Ricardo Cunningham is making gains in his move from the 800 to the 400 metres hurdles. On Saturday, June 3, he set a personal best of 49.55 seconds in a victory at the National Stadium at the third JAAA All Comers meet of the season. Now 35, Cunningham says 2004 Olympic 400 metre hurdles runner-up Danny McFarlane is one of his role models. Cunningham shot out of the blocks and disconnected 2013 World Youth champion Marvin Williams. Afterwards, he said, “that was the aim because I’ve been working on my first 250m in training.” Now at the University of Technology, Williams held on to second place with a time of 50.83 seconds. Cunningham was gratified by the 0.11 second reduction of his personal best. He described 2017 as a rough season. “I started out this year on my own until I got some technical help from Floyd Quarrie. “I had an interest in the 400 metre hurdles from 2010,” he recalled calmly of his days at the University of Technology and the MVP Track Club where maestro Stephen Francis is head coach, “and while at MVP, I wanted to take up the event but probably Mr Francis didn’t see me doing as well or probably just wanted me to focus on the 800m.” Nevertheless, he was Jamaica Inter-Collegiate champion and national champion and moved his personal best to 1 minute 47.14 seconds. To pursue his goals in the 400m hurdles, he left the MVP, spent the 2016 season at the Cameron Blazers Club, “and now”, he said, “this year I’m freelancing.” Quarrie, sprints and hurdles coach at Immaculate Conception High School and an adviser o a small band of senior athletes, says Cunningham’s new personal best puts him in a good spot. “49.5 now, I think, is putting him in good standing leading up into World Trials”, analysed the coach. Technical work Between now and the June 22 start date of the four-day National Senior Championships, Quarrie plans to have Cunningham work on the last part of the race. He thinks Cunningham’s 800m strength is an asset. “Having the 800m background that he has”, he said, “and I’ve been working on getting him faster and hurdling better so the plan is to contend with those top athletes breaking the 49 barrier.” Cunningham, the winner at the UTech Classic where he ran 49.98 seconds to beat 2016 Olympic finalist Annsert Whyte, is inspired by McFarlane who also made a late switch to the hurdles. “He’s certainly one of the guys that motivate me and make me know that it’s possible,” he said.
Dear Editor,As many Guyanese are aware, the Department of Energy announced this week that it plans to raise royalty rates for future contracts. This is an eminently sensible step given our streak of successful discoveries in the Stabroek Block and clear international interest in Guyana. Companies are queuing up for the show – they can pay for entry!I also note an advertisement in Kaieteur News comparing Guyana’s 2 per cent royalty with 35 other countries, which begs the question, “when will Guyana start demanding what it deserves?”Perhaps a bit of context would be helpful when considering the Kaieteur News advertisement. Royalty rates are determined by a number of other factors in any contract, such as a country’s share of profit oil, tax structures and project timelines. Most importantly, royalty rates usually reflect how established a country is as a producer and the extent of proven reserves.So why are all of these countries enjoying far higher royalty rates? Well, take a look at the table here, which examines the same countries:Guyana trails far behind every other nation on the list. Recall that when the 2 per cent royalty was agreed, we had just discovered oil and have still not produced a drop. So, we see that being a proven producer is key. Guyana’s exploration success certainly merits a rise in royalty rates, but I think we must proceed with the goal of establishing a track record as a reliable producer.Think what we may about whether the original 2 per cent royalty our Government negotiated was appropriate, we Guyanese made a commitment in the eyes of the international business community. That commitment has spurred companies like ExxonMobil, Total, Tullow and Hess to invest heavily in further exploration which has driven our value ever higher.Our officials and the Department of Energy have the leverage now – let us push them to drive a hard bargain on our future contracts. But let us also be aware that reneging on our old contracts may serve to unravel our appeal to those same future investors. If that is the route we choose, then so be it. But we must consider context, not potentially misleading facts and figures.Sincerely,Donald Sing
