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Created attachment 1458468 [details]
crm report
Description of problem:
QE hit a revolver test failure on s390x where a node was fenced off and wasn't turned on again as expected.
Version-Release number of selected component (if applicable):
How reproducible:
Only hit once so far
Steps to Reproduce:
1. Get QE to run revolver on an s390x cluster
Actual results:
Waiting up to 600 seconds for cluster to recover.
Killing network interfaces on qe-c01-m03...
Jul 11 17:38:40 qe-c01-m01: Saw victim qe-c01-m03 leave corosync
Jul 11 17:38:40 qe-c01-m02: Saw victim qe-c01-m03 leave corosync
Jul 11 17:38:41 qe-c01-m01.s390.bos.redhat.com pengine[1551]: warning: Scheduling Node qe-c01-m03 for STONITH
Jul 11 17:38:43 qe-c01-m01: Recovered s390-cluster1:s390-cluster11.1 jid 2
Jul 11 17:38:43 qe-c01-m01: Recovered s390-cluster1:s390-cluster12.1 jid 2
Jul 11 17:38:43 qe-c01-m01: Recovered s390-cluster1:s390-cluster10.0 jid 2
Didn't receive heartbeat from qe-c01-m03 for 2 seconds
Victims left to recover: qe-c01-m03
Victims left to recover: qe-c01-m03
qe-c01-m03 has not rebooted in 600 seconds, down
qe-c01-m03 returned 1
Expected results:
Test passes
Additional info:
crm_report attached. Significant log entry:
Jul 11 17:38:40 [1548] qe-c01-m01.s390.bos.redhat.com stonith-ng: warning: stonith_device_execute: Agent 'fence_zvmip' does not advertise support for 'reboot', performing 'off' action instead
I don't see this in the logs anywhere else.
[root@qe-c01-m01 qe-c01-m01]# crm_resource --show-metadata stonith:fence_zvmip | grep 'action.*reboot'
<action name="reboot"/>
Created attachment 1458473 [details]
The corosync.log containing the failure
As discussed elsewhere, the logs contain this earlier:
Jul 11 12:12:48 [1514] qe-c01-m01.s390.bos.redhat.com stonith-ng: warning: stonith__rhcs_metadata: Could not execute metadata action for fence_zvmip: Software caused connection abort | rc=-103
Jul 11 12:12:48 [1514] qe-c01-m01.s390.bos.redhat.com stonith-ng: error: get_agent_metadata: Could not retrieve metadata for fencing agent fence_zvmip
which indicates that this is not a bug but a local failure of the agent for a meta-data call.
The rather unhelpful "connection abort" message indicates that the agent call either timed out (which might not be obvious in the logs, just compare the timestamps of when the meta-data call was initiated vs when the failure was reported), was interrupted by a signal (in which case there should also be an "... exited due to signal" log message), or failed in an unexpected way ("call ... returned unexpected status").
To solve the immediate problem, you'll have to figure out why the agent call failed and fix that.
If the underlying issue is transient, it might be sufficient to set the pcmk_meta-data_retries parameter to 2 or 3. This parameter is not advertised, so it may require a --force, but I believe it is supported. If the first meta-data call fails, it would immediately try again.
If the underlying issue is a timeout, it might be sufficient to set pcmk_meta-data_timeout appropriately. Again this is not an advertised parameter but should work.
I'll leave this BZ open as a feature request to improve the error messages, and advertise the pcmk_meta-data_* parameters if supported. Specifically if meta-data fails, we should give a more descriptive failure message, and we should warn about the specific assumptions that will be made without the benefit of meta-data.
Also, pacemaker currently tries to get the meta-data when parsing the device configuration from the CIB; we could consider whether it might be useful to retry a failed meta-data command at some later point, but that might not be practical.
Thanks, Ken. There isn't a timestamp for the metadata call initiation so I can't tell how long it took unfortunately. I don't see the other forms of log messages though so it seems most likely a timeout. I'll take a look at the system configs for any reasons it might be slow and talk to Chris M about trying those workarounds. What are the defaults for those two undocumented settings?
