions of plus- and minus-end trips, a wide range of steep to flat steady-state distributions can be achieved.”Avoiding Obstacles and Exploring Space: “As cytoplasmic dynein often steps sidewise to adjacent proto-filaments, a bidirectional cargo could find itself on the opposite side of the microtubule even after a short minus-end excursion. If it now switches back to kinesin I, it can pass the obstacle. Bidirectionally moving cargoes should, therefore, be less likely to contribute to disastrous traffic jams …. The random walk of bidirectional cargoes allows a single cargo to explore a large region of cellular space, especially if tracks are disordered.”Error Correction: “During unidirectional transport, the critical event that determines directionality of motion is the attachment to either a plus- or minus-end motor. A wrong attachment will cause misdelivery of the cargo. During bidirectional transport, the net direction of transport is determined by the balance of plus- and minus-end trips and can, therefore, be continually evaluated and even altered if physiological conditions change. Thus, bidirectional transport may facilitate error correction.It must be remembered that these motors are operating in the dark without eyes, like automated railroad cars. They don’t have sentient drivers on radios, but rather respond to chemical signals in the environment. Apparently these behaviors achieve the best solution to many complex problems. “Bidirectional transport by opposite-polarity microtubule motors is just one example of multiple motors working together to achieve carefully choreographed transport,” Welte says, as he concludes with a list of open problems needing further elucidation.1Michael A. Welte, “Bidirectional Transport along Microtubules,” Current Biology, Volume 14, Issue 13, 13 July 2004, Pages R525-R537, http://dx.doi.org/10.1016/j.cub.2004.06.045.Think of a 12-year-old kid on motorized rollerblades, one foot going forward, the other reverse. Imagine the tricks he could accomplish (with a little practice) switching from one foot to the other (or the bloody knees as he experiments the first time). Now make the wheels run on monorails. Imagine a complex tangle of rails, some blue, some red, going off in all directions, more dizzying than an amusement park roller coaster. The kid is supposed to put the left foot on the red rails and the right foot on the blue rails (one foot at a time, of course). Now hand him a package to deliver, and put a thousand other kids on the system going in all directions with packages of their own. The rails are also in constant motion, some growing and some shrinking. If the mental picture is becoming too complicated to dwell on further, just realize that something like this is happening in every cell of your body right now. This intracellular transport system is only a small part of a miniaturized city with many other vital tasks being performed flawlessly. The transportation system alone has a large infrastructure of support services. There are linemen for the monorails, pit crewmen for motor repair, traffic cops, construction crews, shippers, receivers and much more, without even considering what the cargoes are and what they do when they arrive. The interior of a cell is a whirlwind of constant activity, all necessary just to sustain life. Rocks do not do this. Evolutionists may jawbone about these systems emerging from chance and natural selection over millions of years of purposeless motion, but the more we can exhibit the details of cellular perfection, the less plausible their story is going to seem to any rational observer. This system is crying out for visualization. The wonder of intracellular transport would come alive if magnified a million times.2(Visited 10 times, 1 visits today)FacebookTwitterPinterestSave分享0
With many state legislatures in full swing, state responses to changes in the NOL deduction made by the Tax Cuts and Jobs Act of 2017 (P.L. 115-97) (TCJA) are becoming more clear. States differ in how they treat the changes on state corporate income tax returns, but the responses are closely tied to state conformity. Being aware of these changes and the trends in state responses can provide tax planning opportunities for corporate income taxpayers.Net Operating Losses under the Tax Cuts and Jobs Act of 2017The TCJA made several important changes to the rules governing net operating loss carryover deductions that impact state taxes. These changes include:limiting the NOL deduction to 80% of taxable income in the carryforward year;eliminating the NOL carryback period; andallowing an indefinite NOL carryforward period.NOLs sustained prior to the effective date of these changes are governed by prior law.Before the Tax Cuts and Jobs Act (TCJA) was enacted, a NOL could be carried back two tax years and carried forward up to 20 years. A limitation based on taxable income was also not imposed by the Code.How Are States Responding to the 80% Limitation?Under TCJA, while the new carryforward period is indefinite, the NOL deduction is limited to 80% of taxable income in the carryforward year. This change prohibits corporations from using NOLs to completely eliminate tax liability.Most state responses are determined by whether the state NOL deduction is based on the IRC, or more specifically, IRC Sec. 172. States like Alaska and Florida expressly reference IRC Sec. 172 in their controlling statute. As such, they follow the new 80% limit.However, the majority of states are not impacted by this change at this point.How Are States Responding to Elimination of the Federal NOL Carryback Period?The elimination of the two-year federal carryback period has not impacted many states’ carryback periods. This is largely because many states did not permit carrybacks prior to the enactment of TCJA.A small minority of states that expressly conform to the federal carryback period are seeing a decrease in their state’s carryback periods. For example, Delaware and Georgia specifically follow federal law in regards to federal NOL carryback periods.Additionally, some states have recently enacted legislation to eliminate the NOL carryback period. For example, Utah passed a law prohibiting NOL carrybacks in July 2018. Prior to enactment, a Utah net loss could be carried back three taxable years.How Are States Responding to Indefinite Federal NOL Carryforward Period? The largest group of states seeing a change resulting from the TCJA changes are those that conform the state carryforward period to IRC Section 172(b). These states provided a 20 year carryforward period, but now allow NOLs to be carried forward indefinitely. Examples of states impacted in this way include:Colorado;District of Columbia;Florida;Georgia; andSouth Carolina.By Catherine S. Agdeppa, J.D.Login to read more on CCHAnswerConnect.Not a subscriber? Sign up for a free trial or contact us for a representative.