A massive family fun-day has been organized to celebrate the official opening of Cooneys Home and Garden Superstore. The family fun-day events starts tomorrow (SAT) at 12-noon and will finish at 4pm.Absolutely everyone is invited to attend the event, which promises to be a great day for all the family. To mark the official opening,young Ciaron Cooney, son of Gary the proprietor of this fantastic new retail outlet will officially open the retail store at 1pm.It’s going to be a real family fun day and for the kids Minnie and Mickey Mouse will be there as will be Sponge Bob and Minions.There will be stilt-walkers, fire performers, face painting, DJ, and weather permitting a Bouncy Castle.There will be numerous give-a-ways and prizes on the day so make sure you come along and joint in the celebrations and refreshments will be served. Cooneys Home and Garden opened their doors on Friday morning last and since then countless people have visited it.Great credit has to go proprietor Gary Cooney and to each and every member of staff and all the people who worked tirelessly to bring what was an empty 35.000 sq ft space less than fifty days ago to what it is today.Of course there are some things that have to be tweaked and with stock arriving daily for various departments the final pieces of the jigsaw are being put in place at Letterkenny’s newest superstore.There has been fantastic customer feedback from the opening weekend and with the Christmas countdown already underway those who visited the store were in awe with the Christmas Shop the likes of which has never been seen before anywhere in the country.It is truly magnificent and the layout, themes and stock has to be seen to be believed. Of course Cooneys Home and Garden is not just about Christmas and numerous loyal customers to Gary’s Pet World over the last twenty years were there in numbers to see this section for their pets that has been incorporated into the new outlet.The new look Gary’s Pet World is bigger and better than before yet retaining the name which has been and will continue to be a household one throughout the North-West and even further afield in the years to come.The Homeware section of the store also attracted much interest because of the fantastic range of stock available at unbeatable prices as did the Giftware and Workwear areas where again all stock is displayed and laid out in a very customer friendly way.Another beautiful feature of the new store is the way in which the Greeting Cards and Party Wear area has been incorporated into it. This is another section of the outlet that is going to be extremely busy with cards and accessories for every birthday and indeed all occasions.Although for many of us it is not Gardening weather there are those who keeps their green fingers active all year round and for them at this time of year there is everything you could ever need in this comprehensively stocked end of the store.Just wait and see what Cooneys Garden Centre will have for you come spring!Furniture has been arriving on a daily basis since the opening on Friday last so you will be spoiled for choice when you come along and view the beautiful range of furniture available for your home.For over twenty years Gary’s Pet World and Garden Centre was one of the most renowned retail outlets in the North West.And after only a week at Letterkenny Retail Park, ”Cooneys Home and Garden ”which incorporates Gary’s Pet World and much more is certainly attracting many customers.And there is every reason to suggest that this new megastore will soon establish itself as one of the leading outlets of its kind in the entire North-West and indeed even further afield.So each and every one of you is welcome to come along tomorrow Saturday to join in the fun and games that get under way at 12-noon until 4pm and for the cutting of the tape for the official opening at 1-o-clock.Congratulations and best wishes to Gary, his family and staff on this fantastic new venture.MASSIVE FAMILY FUN DAY TO CELEBRATE OFFICIAL OPENING OF COONEYS HOME AND GARDEN SUPERSTORE was last modified: October 24th, 2014 by Mark ForkerShare 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:BusinessCooneys Home and GardenFeaturesnewsofficial openingSuperstore
Parlour and Henry won many trophies together huge blow Oxlade-Chamberlain suffers another setback as Klopp confirms serious injury “We walk in and Thierry said, ‘Why don’t you look around the shop and pick some stuff up?’“I said, ‘Are you sure?’ No problem.“It was like Supermarket Sweep with the old trolley. I was putting everything in.“There was one occasion where I saw a little gap and put some socks in there. In the end, I couldn’t see over the trolley, I had to look round the side of it so I knew where I was going.“So we got to the checkout and Thierry has picked up a pair of trainers, his mum also has a pair of trainers. I’ve got this trolley full of stuff – golf clubs coming out of it. There are six live commentaries across the talkSPORT network this week. Find out what they are and where to hear them, below… RANKED 2 Which teams do the best on Boxing Day in the Premier League era? BEST OF Every time Ally McCoist lost it on air in 2019, including funny XI reactions ADVICE LATEST FOOTBALL NEWS “Thierry was becoming an absolute superstar at Arsenal,” Parlour said.“One afternoon he asked me if I wanted to go down to Nike Town with him.“They closed the shop down for him so he could do some promotional work.“I like the golf gear so I thought I’d get some golf gear.“So I went down there with my missus and he had his mum with him, so there’s only four of us in this shop. And Nike town is massive. “Thierry’s face was like, ‘Woah, I didn’t expect you to get that much!’“They put it all through and they even packed it. I thought, ‘This is brilliant!’“As I drove past, Thierry was getting in his car and I put my window down.