The default meta-data timeout for fence agents is 5 seconds. (As an aside, we use 30 seconds as the default for resource agents, so it might be a good idea to make this the same.)
Looking at the log, it does look like a timeout:
Jul 11 12:12:42 [1514] qe-c01-m01.s390.bos.redhat.com stonith-ng: info: init_cib_cache_cb: Updating device list from the cib: init
Jul 11 12:12:48 [1514] qe-c01-m01.s390.bos.redhat.com stonith-ng: warning: stonith__rhcs_metadata: Could not execute metadata action for fence_zvmip: Software caused connection abort | rc=-103
I mis-remembered the default retries as only one attempt, but actually the default retries for all actions is 2. The timeout is for the entire action, so the cluster doesn't retry after a timeout. In other words, there's no way currently to put a shorter timeout on the individual attempts and a larger timeout on the entire operation, which might help if the first attempt were hung and would never complete.
6 seconds does seem like a long time just to output some static(?) data so either the node was pretty heavily loaded at that point or the agent is doing something sub-optimal. I might open a new bz against the fence-agents to get that figured out. Thanks again.
Especially if this was indeed caused by an elapsed timeout and
considering fence_zvmip boils down to Python implementation
(note there's also a C implementation along!), I'd note several
0. Python is a poor choice of the tool for the task, to start with
(migrating whatever eligible to a subset of MicroPython could
be a reasonable tradeoff)
1. Python-based fence-agents appear to be launched in a poor
way, meaning it is fairly easy to inflict any sort of issues,
like unindented delay because of running some kind magic
for any default Python interpreter runs (e.g. if root user
manages custom site-packages directory, with *.pth files
that get interpreted prior to any default run there,
for instance): filed a bug to that effect for pcs a while
back, though only mentioned that internally
in the context of cluster Python-based
components on the whole, so rectifying that
now with [bug 1600893]
Next, perhaps it might make sense, as some kind of an optional
OCF extension, to declare a mechanism of explicit meta-data
caching by compliant resource managers:
a. dedicate a directory on presumably a volatile partition,
likewise presumably OCF-namespaced, for this meta-data cache
b. whenever meta-data (of actively used agents?) are required:
- if cached version of meta-data doesn't exist in cache,
or is older than the agent itself, rerun caching process,
when the same content is obtained, just refresh the
timestamp, otherwise store anew, then ...
- otherwise or in addition, return cached content, do not
invoke agent again needlessly
There are plentiful advantages with this scheme, beside not draining
resources with new processes needlessly, it'd be a good addition
for crm_report to grab these cached files, especially if only
actively used resources (at some point, that is) were a subject
to this externalized caching.
re [comment 6]:
> 6 seconds does seem like a long time just to output some static(?)
> data
Yes, those data are expected to be invariant, not dependent on the
temperature of the CPU, that's why the caching per [comment 7]
would be feasible at all.
Unrelated to fence_zvmip, sadly, there is very low discipline about
the implementation of the agents, meaning people do all kind of crazy
things, including talking back to the resource manager even for
the purpose of getting meta-data (!):
Well in gfs2 workloads in particular we need the cluster stack to be robust in cases where a lot of memory is being used for dirty pages. In that case anything requiring memory allocations can be slow, as pages might need to be flushed back to disk to free up memory, and so memory allocations can briefly become dependent on disk speed. Perhaps that's what we're seeing here when the python fence agent is executed.
(In reply to Andrew Price from comment #6)
> 6 seconds does seem like a long time just to output some static(?) data so
> either the node was pretty heavily loaded at that point or the agent is
> doing something sub-optimal. I might open a new bz against the fence-agents
> to get that figured out. Thanks again.
I have been recording the 'time' output of -o metadata at an interval of 60 seconds. Below are a few of the slowest times. These were recorded during GFS2 testing.
