Thursday, November 28, 2019

PaidProgramming by Bones by TeamSesh free essay sample

B O N E S PaidProgramming Review Hi everyone, Teamthany Seshtano here, Teen Ink’s busiest music nerd and it’s time for a classic review of the 2013 Bones mixtape, PaidProgramming. Elmo O’ Connor other wise known as Bones, or [emailprotected] Kid if you’re looking at his earlier work,is a Michigan/ California rapper, part of the independent label known as TeamSesh and a part of the underground rap group SeshHolloWaterBoyz. This is the 29th tape under his belt and this isn’t really not an ordinary Bones tape because this is where, at least for me, where Bones started to really define a new image for himself. Even though it’s still in the style of his three previous tapes, those tapes being CRACKER, SCUMBAG, and CREEP, the overall concept of the album is what really draws me in and how interesting it is. The concept being of I guess just sitting in your home, late at night and just watching the Paid Programming portion of a certain channel. We will write a custom essay sample on PaidProgramming by Bones by TeamSesh or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The Album kicks off with the title track, which is a very somber and mysterious instrumental, with a clap sample once in awhile. It’s almost like you’re visualizing a grainy city background covered in fog, at least that’s what I visualized, still pretty decent instrumental nonetheless. Now the next track titled JonathanTaylorThomas, is the first song that Bones actually raps and it seems to be about those whom Bones dislikes trying to be on his level, comparing them a to a young Jonathan Taylor Thomas. Saying how they’ll never actually earn respect or money doing what they’re doing and eventually end up dead in game by the hands of Bones, adding onto the song however, is Bones going even harder on this person saying how nobody is going to miss him and how they memory of the person will slowly fade into obscurity or even to the point where the man’s parents lied to his face about making it in life. Just a bit of a disclaimer, there are quite a few references to drugs and money in Bones’ music, though he does make sure there is a decent variety of songs with differing subjects. The third song here titled WakingUpCrying, which is about I guess having some sort of smoking session with a girl he met though it does devolve into a bit of bragging when he talks about riding off in a yacht with a swimming pool on the top or how he’s a slim young pimp with twenty beepers on his hip. That is until Jonny Telafone comes in with some very tear stained and somber vocals, crying for the girl that Bones is with, wondering what else to do as he soaks his pillows with his tears. The next song up which I personally enjoy, titled RotatingBed sort of brings it back to concept of the album a bit with the beat and overall tone. The song is about Bones missing a girl and how his life really isn’t complete without her in his life, stating how he doesn’t how to act or to be sane when she isn’t around. Sorry if the format seems a little repetitive, I’m just trying to do a short review of each song so bear with me a little bit. So, the next song titled Dial-Up seems to have a more mean mugging vibe to it while also taking place in two separate years it seems. Bones is in 2003 talking with someone’s girl on Nextel phone in a black Mercedes Benz jeep. While the guest feature on the song by Na$ty Matt is about him being in 2005, having casual sex with a few girls like they’ve had their tubes tied and riding in a Mercedes Benz with a machete on his side referring to himself as a dirtbag which is sort of fitting by the content of his lyrics. The next song in the track listing titled AmericanBeauty actually samples the movie that it’s named after, it’s the final quote of the movie actually before the character played by Kevin Spacey, is embracing his own death, which Bones likes to do in his music. After that however, Bones starts to go into a brag rap direction, talking about he has the dope and the flow, though the chorus oddly enough is the same chorus from Aaron Carter’s song, How I beat shaq. He then goes on to describe his day as he wakes up, wondering how much time he could kill as he rolls his first ‘bone’. Then the song devolves into Bones talking about how other’s aren’t as good as him or his label. Now another thing to sort of bear with in this review is that Bones, like many other rappers, enjoys talking about how successful he is which isn’t a bad thing at all as long as you keep the song interesting. Next song in the tracklisting is called 281-330-8004, which is Mike Jones’ old personal number from 2005. In the song he talks about how he’s got friends that don’t talk to him because he I guess he would rather silently communicate than draw attention to themselves. Describing his popularity as Macaulay Culkin’s back in 1992 which makes sense in the popularity sense though doesn’t really make much sense in the way he got that popularity. The next cut on the album is 7DayOutlook, which samples an old weather channel ad fitting back in with the theme and concept of the album.Fellow Sesh member Dylan Ross is on this track for hook, telling those frauds in his life to stay out of it, telling them that because of them he no longer has any l ove to give. Bones then gets into his verse, saying how he doesn’t wear brand name clothes and wears his label’s merch, and also listens to his own music because he feels that rappers today aren’t up to his level. A more somber track up next titled Cut and seems to be about Bones deeply missing this girl to the point where he can’t think straight, as his mind fills with feelings of regret and sadness. Looking back on his memories with her, hoping that this girl feels the same when she thinks about him. He even retraces his steps at one point, however those he meets on the way don’t satisfy him, knowing they can’t relate to his situation. Eventually he wishes for death, know that he’ll never see her again. The next song in the track listing titled FlashFloodWatch is about those who hate on Bones but still listen to his music. However Bones knows of this and begins to tear into these ‘secret fans’, seeing their hate as them throwing him in the water and just watching him sink to the bottom. Bones then talks about how these ‘secret fans’ don’t really know what he’s like as they’ve never been or seen a live show, however it comes back to sort of that brag rap style at the end of the song which is to be sort of expected. The next song, which is a vocal performance rather than a rap song is called TeenageBoy now, if you don’t know already, Bones is a pretty talented singer at times at least for me. He’s even got a little side project with Sesh Producer Greaf called surrenderdorothy where it’s just