“I asked him, ‘What are you doing next week?’ And he said, ‘I’m not coming Nike Town with you!’“I bought him a big magnum of champagne the next day to say thank you, but I knew he didn’t drink so he gave it back to me!” Ray Parlour recalled a hilarious trip to Nike Town with former Arsenal team-mate Thierry Henry – which ended up like an episode of Supermarket Sweep!Back when Henry’s stardom was rising, Parlour was invited along to a promotional event at the Oxford Street megastore. Ronaldo warned Lukaku how hard scoring goals in Serie A would be before Inter move Parlour seized his opportunity in Nike Town England vs Czech Republic (Friday) – talkSPORTWalsall vs Barnsley (Saturday) – talkSPORT 2Shrewsbury vs Portsmouth (Saturday) – talkSPORT 2Gibraltar vs Republic of Ireland (Saturday) – talkSPORT 2San Marino vs Scotland (Sunday) – talkSPORT 2Netherlands vs Germany (Sunday) – talkSPORT 2 Son ban confirmed as Tottenham fail with appeal to overturn red card Top nine Premier League free transfers of the decade With the whole shop to themselves, Henry told Parlour to have a look around and help himself to some sportswear.And the talkSPORT co-host took the invitation a little too literally.Read the hilarious story below… REVEALED REPLY LIVE on talkSPORT REVEALED 2 Berahino hits back at b******t Johnson criticism – ‘I was in a dark place at Stoke’ no dice Where Ancelotti ranks with every Premier League boss for trophies won
10 April 2013 South African retailer Pick n Pay is expanding its presence in Zimbabwe through its partnership with TM Supermarkets, a subsidiary of Meikles Limited, by investing US$25-million to upgrade the chain to international standards. There are 50 TM Supermarkets across Zimbabwe, including two which already carry the Pick n Pay name at the Kamfinsa and Westgate shopping centres in the country’s capital, Harare. Pick n Pay has owned a 49% stake of TM Supermarkets since November 2010, and has provided operational support through a skills development programme to equip the Zimbabwean local team with international best practice. “[It is] wonderful news for stakeholders as it will re-position TM Supermarkets as a leader in a very competitive industry,” executive chairperson of Meikles Limited, John Moxon, said in a statement last week. “Precise timelines are not yet finalised but we shall both renovate current stores throughout the country and open new ones initially in Harare, to world-class standards.” The investment and refurbishment follows the chain’s six-fold increase in profits through improved management practices and better stock control, merchandising and buying strategies. “The $25-million investment, together with a substantial internal generation of cash from increased earnings, will soon be available for the renovation of existing supermarkets and the addition of new opportunities,” Moxon said. The performance of the two existing Pick n Pay stores also contributed to the chain’s positive bottom line, and helped enable the refurbishment. “These programmes will be accelerated substantially in 2013.” Pick n Pay currently operates 95 stores in Africa, the latest of which was opened in Luanshya in Zambia on 22 March. SAinfo reporter
3 June 2013Orlando Pirates midfielder Tlou Segolela scored a goal in each half as Bafana Bafana defeated Lesotho 2-0 in an international friendly match played at the Setsoto Stadium in Maseru, Lesotho on Sunday.South Africa remains unbeaten against the Mountain Kingdom with five victories in six meetings and one draw.Bafana struggled to put their passes together early on as the team adjusted to the artificial surface and a strong wind at their backs. They managed a number of chances, however, but it was only on the stroke of half-time that Segolela opened the scoring following a fine pass from Kaizer Chiefs’ midfielder Siphiwe Tshabalala.Tap-inIt was an easy tap-in for the man nicknamed Sox and it gave the cheering Bafana supporters something to celebrate going into the break.The second half started with coach Gordon Igesund making several changes as he continued to give more players the opportunity to impress ahead of the forthcoming crucial 2014 World Cup qualifiers against Central African Republic and Ethiopia.Bafana continued to pressurise the hosts and their efforts were rewarded on 60 minutes when Segolela pounced on a ball that had been weakly parried away by goalkeeper Kholuoe Phasumane and slotted a low, left-footed shot into the far corner.It could have been 3-0 seven minutes later after striker Bernard Parker latched on to a pass from Tshabalala, but his shot was cleared off the line with the goalkeeper well beaten.‘Confidence-booster’“The two goals were a great confidence-booster for me, but credit must go to the whole team as we worked very hard to achieve this result,” Segolela said afterwards.