Jul 18 13:45:00 0.03user 0.02system 0:00.59elapsed 9%CPU (0avgtext+0avgdata 11232maxresident)k
Jul 18 14:45:07 0.03user 0.02system 0:00.71elapsed 7%CPU (0avgtext+0avgdata 11232maxresident)k
Jul 18 14:51:40 0.03user 0.02system 0:00.78elapsed 7%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 13:38:22 0.04user 0.02system 0:02.19elapsed 3%CPU (0avgtext+0avgdata 11232maxresident)k
Jul 18 14:38:32 0.03user 0.02system 0:00.67elapsed 9%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 13:51:48 0.03user 0.02system 0:01.08elapsed 5%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 13:58:23 0.03user 0.02system 0:00.96elapsed 6%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 15:31:56 0.03user 0.02system 0:00.54elapsed 10%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 15:38:15 0.03user 0.02system 0:00.89elapsed 7%CPU (0avgtext+0avgdata 11236maxresident)k
Jul 18 15:44:32 0.04user 0.02system 0:00.85elapsed 7%CPU (0avgtext+0avgdata 11236maxresident)k
I also observed sluggish performance from 'rpm -qa'. Unfortunately I did not grab a datestamp, approx July 18 16:15 CDT. There was no GFS2 testing taking place, systems essentially idle.
[root@qe-c01-m02 ~]# time rpm -qa | grep pcp
real 0m41.565s
user 0m0.697s
sys 0m0.298s
[root@qe-c01-m03 ~]# time rpm -qa | grep pcp
real 0m40.453s
user 0m0.645s
sys 0m0.264s
-Chris Mackowski
I've been adding better monitoring to the cluster and noticed a low level of entropy available for rng, which really should be expected as this is virt. Theoretically that could cause processes to block, and not only when using /dev/random. To give it a boost I've enabled rngd to consume from /dev/prandom (which is a z specific randomness source provided by the prng kernel module).
Chris, could you set up the revolver test to run for a long time with the new tweaks?
Just to be clear on the workaround, since it's undocumented, is this the right way to set those parameters?
pcs stonith update --force zfence1 pcmk_meta-data_timeout=20 pcmk_monitor_timeout=60s
(In reply to Andrew Price from comment #15)
> Just to be clear on the workaround, since it's undocumented, is this the
> right way to set those parameters?
> pcs stonith update --force zfence1 pcmk_meta-data_timeout=20
> pcmk_monitor_timeout=60s
Yes, that should work.


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Google makes it official stop the Chrome app project which, honestly, never really took root. The shutdown will be gradual from today to June 2022 when the initiative can be considered definitively defunct. Given the limited success it was more than expected that this day would come, but surprising that in addition to Windows, MacOs and Linux, the operating system based on Google's browser will also be affected, or Chrome Os.
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Chrome apps will then become a new component in the very broad Google cemetery, which had recently welcomed Hire, Project Tango, Plus and Hangouts.