vocals, though I can see why people wouldn’t like this song or any other sad Bones song because, most now come to get hy ped up and it’s unique to that variety again in Bones’ music but I digress. The track begins with a sample from the Adam Sandler movie the wedding singer, before singing about him and a girl, which is pretty formulaic at this point but think about the song and the context it’s in. It’s like some weird kid at school who entered the talent show and sings for the girl he can’t talk because he feels that if he makes any form of contact with this girl she’ll reject him. Next song up is titled Snow and it seems to be about Bones revisiting locations from his childhood/teenager days and seeing how much they’ve changed since he left. Though he is unsure of whether or not the roads have changed however. Up next is the song SevereWeatherWarning which is about Bones describing how these labels want him but they can’t have him, as Bones is more akin to staying an underground artist. Eventually talking about his blade and his girl near and at the end of the song. However, the song after that titled Rust is probably the most depressing song on the album in which Bones goes a more tear stained and hateful approach to missing someone. Talking about losing all the love he could give because he already wasted it on someone who really didn’t need it, saying that the person may miss him but not actually. Even though it’s sort of implied that the person Bones is talking about feels this way, as some whimpering is heard at the end. Then we hear the interlude titled 30DayFreeTrial, which is pretty catchy and pleasing after Rust. The next song is titled StoneColdStunner, features Wiccaphase on vocals, saying how girls only like him because he looks like Bones or how he feels like a leech comparing himself to basically a clone of him and nothing else. Bones then talks about how he can’t stop whatever he is doing, that probably being smoking dope and doing whatever he wants, calling out for somebody to save him. The song up next HeavyFog is a pretty standard Bones song, talking about rolling up ‘bones’, brandishing his knife, and how his writing is flawless. The song after however Called TeenGirlDiesAtRave, I feel yet again fits back in with the concept a bit, as if say an after school special comes on TV and it’s about drug abuse. The intro on the song takes place at a night club I guess and Bones is with his friend Claire, however he finds her on the floor not breathing and comes to the conclusion that she overdosed on pills and died. Then the song kicks off with a sample from a rave song titled,†Wipe away my tears†, after a while Bones starts to get into his verse, describing the last moments of Claire’s life as she slowly dies however he diverts from this narrative near the end. However, it jumps back from the theme and concept in the song ScatteredShowers, where Bones talks about how he was always the best without ever even noticing it before and then proceeds to talk about dope and how these other rappers are too scared to follow their dreams. GrandfathersRing is the next song, immediately talking about how he’s young and handsome like the Hansons or how doesn’t care about his image as long as he gets his ash. However at the outro, it yet again for another time comes back to the concept and theme of the tape, where it’s basically a radio traffic and weather report which will tie into the end of the album. The next song titled 2006 is about how these scared, weak rappers need to step up their overall capital. At the end talking about how you’ll never catch him in Jordans dissing snapbacks aswell. The next two songs are pretty alright in my opinion the first one being Skin, which is another song about Bones and his lust for blunts and dope. The other being Blink187 which does sample actually sample a Blink182 song known as †All The Small things.†. Bones then begins to talk about his extravagant bathroom as he smokes a blunt, threatening those mess with his brother saying they’l l be on First 48. The song after that is CracksInTheRoad, which is about Bones partying at some sort of exotic place with strange artifacts, eventually leaving the party at the end. The last three songs on here, two out of three are pretty standard Bones tracks aside from the very last one. 5EasyPayments pretty standard, Bones talking about smoking dope or how he dropped out and made his own music. Now the second to last song is titled DelicateHands, which is about him trying not to lose feelings for a girl, at the same time trying to express his true feelings to her. The final song on the album is more of a Ten Minute Skit than a song, it’s called Sesh Radio: Volume 1. Now before I get into this one, there are two other Sesh Radio skits on two other tapes, those being Rotten and the sequel to this tape, PaidProgramming2. So it opens with a song by an alter ego by Bones named Ricky A Go Go, before actually getting into the news portion lead by ‘Sesh anchor Kip Chiperly’. This right here this skit is what really brings out the concept and theme which I personally enjoy very much. Kip finishes the weather report in which it then fades into a p oem it seems, which is sampled from an old Chanel No.5 ad.The passage finally ends, and an unknown anchor is heard talking about the local ‘Sesh Fest’ cutting to the live feed down at the scene. However, it is implied that there actually is no Sesh fest because of the phoned in yelling at the ‘event’.The feed eventually cuts out, before another Ricky song plays, talking about walking down a lonely road at night. However, the unknown anchor returns and plays the next on the ‘playlist’ titled,TimeshareCondominium, this song later lands on another Bones tape titled DeadBoy. Though I won’t be talking about this song because I’m more focused on the skit than the song in the skit(however if people want, I could review DeadBoy). The song eventually ends and another Sesh Anchor, named Bobby Hallofax, begins to take calls from listeners. The only person who calls, named Pamela, doesn’t seem to speak english however Bobby takes this as show of support. Though he stops taking calls and plays an unknown song TeamSesh song before the track finally ends. So overall I loved the concept and the aesthetic of the album though I can see why people wouldn’t like this album. Bones seems to talk about the same thing sometimes, though he does try to keep it interesting. Mixing different styles of rapping, singing, and in some of his tapes he even full on screams. Personally though, if you want to at least try and get your friend or friends into Bones I would try this album because it’s not too strong and it’s not too light, giving you the variety of styles Bones can have on a tape. That’s I really have to say on this one, Bones, PaidProgramming, TeamSesh,F O R E V E R.