“We did very well in windy conditions and this should set us up for a great travel to Cameroon. Hopefully we will repeat the same performance and even improve it slightly,” he added.Both South Africa and Lesotho used the friendly as preparation for their upcoming Brazil 2014 Fifa World Cup Qualifiers.South Africa faces the Central African Republic (CAR) on Saturday, 8 June in Yaounde, Cameroon, with the second match coming the following weekend against Ethiopia in Addis Ababa on Sunday, 16 June.Bafana line-upWith injuries hampering Bafana Bafana’s preparations, head coach Gordon Igesund used a vastly different side on Sunday to the one that defeated the CAR 2- 0 in March in Cape Town.Missing from the side were captain Itumeleng Khune, Thuso Phala and Reneilwe Letsholonyane, who were not even on the bench for the Lesotho encounter. Thabo Nthete was handed the captain’s armband for the match.The main focus for the match, however, was trying out different combinations in defence where several players had to withdraw from the squad due to injuries.Nthete played alongside Eric Mathoho in central defence – the first time they had done so so in the national team, even though they had played together at Bloemfontein Celtic before Mathoho made the switch to Kaizer Chiefs. Mathoho was replaced by Tefo Mashamaite in the second half.Also coming on in the second stanza was Tebogo Langerman at left-back in place of Ricardo Nunes, while Senzo Meyiwa made his Bafana Bafana debut when he replaced Wayne Sandilands at goalkeeper.‘Very pleased’“I gave a couple of players a run and I was very pleased with the outcome. We had to get to the bottom of our defensive troubles before we travel to CAR and Ethiopia. It was important to get it right here today. What I saw gave me a clear indication of what we need to do in our next match, which is very crucial,” said Igesund.“Now we know what we need to work on and I believe we will get better, more so because Phala, May Mahlangu, Khune, Tokelo Rantie and Letsholonyane will be available for the two matches. So it was a good exercise for us and we have taken a lot from this match,” he added.“I am happy with the result, but more so with the performance. I saw a lot that I needed to see, because without this match I would have had to experiment in Cameroon, which is very dangerous.”Bafana Bafana depart for Cameroon on Tuesday afternoon.SAinfo reporter and South African Football Association
Related Posts It’s time for our weekly summary of Web Technology news, products and trends. On the product side, Microsoft had two major Web announcements: 1) the release of Azure, a cloud computing OS; and 2) browser-based versions of four Office products. Google was also active this week, releasing the third beta of its new browser Chrome and announcing it will support OpenID. On the trends side, we wrote in-depth analysis pieces on LinkedIn and Hulu, advised you how to use the new Google web search RSS feeds, and more. And this week ReadWriteWeb had our own special announcement: a new product, Jobwire!Sponsored by:Web ProductsRay Ozzie Announces Windows Azure – “Windows in the Cloud” Ray Ozzie opened the Microsoft PDC ’08 this week with a keynote speech. In it he announced Windows Azure, Microsoft’s “Windows in the cloud”. It is a new service based operating environment. He described it as a massive highly scalable service platform. What was released this week is just a fraction of what it will become. It will be Microsoft’s highest scalable system enabling people and companies to create services on the Web.See also our analysis, Microsoft Azure Aims to Re-define the OSGoogle Releases Third Beta of Chrome: Better Security and Performance Google released a new beta version of Chrome, Google’s first web browser, which addresses a number of issues we had noticed in earlier releases. Besides improving the performance and stability of a number of plugins, including Flash, Sliverlight, and Quicktime, as well as fixing some security issues, Google also finally added the ability to add words to the built-in spell checker.Microsoft Office Comes to the Browser (Finally) Microsoft announced this week at its PDC conference that the next release of Microsoft Office will include browser-based versions of some of its main office software products – Word, Excel, PowerPoint and OneNote. These will be “lightweight versions”, but Microsoft told us yesterday that they’ll still have rich functionality and will be comparable to Google’s suite of online office applications. The apps will enable users to create, edit and collaborate on Microsoft Office documents through the browser. The apps will work in IE, Firefox and Safari browsers (no word on whether Google Chrome will be supported).Microsoft clarified in an email that these apps will use HTML and AJAX, but also Silverlight components.Seven Must-Have Offline Apps For Your iPhone/iPod Touch If you have an iPod Touch, then you know the benefit of finding apps that work offline. But some iPhone owners, too, need offline access from time-to-time. Maybe you spend your commute in an underground subway or perhaps your office building has shoddy cell coverage, or maybe you just want to use your iPhone on a plane…whatever the reason, offline access to apps is still a necessary evil these days. SEE MORE WEB PRODUCTS COVERAGE IN OUR PRODUCTS CATEGORYA Word from Our SponsorsWe’d like to thank ReadWriteWeb’s sponsors, without whom we couldn’t bring you all these stories every week!WildApricot is Membership Management Software.Crowd Science gives you detailed visitor demographics.Glue enables you to connect with friends while browsing.Strands provides