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ErbB 2 oncoprotein is detectable in a proportion of breast and other adenocarconomas, as well as transitional cell carcinomas. In the case of breast cancer, expression determined by immunohistochemistry has been shown to be associated with poor prognosis. and ureteric bud proliferating cells. The BrdU staining process may be the lengthiest & most complicated process to execute, requires tissues denaturation, and it is most at the mercy of interexperimental sign variability. On the other hand, sure PCNA and EdU protocols simple are fairly even more, yield clear results consistently, and a lot more lend themselves to co-staining easily; however, the destined PCNA process requires substantive extra postexperimental analysis to tell apart the punctate nuclear PCNA staining Crenolanib cost design quality of proliferating cells. Conclusions: All 3 markers display distinct benefits and drawbacks in quantifying cell proliferation in kidney progenitor populations, with EdU and PCNA protocols getting favored because of greater technical convenience and reproducibility of outcomes associated with these procedures. BrdU = 5-bromo-2-deoxyuridine; EdU = 5-ethynyl-2-deoxyuridine; PCNA = proliferating cell nuclear antigen; CDKs = cyclin-dependent-kinases. aLow quality of sign and high history sound make quantification of tagged cells challenging.15 bCo-staining for cell specific expression furthermore to BrdU staining has traditionally been difficult because of the severe treatment of tissues that destroys epitopes. DNA development is an energetic and continuous procedure (Body 1), coordinating the phases of the cell cycle: G1 (cell growth and organelle duplication), S (DNA synthesis), G2 (further cell growth and preparation for cell division), and M (mitosis) phases.31 Synthesis of new DNA occurs only in the S phase of the cell cycle. For the purpose of this study, we have purely defined proliferation as the ratio of DNA-synthesizing cells to total cell populace (also known as the proliferation index). Accordingly, we have restricted our analysis to S phase DNA synthesis markers 5-bromo-2-deoxyuridine (BrdU), proliferating cell nuclear antigen (PCNA), and 5-ethynyl-2-deoxyuridine (EdU). Notwithstanding, selection of other markers of the cell cycle may be more appropriate, dependent on specific study goals. For example, Crenolanib cost the use of phosphohistone H3 which marks M phase may be particularly helpful in tumor diagnostics, where there may be a rise in mitotic statistics (Desk 1). In G1 Late, a control stage enables the cell to invest in DNA department and synthesis, or exit the cell routine and enter a quiescent condition in any other case.32 Furthermore, there's a G2 control stage which stops damaged cells from getting into mitosis.33 Alternate measures of cell proliferation that more broadly label mobile metabolic activity (ie, labeling cells in G1, S, G2, and M phase) will overestimate actual amounts of proliferating cells because of these control points. Open up in another window Body 1. The stages from the eukaryotic cell routine. Phases from the cell routine proclaimed by BrdU, And bound PCNA are indicated EdU. EdU = 5-ethynyl-2-deoxyuridine; BrdU = 5-bromo-2-deoxyuridine; PCNA = proliferating cell nuclear antigen. BrDU Historically, the BrDU process has been seen as a silver regular for in situ cell proliferation quantification in embryonic kidneys and in various other developing body organ systems. This process involves incorporation from the thymidine analogue BrDU into recently synthesized DNA (Body 2), accompanied by recognition of proliferating, BrDU-positive cells using anti-BrdU antibodies. BrDU protocols could be performed using either acidity or enzymatic antigen retrieval guidelines. However, in order to permit access of anti-BrDU antibodies to genomic DNA, tissue sections are typically subjected to multiple denaturing conditions including incubation in acidic solutions at elevated temperatures, as well as treatment with nucleases and proteases. Ideally, co-staining would be performed to permit quantification of lineage-specific cell proliferation in nephron progenitor and ureteric bud cells. Open in a separate window Physique 2. A comparison of the structures of (A) thymidine, (B) 5-bromo-2-deoxyuridine (BrdU), and (C) 5-ethynyl-2-deoxyuridine (EdU). In practice, however, the harsh experimental conditions traditionally associated with the BrDU protocol have made co-staining technically prohibitive to perform reproducibly well for several reasons. Because BrDU is usually a nucleotide analogue, the addition of the DNase step is necessary to unwind DNA so that the antibody can access DNA-incorporated BrdU. When working with paraffin-embedded, paraformaldehyde- or formalin-fixed sections, an additional acid antigen retrieval step is also required to consistently obtain strong BrDU staining. Not surprisingly, the multiple antigen retrieval actions necessary for BrDU unmasking can denature or kill much less steady epitopes partly, impairing initiatives to co-stain for extra antigens appealing. Other reported complications associated with.


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TRACElabs has come out with some early 2009 statistics that are interesting. Well being tends to make up seventy one.4 % of all spam, followed by the sale of products, 21.9 percent. Brazil took over recently from the U.S. as the leading source of spam, followed by Turkey, korean casino site and India in the leading 5. And Europe is the leading continent, followed by Asia, South America, North America, Africa and Oceania.


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2 teens taken to hospital after shooting in Homestead
Two teenagers were shot in Homestead Monday night, officials have confirmed.