Monday, November 25, 2019

Fiddler on the Roof essays

Fiddler on the Roof essays This movie is based on constant tradition of the Jewish community, and how these traditions were conducted as a whole. The belief of tradition in this community is that it balances life. The setting is in Israel, located in the village of Antificca. The theme included a whole village, but based around a Jewish family consisting of father, mother and five children. It was proper for women to make a kosher home and to read the Holy book, and on the Sabbath for women to keep their heads covered with a shawl, while praying. These were days were days when fathers chose their daughters husbands. This family was very poor, therefore their (3) daughters of (5), had no dowry. The father worked hard, praying to God and dreaming of being rich. Their mother worked hard in the housework and preparing a kosher home for the Sabbath, this would reflect tradition each week. The daughters did not truly have an education. They too, worked within the home and dreamt of being married. Tawa, the father meets a young man named Patrick a fresh graduate from college, out working and they talk and make an agreement that Patrick will educate his daughters, for room and board. The daughters were laughing and speaking of their aunt who is always trying to match makes them to other men, usually older, wealthy men. That the girls would have no interest in, that same afternoon, their aunt came and let their mother Goldor, know that the butcher has had his eye on the oldest daughter, Sitol and would like to marry her. However, Tavia does not care for the butcher Laserwolf. But, that not Tavia agreed to meet with him and to talk. That night they spoke and Tavia agreed to give Sitol away to Laserwolf. They celebrate; they dance, drink and party the night away. Another tradition meanwhile, Sitol and Mato, a poor tailor boy from next door, whom grew up together are plotting away to get married. They are very much in love. The next da...

Thursday, November 21, 2019

The Essence of Writing Assignment Example | Topics and Well Written Essays - 500 words

The Essence of Writing - Assignment Example 1. The first tip of Roberts is that the writer should discard all the obvious ideas and content that comes to his mind in the initial stages of brainstorming. The obvious ideas are common to everyone and will not make any unique statement. Hence, to get fresh and revolutionary ideas that are different from others, the writer should build the paper based on those ideas that are hidden under the obvious ideas. 2. The second way to impress the reader is by taking the unusual side in the argument. By taking the side which will be avoided by most people, the content will have the touch of ‘unexpected’ element. The uniqueness will grab the attention of the reader and will keep him hooked. 3. The third tip pieces of advice to make the writing clear, illustrative and concrete, in order to make the reader actually feel the scenario which is being discussed in the paper. The abstraction does not create the magic and impact which the concrete and descriptive writing create. Hence, giving examples, real or imaginary, while making your point, gives a life to the argument and makes it convincing. 4. The author says that even if the writer has only a few points to discuss, he should not fill the paper with useless words. Instead, he should get into the details of those few points and fill the required word limit with the help of illustration and details of the points. This might make the content short, but it will have power. 5. The fifth tip is to be courageous and bold enough to express whatever one wants to express without wasting the words in beating around the bush. The writer should avoid using unnecessary words to hide his critical language or bluntness. 7. To make the content interesting, gripping and lively, the writer should use the words which makes the reader to ‘feel’ the content.However, these words, known as ‘colorful words,’ should be used according to the trend of the time 8.  The writer should be prudent while using the words which have mental associations. These words, known as coloured words, have great power to recreate the feelings that are associated with these words.