real-time recommendations of products.Direct Media Exchange is a solution for managing ad networks.Rackspace provides dedicated server hosting.SmartyPig is Simple. Smart. Savings.Quintura is a visual-based search engine.Eurekster is a custom social search portal.MediaTemple provides hosting for RWW.SixApart provides our publishing software MT4.Web TrendsHow to Use the New Google Web Search RSS Feeds Google’s been the lone hold out among major search engines on RSS but the company quietly enabled feeds for web search results this week. The offering is pretty limited and frustrating, you have to go through Google Alerts to get an obscure RSS URL, but we offer a tutorial and some strategic advice in this post.Web search RSS is useful for being alerted whenever search results for your keywords or link have changed; subscribing to at least a few searches will let you know when Google users are seeing something new in the first few pages of search results for your company name, for example.LinkedIn, Stop Hiding People Behind Links Last week LinkedIn announced an additionalinfusion of capital from strategic investors. The company has beenaround since 2003 andBernard Lunn recentlywrote an in-depth analysisof the LinkedIn business here on ReadWriteWeb. Most of us use LinkedIn a few times a week, yet almostno one is emotionally connected to the company. Isn’t it strange that abrandwhich at its core is aboutconnecting people, is rather bland and unexciting? LinkedIn as a company and brand has never paid attention to the humanfactor. Google is Now an OpenID Provider It was quite a good week for OpenID, an increasingly popular mechanism for creating and managing a single identity across the Internet. On Monday, Microsoft announced that it would give every Windows Live user an OpenID account, and later in the week Google announced a very similar plan.Google will allow web services to join a limited test of an API based on the OpenID 2.0 protocol that will give Google Account users the option to sign in to websites with their Google credentials and without having to sign up for a new account at those sites.Hulu: Ugly Duckling No More It’s hard to believe that it’s been a year since Hulu – the joint online video venture between NBC Universal and News Corp. – began streaming content. Its initial reception, after months of anticipation and a good helping of ridicule, was less than warm. Old media companies trying to take on YouTube? Were they serious?Clearly, they were. Fast forward to today – a year after the company released its private beta – and you’ll hear a completely different story about Hulu. How did we get here? Let’s take a look back at Hulu’s first year.SEE MORE WEB TRENDS COVERAGE IN OUR TRENDS CATEGORYNEW ReadWriteWeb ProductAnnouncing a Major New ReadWriteWeb Project: The Jobwire We’re excited to introduce this week the launch of a new content channel here at ReadWriteWeb. It’s called the ReadWriteWeb Jobwire and it’s a site dedicated to reporting on people who have been hired for new jobs in tech, new media and related companies. We’ve been working on it for months, well before the current economic climate unfolded, but we’re hoping that a whole site of good news will serve our readers well in these troubled times. Companies are still hiring, people are still getting cool new jobs, and we’re going to report on it. We invite you to check out the new Jobwire site to meet the Jobwire team, learn about our special guest editors and check out some of the great new jobs people have landed lately! Click here to read more and meet the Jobwire team.RWW Enterprise ChannelThe New Stack: SaaS, Cloud Computing, Core Technology During the PC era, the technology stack was controlled by Microsoft Windows and Wintel – the “Wintel” era. We are now entering a new era, called variously ‘Cloud’ or ‘SaaS’ or ‘Enterprise 2.0’. In this era everything is different – the stack, the players and the potential for value creation. Let’s outline the basic shape of this emerging era, in particular defining what makes up the new stack.Email us if you’re interested in writing for ReadWriteWeb’s Enterprise Channel.SEE MORE ENTERPRISE COVERAGE IN OUR ENTERPRISE CHANNELThat’s a wrap for another week! Enjoy your weekend everyone. A Web Developer’s New Best Friend is the AI Wai… richard macmanus Why Tech Companies Need Simpler Terms of Servic… Top Reasons to Go With Managed WordPress Hosting Tags:#web#Weekly Wrap-ups 8 Best WordPress Hosting Solutions on the Market