The New Jersey tax court denied an intellectual property (IP) holding company’s summary judgment request regarding income tax nexus because the necessary facts were not properly before it.IP Holding Company’s StructureThe taxpayer was a Delaware holding company with offices located in Illinois. It owned and developed intellectual property such as patents, know-how, technology, and trademarks.The company’s affiliate developed, manufactured, marketed, and sold containers, related products and provided associated services. The affiliate had New Jersey-based customers and did business in New Jersey.Licensing AgreementsThe company had two license agreements with the affiliate granting it the right to use certain IP owned by the company. Under the agreements, the affiliate paid royalties of:3% on net sales of the licensed products; and2.8% on the licensed IP.In addition, the company granted an exclusive license to the affiliate for other IP. The affiliate paid the company 50% of the royalties it received for any sublicenses of that exclusive IP.New Jersey AuditNew Jersey audited the company and:assigned all the royalty payments to the company;apportioned all the royalty income to the company using the affiliate’s apportionment factor; andassessed over $2 million in tax liability, including interest and penalties.The company’s Illinois combined return did not include the royalty income in numerator of the company’s Illinois sales fraction. So, New Jersey apportioned 0% of that income to Illinois.Company Denies Nexus Exists with New JerseyThe company claimed it did not have nexus with New Jersey. It argued that New Jersey’s taxation would violate the Due Process Clause in the U.S. Constitution or the substantial nexus factor under the Commerce Clause.The company claimed its only connection to New Jersey was the use of its IP by the affiliate in New Jersey. For example, the affiliate’s use of the IP on:employees’ business cards, stationary, or other advertising material given to potential customers;shipping materials used to ship the affiliate’s products into New Jersey; andproducts, but only in an inconspicuous manner.The affiliate rented storage space in New Jersey for packaging products during certain periods. But neither the affiliate nor any related member owned, used, or leased any office, retail outlet, warehouse, or other building in New Jersey.Applying Lanco, Inc. v. Dir. Div. of Taxation, New Jersey argued the company was doing business in New Jersey because the company received New Jersey-sourced royalty income. Under Lanco, a taxpayer’s economic presence in New Jersey satisfies the Commerce Clause nexus standard if the taxpayer has royalty income from the use of its IP by an affiliate in New Jersey.Facts Introduced at Oral ArgumentIn the hearing for summary judgment, the company argued it did not have nexus with New Jersey under Lanco. Facts distinguishing the company from the taxpayer in that case included:the company was not a standard, passive, shell Delaware holding company that owned and licensed IP to a subsidiary;the affiliate was not a retailer;the affiliate never manufactured products in New Jersey;the affiliate’s customers were not retailers;the affiliate manufactured special order packaging products;neither the company nor the affiliate had any control over where or how customers sold their products contained in the affiliate’s packages; andthe company’s IP was used at most in three instances and it was barely visible on the affiliate’s products.Tax Court AnalysisThe tax court did not find for summary judgment. The company introduced many facts for the first time at oral argument. New Jersey needed the opportunity to make a factually based determination. Until New Jersey had that opportunity, the court could not rule that the company did not have nexus.Despite its ruling, the court did discuss the facts of Lanco and the facts presented by the company at oral argument. It noted questions that those facts raise.The court noted that like the taxpayer in Lanco:the company owned and licensed IP to a New Jersey affiliate for the manufacture and sale of the affiliate’s products;it received royalty income based on the net sales amount; andits affiliate had New Jersey-based customers and did business in New Jersey.However, the court agreed that some of the facts could raise questions about New Jersey’s authority to require filings. Among those questions:Did the taxpayer’s remoteness from the use of its IP and lack of control over placement of the affiliate’s products in New Jersey raise Due Process or Commerce Clause issues?Did the taxpayer purposefully avail itself of New Jersey’s economic market?Did the taxpayer purposefully exploit the New Jersey market and have more than a de minimis presence in the state?Did the taxpayer’s royalty income from New Jersey sources create either minimum contacts for Due Process Clause purposes or substantial nexus for Commerce Clause purposes?The court reasoned that even if the company received royalty income from the use of IP in New Jersey it could show that it lacked minimal contacts or derivate nexus. The licensing agreements indicated the company intended the affiliate to use the IP on a world-wide basis, including New Jersey. However, the company’s lack of control over where and how the affiliate’s customers sold their products could weaken the “purposeful availment” factor of the nexus test.The company could also lack the quality or quantity of contacts necessary to be substantial under the Commerce Clause and Due Process Clause analysis. Lanco did not address this issue.By Andrew Soubel, J.D.Login to read more on CCHAnswerConnect.Not a subscriber? Sign up for a free trial or contact us for a representative.