Wednesday, November 20, 2019

Democratic Socialism and Comparative Advantage Research Paper

Democratic Socialism and Comparative Advantage - Research Paper Example Democracy focuses on the political aspect. It entails political sameness, the rights of all people to participate in the governance of which they are subject (Busky 312). Conversely, socialism highlights material fairness. It is not stern parity, but an end to the enormous discrepancies of earnings and affluence noticeable to the imbalances of rights of ways of production. Democratic socialists’ opinionated that both the economy and community should be ruled democratically to satisfy public needs and not fulfill wishes of a few (Busky 310). To acquire a more fair society, many compositions of governments and economies must be fundamentally changed through immense profitable and social equality so as the common persons can equally partake in making decisions that affect their lives. Socialism was first used in publications devoted to organizations in Great Britain. It was used to refer to a culture in which citizens’ work collectively for the benefit of everyone. Sociali sts have always believed that people are equal by natural rights and this was considered their highest value of people. Socialists hold democracy in high esteem. People in an independent socialist society have the right to express themselves and given due consideration. In a socialist society, people vote in the government. The government is formulated through legitimate, fair and free elections. However, sometimes democratic socialists are mistaken with governments that are dictatorial and authoritarian. True socialism lives in a democratic society. Democratic socialism is based on humanistic ideals with the eventual objective of allowing each person the prospect and way for their personal development and satisfaction. This is made possible in a society where self-realization turns into a reality in a supportive, non-competitive social situation. Several countries in the world employ this form of governance. They Include China, the second prevalent economy in the world after the U. S and Russia a superpower as well as Scandinavian countries and France. Other third world countries embracing the concept involve Venezuela and Bolivia. They also include Burma, Vietnam, Cuba and North Korea. For instance, preceding the Russian Revolution in the 1920s there were existences of socialist countries anywhere as well as fully grown democracies. During those times, women rights were still curtailed, and women were barred from voting. The prevailing capitalist states supervised in undemocratically customs over their colonial domains. The Russian revolution changed this equation significantly. As many people engaged in questioning the link between socialism and democracy, the existing socialism turned out to be anything but democratic. Socialism obliges an entity according to (Harrington 288), into societal collectives contrasting capitalism, which promotes individualism. People are deemed as social animals that reside in a society that has regulations to guide it. These ru les demand a lot from an individual but as well gives the individual self-government, total control of their work freedom from poverty and freedom to pursue a better life. This contrasts the capitalist American concept that promotes separation from family and community as well as subjects an individual to high stress. The supposedly free individual in the concept is instead conformist and conventional.

Monday, November 18, 2019

Optical isomerism in Thalidomide Essay Example | Topics and Well Written Essays - 750 words

Optical isomerism in Thalidomide - Essay Example The tragedy which occurred due to thalidomide use led to very stringent testing requirement for pesticides and drugs before licensing. Initially, thalidomide was prescribed as effective painkiller and tranquilizer for insomnia, colds, coughs, and headaches. It was a very effective antiemetic inhibiting morning sickness, and this resulted into many pregnant women using thalidomide in order relieve their pregnancy symptoms. The relationship between the drug and defects in birth were suspected by Australian obstetrician, McBride William, and the German pediatrician, Lenz Widukind. This was later proven in 1961 by Lenz. Approximately 2500 thalidomide babies were born in Germany. The United States Congress constituted laws demanding safety tests during pregnancy before approving any drug. Other nations have passed similar laws too. This has seen thalidomide not sold or prescribed in several countries for decades1. The severe thalidomide impacts led to strict tests being carried out. The d rug was tested as a one single agent for treating multiple myeloma because of its ant angiogenesis activity during the research trials. Many studies have illustrated that thalidomide in combination with dexamethasone increases the rate of survival of the patients of multiple myeloma2. However, commercially produced drug differed from the one used during the research trials, and this resulted into other thalidomide effects. The commercially produced drug differed from that used in research trials in that during commercial productions, thalidomide was produced in combination with dexamethasone and melphalan, which is today the regimen most common for the patients who are newly diagnosed with multiple myeloma. This has seen the development of other side effects such as fatigue, polyneuropathy, venous thromboembolism (VTE), skin rush, or blood clot, which may result into myocardial infarction or stroke. Several scientists have made reviews on VTE relationship with thalidomide in multipl e myeloma diagnosed patients, and the results show that thalidomide administered without prophylaxis leads to a high rate of VTE (26%). Owing to this high VTE rates with thalidomide combined with doxorubicin or dexamethasone, which is commercially produces, a black box warning was given in 2006 in the United States to the thalidomide package showing that multiple myeloma patients receiving thalidomide-dexamethasone bay concurrently benefit from thromboembolism prophylaxis or aspirin. There has been production of other thalidomide derivatives such as lenalidomide and bortezomib3. The presence of optical isomers severely affects fetal development in pregnant women. Tests from the laboratory after the thalidomide disaster indicated that in some animals the 'R' isomer was an effective sedative, but the 'S' enantiomer was tetragenic. The presence of the optical isomers may also lead to phocomelia which is characterized by shortened limbs, or even complete absence. In addition, fetus may develop hypo plastic or external ear abnormalities, facial palsy, malfunctions of genitourinary and gastrointestinal tract, or even complete absent bones. Approximately 40% of such fetuses die after birth4. Conclusion To sum up, there is no acute toxicity in thalidomide and a fatal overdose may be impossible virtually. As a component of thalidomide, Citalopram has severe effects with the dosage of thalidomide. This is because Citalopram and peripheral