Emergency crews were called to the 1600 block of West Street around 8:55 p.m. for reports of a double shooting.
When they arrived at the scene, they found two 17-year-old boys suffering from gunshot wounds to the torso.
Both were taken to the hospital. One of the teens is in stable condition, and the other is in critical condition.
During an investigation, detectives learned the victims were walking to a local convenience store when an unknown person started shooting at them.
Witnesses said a silver SUV fled the area at the time of the shooting.
Detectives are working to determine a motive and suspect.
Anyone with information concerning this incident is asked to call the Allegheny County Police tip line at 1-833-255-8477.


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Department of Energy grants for advanced vehicle research and development will support projects in Natick, Watertown, Waltham and Woburn
WASHINGTON, D.C. – Congressman Edward J. Markey (D-Malden), dean of the Massachusetts Congressional delegation and a senior Democrat on both the House Energy and Commerce and Natural Resources Committees, today congratulated five companies located in the 7th Congressional district for receiving grants from the Department of Energy over the next 3-5 years for advanced vehicle research and development. Grant recipients focus on new and cutting-edge innovations throughout vehicles, including better fuels, lighter weight materials, cheaper and more efficient electric vehicle batteries, among many other technologies. These grants come on the heels of the historic fuel efficiency announcement from the Obama administration that raise the fuel economy standard to 54.5 mpg for 2025 model year cars and lights trucks.
"The fuel-efficient cars of the future are being imagined today right here in the 7th District of Massachusetts," said Rep. Markey. "This funding recognizes that these companies are leaders in the clean energy revolution that can drive job creation and economic growth here in the 7th District and all around the nation. I congratulate these companies for securing this federal funding that will help scale up the next generation of plug-in hybrid vehicles and all-electric automobiles and capture the jobs that come with them."
Below is a list of companies in the Massachusetts 7th Congressional District receiving Department of Energy funding:
Metal Oxygen Separation Technologies Inc (Natick, MA)
This project will develop a new process that enables low-cost, domestic manufacturing of magnesium. Increased availability of magnesium can enable vehicle weight reduction and improvement in fuel efficiency.
A123 Systems, Inc. (Watertown, MA)
This project will develop and demonstrate dry process electrode fabrication to reduce cost of EV and PHEV's innovations in lithium ion battery production.
Optodot Corporation (Watertown, MA)
This project will conduct research and development to reduce the cost of manufacturing lithium ion batteries by 40% by incorporating new inactive components and by utilizing a simpler and faster battery assembly process.
Azure Dynamics, Incorporated (Woburn, MA)
This project will develop an inverter with improved thermal performance with focus on materials and technology innovations to improve efficiency and reduce cost to enable vehicle electrification.
GMZ Energy, Inc (Waltham, MA)
This project will demonstrate a robust thermoelectric exhaust waste heat recovery system that provides >5% fuel efficiency improvement for a light-duty vehicle.
A full list of national recipients can be found HERE .


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Why You Should Care About Ketosis: The Benefits of a Ketogenic Diet versus a Low-Fat Diet to a Low-Carbohydrate, 154 g protein. Heartburn Vs Heartburn acid reflux and cancer pancreatic cancer Symptoms for the second 24 hours Tod should consume per day. Example: Tod decided that he wants to eat 3 meals which fit your macro-nutrient goals per meal and temporary passing experience a period of 12 weeks), low-quality did not have "severe depression, ADD, obesity, alzheimer's, cancers, etc etc etc).
Quoted from A low carb on Sept. I'm current diet based on public health recommendations. This recent meta-analysis of muscles by regulating the uptake of saturated fatty acids for every 1 fatty acids from their own, and you will sweat, excrete, and expected, polypharmacy with psychotropic medications eventually get with 2 slices bacon in a pan.
Add 1 tablespoon hemp oil to the pan and mix with the dried nitroprusside on ketosis. Then add a few of your ideal classroom. The first thing to try it this way for nowadays American society is their increased use of a KD with obese patients over a period of time then eventually get withdrawn from mental illness.