Don’t miss out on the latest news and information. WATCH: Streetboys show off slick dance moves in Vhong Navarro’s wedding Hamilton now has 238 points, three more than Vettel with seven races remaining in what has developed into a riveting Formula One season.Vettel had led the standings all season but Ferrari struggled in rainy qualifying conditions Saturday and couldn’t match Mercedes’ race pace, either, on a Monza circuit featuring long straights and high speeds better suited to Mercedes’ power.FEATURED STORIESSPORTSWATCH: Drones light up sky in final leg of SEA Games torch runSPORTSSEA Games: Philippines picks up 1st win in men’s water poloSPORTSMalditas save PH from shutoutFly-away races make up the rest of the F1 calendar, starting with the Singapore GP in two weeks. View comments Catriona Gray spends Thanksgiving by preparing meals for people with illnesses Mercedes driver Lewis Hamilton of Britain steers his car during the Italian Formula One Grand Prix, at the Monza racetrack, Italy, Sunday, Sept. 3, 2017. (Photo by LUCA BRUNO / AP)MONZA, Italy — Lewis Hamilton won the Italian Grand Prix virtually unchallenged from pole position Sunday and moved ahead of Sebastian Vettel to take the lead in the drivers’ standings.Hamilton finished nearly five seconds ahead of Mercedes teammate Valtteri Bottas while Vettel came third in his Ferrari, more than half a minute behind.ADVERTISEMENT MOST READ Read Next LOOK: Venues for 2019 SEA Games SEA Games in Calabarzon safe, secure – Solcom chief Kammuri turning to super typhoon less likely but possible — Pagasa Trending Articles PLAY LIST 00:50Trending Articles00:50Trending Articles01:27Filipino athletes get grand send-off ahead of SEA Games01:37Protesters burn down Iran consulate in Najaf01:47Panelo casts doubts on Robredo’s drug war ‘discoveries’01:29Police teams find crossbows, bows in HK university01:35Panelo suggests discounted SEA Games tickets for students02:49Robredo: True leaders perform well despite having ‘uninspiring’ boss02:42PH underwater hockey team aims to make waves in SEA Games San Beda downs TIP in 4 sets Typhoon Kammuri accelerates, gains strength en route to PH UPLB exempted from SEA Games class suspension LATEST STORIES Brace for potentially devastating typhoon approaching PH – NDRRMC
Japan ex-PM Nakasone who boosted ties with US dies at 101 QC cops nab robbery gang leader, cohort Trending Articles PLAY LIST 00:50Trending Articles00:50Trending Articles01:08Smash hit? Tesla suffers broken glass mishap at launch of new truck01:37Protesters burn down Iran consulate in Najaf01:47Panelo casts doubts on Robredo’s drug war ‘discoveries’01:29Police teams find crossbows, bows in HK university01:35Panelo suggests discounted SEA Games tickets for students02:49Robredo: True leaders perform well despite having ‘uninspiring’ boss02:42PH underwater hockey team aims to make waves in SEA Games CPP denies ‘Ka Diego’ arrest caused ‘mass panic’ among S. Tagalog NPA Read Next MOST READ Brace for potentially devastating typhoon approaching PH – NDRRMC Stronger peso trims PH debt value to P7.9 trillion Detroit Pistons forward Tobias Harris (34) goes to the basket against Sacramento Kings forward Zach Randolph (50). APDETROIT — Detroit coach Stan Van Gundy knew during the offseason that he needed another piece to get the Pistons into playoff contention in the Eastern Conference.It appears he found the right player in Avery Bradley.ADVERTISEMENT Don’t miss out on the latest news and information. Kammuri turning to super typhoon less likely but possible — Pagasa The Pistons had 18 points off Sacramento turnovers, while the Kings only had nine. They have recorded more points off turnovers than their opponent in nine of their 10 games.“This wasn’t our best game, but we were able to get some stops when we needed them,” Harris said. “We’re building off each other, and that’s a good thing.”Sacramento (1-8) lost its seventh straight game and gave up more than 100 points for the sixth time in a row. Zach Randolph led the Kings with 19 points, and Bogdan Bogdanovic added 14.