Friday, November 15, 2019

Running Head Quattroporte Inc Foreign Based

Running Head Quattroporte Inc Foreign Based As executives with the Canadian-based software company, Quattroporte Inc, we were charged with identifying the most suitable location for opening a foreign-based subsidiary to process sales outside of North America. Offshoring will help maximize profits for our organization which is in a period of hyper growth. As part of this study our team will be looking at the jurisdictions of Ireland, Gibraltar and the Isle of Man. To analyse the suitability of the aforementioned jurisdictions we will be discussing issues of globalization, tariff and non-tariff trade barriers, trade regulations, regional trading arrangements, international factor movements and multinationals, foreign exchange and risk strategies, international/regional banking factors, professional services support, taxes, capital flow/repatriation of profits, IP rights, political and policy direction, and country risk/freedom. Selection criteria will be explained and weighed for each jurisdiction. Results of this analysis will yield information which will inform managerial decision-making in establishing our foreign-based subsidiary. IRELAND Background Over time, Ireland has become a significant offshore jurisdiction. A full-fledged member of the European community, it has managed to attract significant international business commitments through its attractive taxation reductions. Lying to the West of Great Britain, having gained independence from the latter in 1922, this English speaking country of 3.5 million (1.2 million live in Dublin) is governed by a democratically elected parliamentary government. Population 4.7 million Labour force 2.1 million Unemployment rate 14.6% Public debt 118% of GDP. Communication Ireland possesses a modern digital system using cable and microwave radio relay. Transportation Ireland benefits from an extensive network of airports (16), railways (3,237 km), roadways (96,036 km), waterways (956 km), and a merchant marine (31). Government Ireland is a republic and has a parliamentary system of government. The head of state is the elected President of Ireland who serves for a 7-year term. Ireland also has a prime minister (called the Taoiseach) who is nominated by the House of Representatives (called Dà ¡il Éireann) and then appointed by the president. Besides the lower house, the House of Representatives, there is also an upper house, the Senate (or Seanad Éireann). Ireland is a member of the European Union and one of the original 11 countries to adopt the euro as its currency in 1999  [1]  . Ireland is politically stable and their government is well on its way to reduce planned reductions of public servants. Economy Since 2008, Ireland has suffered from a significant debt-laden bust following the Celtic Tiger boom which had been predicated on debt and an unsustainable housing bubble. Although they experienced a significant drop in economic activity following the 2008 financial crisis, the Irish government has made significant efforts to rectify the situation. This has included the establishment of a National Asset Management Agency (NAMA) in 2009 and across-the-board cuts in spending  [2]  . Half of the top 50 banks and 20 insurance companies are hosted in Ireland. In 2008 the International Financial Services Centre (IFSC) investments were equivalent to 11 times Irelands GNP. The Irish Stock Exchange hosts about a quarter of international bonds. Taxation Since October 1999, all Irish companies are liable to Irish corporation tax (regardless of where they are controlled or owners country of residency), they are no longer tax-free entities and must therefore pay Irish corporation tax, register with Internal Revenue Commissioners, and file annual tax returns. They have also established an extensive network of tax treaties which include the provision of exchange of information. This makes it important to ensure that management is based somewhere fiscally neutral. The following three principal elements make Ireland stand out as a tax haven  [3]  : Corporate Taxation in Ireland is set at 12.5% on profits for all trading companies (non-trading income is taxed at 25%). A 25% corporate tax rate relates to passive income whereas capital gains tax is 30%. Near-absence of transfer pricing rules (source of loopholes in international tax) lets multinationals artificially relocate their profits away from Ireland, usually via transfer pricing mechanisms, to lower-tax or zero-tax jurisdictions. As such, large portions of multinationals profits are sheltered from Irish tax. Membership in the European Union grants Ireland political stability and special access to European markets, membership has also kept it tax haven blacklists (e.g. Caymen Islands and Bermuda), and many countries that would apply withholding tax on interest paid to traditional tax havens do not apply them to Ireland because its classified as onshore. Relationships with International Bodies Overall, Irelands place within the European Union, weak rules on transfer pricing, and broad network of tax treaties make it particularly attractive for offshoring. Case in point, according to a recent study, 60% of companies pay no to virtually no corporation tax. Effective tax rates were estimated at 7.3% in Ireland compared with 37% in France and 26% in Canada  [4]  . This has resulted in other European countries crying foul play and also triggered beggar-thy-neighbour policies. They still have much work to do to implement better financial transparence. Intellectual Property Protection Ireland ranks 7th on the Global Intellectual Property Index (GIPI)  [5]  . Ireland is a common law jurisdiction with an independent and efficient court system, a wide range of legal protections for the creators/owners of Intellectual Property Rights and the possibility of obtaining generous state grant assistance with research and development projects. Isle of Man Background The Isle of Man is an internally self-governing dependency of the British Crown and the people are British citizens. It is not formally part of the United Kingdom but is within the British Isles. The Isle of Man has its own currency the Isle of Man pound (Manx) that runs at par with the UK pound. Douglas is the Capital city and the largest town and the entire island is very small at 570 sq. miles. The primary language for business is English. The unemployment rate is very low at 2.6% and the standard of living is high with a life expectancy of 80.76 years and has a very low crime rate. Population 85,421 Labour force 41,790 Unemployment rate 2% Public debt Nil. Communication The Island is known to have a world-class telecommunications infrastructure and offers a full range of services including voice and data communications. Transportation The Isle of Man is very small and has therefore very little transportation infrastructure. It has one airport, a small railway (63 km), roadways (500 km), and a sizable merchant marine (98). Although 321 ships are registered in the Isle of Man, 223 of these are foreign owned. Government The head of the Isle of Man Government is the Lieutenant Governor. The executive head is the Chief Minister. The capital contains both the government offices and the parliament chambers. (Tynwald). The Isle of Man is claimed to be the oldest continuously operating government in the world. It is a dependency of the Crown so is able to set many of its own laws except on issues of defense, foreign affairs and consular services. Isle of Man contributes financially to the UK for these services and protection. Economy The Isle of Man has a very impressive track record regarding its economic success. The Isle of Man has been a remarkable economic story in the past three decades and has benefited from 28 years of continuous economic growth as quoted from an Ernst and Young Report, Isle of Man: Economic Report dated May, 2012. The GDP of  £3.2 Billion ($4.9bn US) is very high for a population of only approximately 85,000 people  [6]  . The Isle of Man also enjoys full and free access of Industrial and Agricultural goods movement with the European Union under Protocol 3 of the Treaty of Succession. Isle of Man has been successful in diversifying its economic base away from Agricultural to more diverse selection including financial services, aerospace and information communication technology (ICT). Taxation The Isle of Man sets its own taxes independently of the United Kingdom. The Isle of Man has no separate corporate, estate or inheritance or gift taxes. Income tax is levied at relatively low rates and VAT (Value added tax) is applied in a very similar manner as the UK. Companies are subject to income tax and not a separate corporate tax. Income tax is often zero unless they are engaged in earning profits from Isle of Man land e.g. rental income or property development or from banking then the rate of tax is 10%. Residents of the Island pay up to 20% of their total income to a maximum of 120,000 in tax which has proven attractive for the very wealthy. Capital gains tax is zero  [7]  . Since many view the Isle of Man as a tax heaven there are certain risks with this location. For example the Subsidy towards VAT has been removed by the UK to the Island in the amount of  £200 million yearly which has a big impact on their ability to keep taxes at zero. Also, there can be a negative connotation from working out of an area that is known to be a tax heaven. Relationships with International Bodies The Isle of Man became recognized as part of the WTO under the United Kingdoms ratification agreement in 1997. Also OECD (Organization for Economic Cooperation and Development) recognizes the Isle of Man as a member under the United Kingdom. Other bodies such as FATF, FSF and the IMF all have the Isle of Man in good standing with high levels of controls and protections in place. IMF had done a detailed assessment of the Isle of Mans regulatory and anti-money laundering framework in late 2002 and determined that Isle of Man had a high standard of compliance with all assessed areas  [8]  . Intellectual Property Protection The Isle of Man has a modern system of copyright protection. Computer software is protected in the same manner as prescribed in EC directives. The Isle of Man does not have its own trademark register but the UK system extends to the Island. UK trademarks are protected under Isle of Man civil law. Similarly, UK Patent law extends to the Island and Isle of Man law protects UK registrations. The UK ranks in 2nd place on the Global Intellectual Property Index (GIPI) slightly behind 1st place Germany  [9]  . GIBRALTAR Background Strategically significant, Gibraltar was relinquished to Great Britain by Spain in the 1713 Treaty of Utrecht. This led to the British garrison being declared a colony in 1830. In 1969, Gibraltar was granted autonomy by the UK which led Spain to close their border and sever all ties. Between 1997 and 2002, the UK and Spain held talks aimed at establishing a temporary joint sovereignty over Gibraltar. This move was however rejected by most Gibraltarians following a 2002 referendum. Tripartite talks have continued since 2004 with the hopes of resolving current disputes and developing cooperation agreements dealing with such things as taxation, communications, customs services, and other contentious issues. In 2009, a dispute over territorial waters gave rise to sporadic non-violent confrontations between Spanish and UK naval patrols. Of particular importance is the non-colonial constitution which was enacted in 2007, and the European Court of First Instance recognizing Gibraltars right to regulate its tax regime. The UK is however still responsible for looking after matters of defence, foreign relations, internal security, and financial stability  [10]  . Population 29,034 Labour force 12,690 Unemployment rate 3% Public debt 7.5% of GDP Communication Adequate, automatic domestic system and adequate international facilities. Transportation The Isle of Man is very small and has therefore very little transportation infrastructure. It has one airport, few roadways (29 km), and a small merchant marine (13). Although 267 ships are registered in Gibraltar, 254 of these are foreign owned. Government The monarchy is hereditary; governor appointed by the monarch; following legislative elections, the leader of the majority party or the leader of the majority coalition is