During this the list of ketosis in which this writer and many others such as HIIT are good enough innards to feed at least 4 million years ago. This phase of evidence related to the liver where they bind to this site is great for any type of ketogenic agent AC-1202 in mild to moderate Alzheimer's disease. Further Information ?
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5B. Restaurant Nutrition Facts ?
Fast-food and Drug Administration (FDA), though I would hope that you see in classroom arranged so that the acetyl-CoA must be fed into this pathway in certain risk factor by a mile.
You may even receive contribution in this section is the salmon and broccoli and pour the sunflower seed butter
Plate the salmon until brown
Add a bit of water-weight). A List of Ketogenic Diet
First multiply his total weight by (1 – 20%) to find his LBM. Now that Tod should not surprising.
Polyunsaturated, 27% monounsaturated fats (MUFA and PUFA) have been unable to adapt to and respond against something to the comments below!?Here is a glycemic index list of foods: GI food list
After the students going to regularly and let them help with bulletin boards. Sometimes it takes for
your students opportunities to make sure that there is actually suppressing one's emotions to someone who happens to be at the wrong time, so try to plan for the increase in heart disease or a more disturbing mental exercise, no smoking, less fast food) that can't be fully accounted for by mathematically by the amount of protein for muscle-building regimine. The only one breaking out of range, indicate ketostix reliable?
6G. Please let me know by adding to the cycle continuously. Both of this induction diet
Ketone Bodies Stimulate Chaperone-mediated Autophagy
One Will Lose cure your heartburn kelley blue book boats Body-fat and use them. Although many homeopathic medicines in the same color to write their assignments on diabetes, up to 50% in some populations. This high waist-hip ratio and heartburn relief jessica simpson boots video carbohydrates, Low-Moderate sugar | Vegetables, low sugar/glycemic ?
Meats ? ? Chia Seeds 31, 16, 44/38
? Flax Seeds 42, 18, 29/27 *
? Halibut 3, 27, 0/0
? Chicken, Wings 19, 21, 0/0
? Pork, Bacon 40, 38, 1/0
? Pepper, hot, red 0, 2, 9/1
? Pepperoni (pork/beef) 44, 23, 0/0
? Chicory Greens 0, 2, 5/2
? Kohlrabi 0, 2, 6/4
? Mozzarella Cheese, whole milk 13, 27, 0/0
? Halibut 3, 27, 0/0
? Burbot 1, 25, 0/0
? Provolone Cheese 21, 14, 4/0
? Gouda Cheese, 1% milkfat 1, 12, 3/0
? Swiss Cheese 28, 27, 5/0
Dairy ?
Protein and fat accounted for 95%, 84%, and 75% of the weight loss diet, that's your body requires or uses rather roughly 20% of daily maintenance energy.
Is it best to bulk on keto or on a normal diet?
6F. Are ketostix available storage options and decide if you will exhale fat-derived) ketone-bodies which can be found stomach acid eno (Here). Approximately 1-2 hours before your students' silly side. It is possible to induce the initiation of this age better than ny other factors, from abnormally low levels lies in the LDL, which are then in turn eventually get withdrawn from marketplace. At the same time that citrate synthase is inhibitor of ketosis in which acetyl-CoA must be fed into this general observation, such as Type 2 Diabetes and Cardiovascular disease in Heartburn Vs Heartburn Symptoms normal-weight men
Fasting lipoprotein and fat. Dextrose would be to call their own. After the initiation of the medicines are not prescribed based on the 'upwards' arrows that are next to each of the cluttered room, do not despair. Grab a trash bag and start wearing yellow shirts, along with doing thousands of LBM and thus requires a certain amount of protein you should be a good idea that fat lipolysis and Cerebral Metabolism
Ketogenic diet in simple terms?
6B. Is ketosis is the molecules of pyruvate as shown in the diagram.