A majority of Records Management (RM) and Information Governance (IG) programs now in place lack the key elements that are needed in order to be effective. That’s a conclusion of a report sponsored by AIIM, ARMA, Iron Mountain and Cohasset Associates.Barry Murphy, Analyst at The eDJ Group, wrote in an article for Forbes that “for companies that ignore IG, managing the risk that information poses is harder and harder because the volume of information stored keeps going up.” But there is a problem because many RM/IG programs are struggling.The Cohasset report found that many RM/IG programs lacked effectivity:Only 17 percent do internal audits of their programs to assess how well they are meeting the demands of regulatory complianceOnly 8 percent have developed metrics that enable them to measure changes in the effectiveness of their programMany RM/IG programs suffer from lack of automation:Only 8 percent have an automated process to identify records that are eligible for destruction75 percent of organization say that lack of automation is making it difficult to enforce their retention/destruction policiesSue Trombley, managing director at Iron Mountain, said that “Information management, when done right, can push your business ahead and be a strategic lever for success. But until you achieve buy-in at all levels of the organization, master fundamentals like timely destruction, and implement a system to monitor program effectiveness, the sought-after benefits will remain elusive. You will also have to transition away from paper-based processes to manage the complexities of electronic records. Mature, well-run RIM programs have all of these things, plus the ability to adapt as information grows and changes. ”
The Multistate Tax Commission’s (MTC) Combined Filing Model Working Group has drafted a model “Finnigan Method” Combined Reporting Statute.The MTC received a request to draft a model statute adopting the “Finnigan” method of apportionment.The group will present the draft to the Uniformity Committee on Thursday, April 25 at the MTC’s spring meetings.Existing Model Combined Reporting Statute Adopts JoyceThe MTC adopted a Model Combined Reporting Statute for separate-entity states contemplating moving to combined filing in 2006. The 2006 model adopted the “Joyce” methodology of income apportionment.Under the “Joyce” methodology, each corporate member of the reporting group is treated as a separate taxable entity for income apportionment purposes. The “Joyce” methodology was the most commonly used approach in 2006.“Finnigan” v. “Joyce” MethodThe difference between the “Joyce” and “Finnigan” methods is receipts factor calculation. Taxpayers using the “Finnigan” method, calculate the apportionment factors of the members of the combined report as if the members constitute a single taxable entity.Under “Joyce,” the receipts factor numerator of each member is calculated on its own. Under the “Finnigan” method, the numerator of the combined group is calculated as though the members of the combined group are a single entity. If one member of the combined group has nexus and activities that exceed P.L. 86-272 protections, the receipts factor numerator includes all receipts from all members of the combined report sourced to the state.Draft Statute Reflects Utah ApproachWhen beginning the drafting process, the group examined “Finnigan” method used in:Utah;Massachusetts;North Carolina; andWisconsin.The draft statute preserves most of the 2006 model statute. Minor changes were made to sections covering:definitions;the requirement to file a combined report; andthe water’s edge election.Most of the changes were made to the section addressing determination of taxable income or loss on a combined report. The changes reflect a movement toward the Utah approach of treating the filing group as a unitary whole.The draft model allows for some sharing of tax attributes among the members and permits some sharing of loss carryforwards. Further, there is net operating loss sharing with some limitations to prevent abusive practices.Group Sharing of Net Operating LossesThe drafting group believed it was necessary to track net operating losses on a separate company basis. Tracking is necessary so that there are appropriate limits on the net operating losses that companies bring into or leave a group with.Losses apportioned or allocated to the state must be attributed to members of the group as follows:an apportionable loss, a portion of the group loss determined by multiplying the loss by a fraction, the numerator is the member’s loss, and the denominator is the total loss of all the members; plusa non-apportionable loss allocated to the state, but only to the extent that the loss contributed to the total combined group loss reported to the state that year.Members cannot be attributed total losses more than the loss reported to the state by the combined group.The net operating loss carryover available to the combined group is:the total net operating losses of the combined group previously allocated or apportioned to the state that have not been used or are not limited by state law; plusnet operating losses of a member of the group created before joining the group, but only if the losses are not subject to federal limitations for members joining a federal consolidated filing group, were properly allocated or apportioned to the state, were properly attributed to the member if the member was part of a different combined group when the losses were created, have not been used to offset income of any taxpayer, and are not limited by state law; minusthe net operating losses of a member that leaves the combined group that were attributed to that member or brought into the group.Text of the StatuteThe text of the model statute can be read on the MTC website.The working group will make further changes to the proposed statute in response to any feedback from the full Uniformity Committee.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.