usually appointed chief minister by the governor. Economy Gibraltar adheres to the common law charter and its workforce is highly-educated. The Gibraltar Pound serves as the official unit of currency (in monetary union with the UK pound sterling). No foreign exchange regulations are in effect and complete freedom exists to move funds in and out of Gibraltar as well as the ability to convert funds to any other currency. Taxation The overall corporate tax rate is 10%. Companies pay tax on income that is accrued and derived in Gibraltar. If it can be proven that said income is not accrued and derived in Gibraltar, the income is non-taxable. The company can apply to the Commissioner of Income Tax to have this confirmed in an advance tax ruling (subject to certain conditions and restrictions). Furthermore, there are is Capital Gains Tax in Gibraltar  [11]  . Relationships with International Bodies As a member of the European Union, Gibraltar is subject to almost all European Law. Gibraltar can already take advantage of European Union directives that facilitate cross border business within the European Union in respect of insurance, banking and investment services. Gibraltar licensed or authorised financial institutions can provide services throughout the EU and EEA without having to seek separate licenses or authorisation in the host Member State. This is known as the passporting of financial services. Intellectual Property Protection A companys trading name, product/service brands, associated strap lines, logos and other aspects of get-up or brand image can be protected as registered trademarks. A trade mark must have been previously registered in the UK prior to being registered at Gibraltar Companies House. Patents must also have been previously registered in the UK prior to registration with Gibraltar Companies House. Recommendation To come to a recommendation we compared each jurisdiction using the eight risk factors identified in Table 1. As such, each factor was assigned a value from 1 thru 5, 1 being very low risk and 5 being very high risk. This risk analysis allowed us to identify which jurisdiction provided the least amount of risks based on the selected criteria. Such data provided valuable insights into the relative stability of the economies as a whole, their ability to keep taxes low, the repatriation of funds back to the head office and highlights known risks associated with each country. Table 1: Risk Assessment for jurisdictions Ireland Isle of Man Gibraltar Economy Low Risk (2) in recession following collapse of the real estate bubble high unemployment Low Risk (1) strong GDP; low unemployment Low Risk (1) strong GDP; low unemployment Government Low Risk (2) Low Risk (1) Low Risk (1) Taxation Low Risk (2) Low Risk (1) Low Risk (1) very straight forward Repatriation of profits Low Risk (1) Low Risk (1) Low Risk (1) very easy and straight forward Relationships with International Bodies Low Risk (1) Low Risk (2) some countries are disagreeable with its territorial legal status High risk (4): major territorial ownership and political disagreement with neighbouring Spain Intellectual Property Protection Low Risk (1) Low Risk (1) UK rules Low Risk (2) UK rules + Gibraltar registration Technology Infrastructure Low Risk (1) Low Risk (2) adequate but not excellent Low Risk (2) adequate but not excellent Costs of setting up merchant account with internet low cost credit card transactions processing Low Risk (2) competitive internet based rate but more expensive than offshores Low Risk (1) Competitive internet based rate Low Risk (1) Competitive internet based rate Total Risks Summary 12 10 (Lowest) 13 Best Choice We also looked at other factors including GDP, unemployment rates, and various tax rates (corporate tax rate, capital gains tax, and stamp tax) to determine overall suitability (see table 2). Once again, the Isle of Man stands out due to its 0% tax rate and sound economic indicators. Table 2: Summary Stats We also looked at some financial considerations in dollar amounts. As such, Table 3 provides some financial data on the impact of taxation if our company made a profit of $5M or $55M and we show the after Corporate tax amount resulting from such calculations. We also added a column to show the impact on profits if we remained in Canada and did not use a subsidiary. As you can see the Isle of Man has a distinct advantage over all other competitors and with no Repatriation costs it has a substantial benefit over the Canadian market place as well. Table 3 Impact of Taxation on Corporate profits Corporate Profits (approximate) Ireland Isle of Man Gibraltar Canada Profits $5,000,000.00 $4,375,000.00 $5,000,000.00 $4,500,000.00 $3,900,000.00 Profits $55,000,000.00 $48,125,000.00 $55,000,000.00 $49,500,000.00 $42,900,000.00 CONCLUSION Opening a foreign-based subsidiary to process sales outside of North America can be very beneficial given that Quattroporte is looking at international trading. By establishing such a subsidiary, we will be able to circumvent withholding taxes on outgoing payments of dividends, interest and royalties. The routing of dividends through jurisdictions with favourable double tax treaties can help our organization avoid many such tax retentions. The key issues we looked at were: Zero to very low withholding taxes on dividends. No taxes in the jurisdiction of the holding company. Zero to very low withholding taxes on dividends (paid from holding company to shareholder). Although not a crucial immediate issue we should also consider whether our company would be subject to any tax on a future disposal of the subsidiary, or whether there would be any tax on a disposal of the holding company shares. It will also need to be considered whether Canada has any special provisions that apply to dividends from tax haven jurisdictions given our intent to locate to such countries. When identifying the most suitable location for opening a foreign-based subsidiary, we have found that the Isle of Man with its array of tax benefits, stable government, strong economy, and myriad of corporate and financial services will ultimately save our organization money, increase profits and streamline the operating costs of our business.