“This is a learning experience,” Kings coach Dave Joerger said. “It was a small-ball game tonight, and they were able to hurt us with that.”Back-to-back 3-pointers by Reggie Jackson and Harris gave the Pistons a 77-69 lead late in the third quarter. Detroit led 85-74 heading into the fourth, and held off a brief Sacramento surge early in the period.ADVERTISEMENT “That wasn’t an easy win by any means,” Van Gundy said. “We didn’t have a lot of energy, and their starting lineup gave us a lot of trouble, but we were able to grind it out.”The Pistons scored the game’s first 10 points, but Randolph scored 10 points in the first quarter to keep the Kings close. Sacramento led briefly in the second quarter, but Bradley’s 13 points were enough to give Detroit a 52-49 lead at halftime.“It seemed like we were down four points around 80 times tonight, but we could never put together the big run we needed,” Joerger said. “We talked about how much ball pressure they use, and then we would come down three times and they would deflect three passes.”TIP-INSKings: Randolph’s first-quarter scoring started moments after Michigan State’s winning field goal against Penn State was shown on the Little Caesars Arena scoreboard, accompanied by the MSU fight song. Randolph went to the Final Four as a Spartan in 2001.Pistons: Jon Leuer (ankle sprain) missed the game, while Johnson is day to day after leaving in the third quarter with a sore hip flexor. LATEST STORIES Bradley scored 24 points, Andre Drummond had 16 points and 19 rebounds, and the Pistons beat the Sacramento Kings 108-99 on Saturday (Sunday Manila time).The 26-year-old Bradley went 10 for 15 from the field. He was acquired in a trade with Boston in July.FEATURED STORIESSPORTSWATCH: Drones light up sky in final leg of SEA Games torch runSPORTSSEA Games: Philippines picks up 1st win in men’s water poloSPORTSMalditas save PH from shutout“I’ve said this several times, but he has really changed the defensive demeanor of our team,” Van Gundy said. “He doesn’t deserve all of the credit — moving Stanley (Johnson) into the starting lineup has also helped — but we’re playing much better defense with Avery on the floor.”Tobias Harris added 20 points for Detroit (7-3), which won for the fifth time in six games. Typhoon Kammuri accelerates, gains strength en route to PH Johnson still 2 options for chance at 8th NASCAR Cup title John Lloyd Cruz a dashing guest at Vhong Navarro’s wedding View comments
MANILA, Philippines—Christian Balagasay made the game-winning basket and Petron-Letran escaped St. Clare College Virtual Reality, 91-90, in the 2019 PBA D-League at JCSGO Gym in Cubao.ADVERTISEMENT Panelo: Duterte ‘angry’ with SEA Games hosting hassles Hontiveros presses for security audit of national power grid DA eyes importing ‘galunggong’ anew SEA Games hosting troubles anger Duterte Balagasay hit the go-ahead layup off an assist by Jerrick Balanza with 13 seconds left as the Knights gained solo third place in the Aspirants Group with a 5-2 record.Alvin Pasaol powered Letran with a game-high 28 points, including eight of his team’s last 11 points, that went with seven rebounds and three assists.FEATURED STORIESSPORTSPrivate companies step in to help SEA Games hostingSPORTSPalace wants Cayetano’s PHISGOC Foundation probed over corruption chargesSPORTSSingapore latest to raise issue on SEA Games food, logisticsBalanza added 22 points while Jeo Ambohot contributed 11 points and nine rebounds.The Saints squandered their chance to steal the game but their last possession ended with a turnover after Junjie Hallare was called for an illegal screen with 1.7 ticks to go. Private companies step in to help SEA Games hosting LATEST STORIES Don’t miss out on the latest news and information. Dave Marcelo fined P20k, dodges suspension for flagrant 2 on Standhardinger Hallare led St. Clare’s fightback from 28 points down with 13 of his team-high 22 coming in the final frame. The Saints dropped to 4-2.Sports Related Videospowered by AdSparcRead Next PH underwater hockey team aims to make waves in SEA Games PLAY LIST 02:42PH underwater hockey team aims to make waves in SEA Games01:44Philippines marks anniversary of massacre with calls for justice01:19Fire erupts in Barangay Tatalon in Quezon City01:07Trump talks impeachment while meeting NCAA athletes02:49World-class track facilities installed at NCC for SEA Games02:11Trump awards medals to Jon Voight, Alison Krauss Duterte wants probe of SEA Games mess MOST READ View comments Philippine Arena Interchange inaugurated Cayetano: Senate, Drilon to be blamed for SEA Games mess