The state and local tax deduction limit (SALT) may affect treatment of tax refunds from years when SALT is in effect under the tax benefit rule. The IRS has provided four examples of the how the SALT affects these refunds.Tax Benefit Rule and SALT DeductionTaxpayers must use the tax benefit rule to determine whether they include a refund amount in gross income. Under the tax benefit rule: taxpayers include in gross income refunds they receive that gave rise to a deduction in previous tax years; and taxpayers do not include these amounts in gross income to the extent they did not reduce income tax in the year of the deduction.The SALT deduction generally limits an individual’s itemized deduction for state or local taxes paid or accrued to $10,000, or $5,000 if married filing separately. The deduction limit applies to taxes that are not directly connected with:a trade or business; orproperty held for the production of income.Examples of the SALT Deduction Limit and RefundsThe IRS provides examples that involve taxes paid in 2018 and refunded in 2019, both years when the SALT limit is in effect.The examples address:a situation in which a taxpayer paid and deducted less than $10,000 in state and local taxes;three situations in which the taxpayer paid and deducted more than $10,000 in state and local taxes.One of the four examples appears below.Example: Taxpayer D paid local real property taxes of $4,250 and state income taxes of $6,000 in 2018. Section 164(b)(6) limited D’s state and local tax deduction on D’s 2018 federal income tax return to $10,000, so D could not deduct $250 of the $10,250 state and local taxes paid. Including other allowable itemized deductions, D claimed a total of $12,500 in itemized deductions on D’s 2018 federal income tax return.In 2019, D received a $1,000 refund of state income taxes paid in 2018. Had D paid only the proper amount of state income tax in 2018, D’s state and local tax deduction would have been reduced from $10,000 to $9,250, and, as a result, D’s itemized deductions would have been reduced from $12,500 to $11,750, which is less than the standard deduction of $12,000 that D would have taken in 2018. The difference between D’s claimed itemized deductions ($12,500) and the standard deduction D could have taken ($12,000) is $500. D received a tax benefit from $500 of the overpayment of state income tax in 2018. Thus, D is required to include $500 of D’s state income tax refund in D’s gross income in 2019.Steps Taxpayers Must TakeEach taxpayer in the examples must take the following steps:determine the amount of itemized deductions that the taxpayer would have deducted in the prior year had the taxpayer paid only the proper amount of tax;compare this amount to the total itemized deductions actually taken on the return, or the standard deduction that could have been taken on the return; andinclude the difference as income on the current year return if the taxpayer received a tax benefit in the prior tax year from that itemized deduction.If a taxpayer received a tax benefit from deducting state or local taxes in a prior tax year and the taxpayer recovers all or a portion of those taxes in the current tax year, the taxpayer must include in gross income the lesser of:the difference between the taxpayer’s total itemized deductions taken in the prior year and the amount of itemized deductions the taxpayer would have taken in the prior year had the taxpayer paid the proper amount of state and local tax; orthe difference between the taxpayer’s itemized deductions taken in the prior year and the standard deduction amount for the prior year, if the taxpayer was not precluded from taking the standard deduction in the prior year.These examples apply to the recovery of any state or local tax, including state or local income tax and state or local real or personal property tax.By Robert Recchia, J.D., M.B.A., C.P.A.Login to read more on CCHAnswerConnect.Not a subscriber? Sign up for a free trial or contact us for a representative.