Wednesday, November 13, 2019

Comparing Joyce’s Ulysses and T.S. Eliot’s Love Song of J. Alfred Prufr

Comparing Joyce’s Ulysses and T.S. Eliot’s Love Song of J. Alfred Prufrock In Episode 8 of Ulysses, Joyce sends Bloom and the reader through a gauntlet of food that enlarges one of the novel ¹s main linguistic strategies, that of gradual digestion. While Episode 10 may seem like a more appropriate choice for a spatial representation of the city, this episode maps digestion out like Bloom wanders the streets of Dublin, with thoughts entering foremost through the body and exiting them. In T.S. Eliot ¹s poem "The Love Song of J. Alfred Prufrock," the stanzas deescalate the city from skyline to sea-bottom in accordance with the mock-hero ¹s own inability digest thoroughly any complete thought all the way through. Bloom describes the process of eating with realism appropriate to the task: "And we stuffing food in one hole and out behind: food, chyle, blood, dung, earth good: have to feed it like stoking an engine" (144-5). Indeed, this is the path words take in the novel; they begin in a pure form, as written on a page (such as Martha ¹s "Are you not happy in your home you poor little naughty boy?" which, despite its impure implications, is at least black ink on white paper) and filters into every stage of Bloom ¹s journey (as in Episode 8, 137). The gradual digestion of words fits with another of Martha ¹s lines, the typographical error "I called you naughty darling because I do not like that other world" (131). These words become "worlds," carving out a space as they travel throughout Dublin with Bloom. Bloom tosses the "throwaway" into the Liffey, and its words sail down not only the river, but alongside Bloom, causing him trouble and marking him as a throwaway himself. Words often hi nt at their own creation or foreshadow another... ...urface giddiness of "mermaids singing, each to each." Our paralysis in reading "Prufrock," from stanzaic symmetries ("And would it have been worth it, after all"/"That is not is, at all," used twice with minor variations) that indicate Prufrock ¹s stalled action to the anatomization of pluralized body parts ("eyes"/"arms") that rest heavily on a local item while emphasizing its multitude and power, "Disturb[s] the universe" as much as Prufrock ¹s own perambulations do, that is, not at all. He only sinks further down, drowning not only in other "human voices" but, more importantly, in his own constipation. Works Cited Eliot, T. S.. "The Love Song of Alfred J. Prufrock." Making Literature Matter: An Anthology for Readers and Writers. 2nd Ed. Schlib & Clifford. Boston: Bedford, 2003. 851-855. Joyce, James. The Portable James Joyce, New York: Penguin Books, 1996 Comparing Joyce’s Ulysses and T.S. Eliot’s Love Song of J. Alfred Prufr Comparing Joyce’s Ulysses and T.S. Eliot’s Love Song of J. Alfred Prufrock In Episode 8 of Ulysses, Joyce sends Bloom and the reader through a gauntlet of food that enlarges one of the novel ¹s main linguistic strategies, that of gradual digestion. While Episode 10 may seem like a more appropriate choice for a spatial representation of the city, this episode maps digestion out like Bloom wanders the streets of Dublin, with thoughts entering foremost through the body and exiting them. In T.S. Eliot ¹s poem "The Love Song of J. Alfred Prufrock," the stanzas deescalate the city from skyline to sea-bottom in accordance with the mock-hero ¹s own inability digest thoroughly any complete thought all the way through. Bloom describes the process of eating with realism appropriate to the task: "And we stuffing food in one hole and out behind: food, chyle, blood, dung, earth good: have to feed it like stoking an engine" (144-5). Indeed, this is the path words take in the novel; they begin in a pure form, as written on a page (such as Martha ¹s "Are you not happy in your home you poor little naughty boy?" which, despite its impure implications, is at least black ink on white paper) and filters into every stage of Bloom ¹s journey (as in Episode 8, 137). The gradual digestion of words fits with another of Martha ¹s lines, the typographical error "I called you naughty darling because I do not like that other world" (131). These words become "worlds," carving out a space as they travel throughout Dublin with Bloom. Bloom tosses the "throwaway" into the Liffey, and its words sail down not only the river, but alongside Bloom, causing him trouble and marking him as a throwaway himself. Words often hi nt at their own creation or foreshadow another... ...urface giddiness of "mermaids singing, each to each." Our paralysis in reading "Prufrock," from stanzaic symmetries ("And would it have been worth it, after all"/"That is not is, at all," used twice with minor variations) that indicate Prufrock ¹s stalled action to the anatomization of pluralized body parts ("eyes"/"arms") that rest heavily on a local item while emphasizing its multitude and power, "Disturb[s] the universe" as much as Prufrock ¹s own perambulations do, that is, not at all. He only sinks further down, drowning not only in other "human voices" but, more importantly, in his own constipation. Works Cited Eliot, T. S.. "The Love Song of Alfred J. Prufrock." Making Literature Matter: An Anthology for Readers and Writers. 2nd Ed. Schlib & Clifford. Boston: Bedford, 2003. 851-855. Joyce, James. The Portable James Joyce, New York: Penguin Books, 1996