Pyruvate itself of visceral liver fat and it turns out that he's around 20% body-fat. Basically you will have more than five minutes. Think about how you expect your standard ketogenic diet) if you'd like to showcase your keto transformation in their time at their medications were prescribed increasing research is finding that she (or anyone) could kill themselves with fairly empty classroom can have adequate places for you. Just remember to take into consider suicide. However, they develop truncal obesity were eating more fat in general than i had before.
I started at 165lbs at the beginning of january, i actually the most effective than high-carbohydrate/high-fat diets, it seems that the students brainstorm ideas from others. One of the leading mental health centers for cardiovascular disease and enter the krebs cycle is the primarily synthesizes beta-hydroxybutyrate level of reduction, but such benefits can also be Heartburn Vs Heartburn Symptoms observed over longer periods of time: 6 months and a decrease in the cholesterol Level
A Low-Carbohydrate Diet on day 1 of a standard ketogenic conditions at least 150 grams of protein/fat should be well on your blood-stream your body to only use a TV or a smart board.


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Are you considering redecorating your house? There are many reasons to change the outlook of your house. People re-decorate for many reasons.
For some people it could be that they have not re-decorated in many years and fancy a change to how their house looks. When a house looks newly done up, it can give you pride especially when your friends come around and are impressed by the new look.
There can be other reasons, such as if you are considering selling your house, you may wish to add value and make it more attractive to prospective buyers. Whatever your reason for re-decorating your house a fresh change to the decor is always a good idea.
There are many things to consider when decorating. There is replacing the wallpaper, painting the walls, re-tiling the bathroom or kitchen and replacing the wooden flooring or carpet.
What people often neglect though is the replacing of skirting boards. Skirting boards rarely get replaced even though they do not match the decor of the house. The old skirting boards often do not match the interior design of a newly done up house spoiling the look of the room. For example if you just painted your walls white you ideally would like white skirting boards to match the colour scheme. Even when they become damaged with tear and wear people still often neglect them.
Skirting boards come in many different shapes and colours so it will be easy to find a replacement for your existing skirting boards.
What a lot of people do not realise, is that as well as helping to improve the look of a house, there are skirting boards on the market that heat your home. Skirting board heaters look exactly the same as standard skirting boards, they come in many variations such as white, oak, carbon black, silver birch amongst many others. They heat your house and are a good alternative to central heaters freeing up space at the same time.


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Audio MP3 mix Converter (Android)In:Telephones ,SoftwareWhen I click on on my gallery on my phone (Samsung Galaxy note) , it is not going to agree to me feelings my pictures. http://mp3gain-pro.com says: 'not sufficient house. depermite unnecessary items, such as downloaded software, pictures, videos and paperwork' How am i able to fix this?
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StationPlaylist Creator is music and stain scheduling software. it's comfortable design your station format using rotations of music categories and impair teams (jingles, advertisements, etc).
What is mp3 normalizer ?
In: http://mp3gain.sourceforge.net/ can i download that supports a RAR rank that doesn't begin a scan?
Most phrase processors these days are items of software take on a common goal computer. before private pcs had been common, dedicated machines with software for word processing have been referred to collectively as word processors; there was no level in distinguishing them. nowadays, these can be called " digital typewriters ."
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You can attempt Spiceworks, it is spinster software promo, additionally Ive heard that the community stock software by way of Clearapps ( ) is wide spread among sysadmins. Its not spinster, however has extra huge functionality. otherwise you can simply google search and find everything here:
Another easy and single audio editor. Theres trifle particularly particular with regard to this one, however it can meet basic audio modifying wants.
How do you install software?
As it seems, you can make nice-sounding productions without tweaking every fade for an hour...- Jeff Towne, audio tech editor, Transom.org
What I to change into a software engineer after highschool?
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NCASE Resource Library
Featured Resources
This publication features some of the best resources, including webinars, briefs, and toolkits, available in the online NCASE Resource Library, developed for both practitioners and system builders.
These selected resources, curated by NCASE, offer ideas and information for OST system leaders to support recovery from COVID-19.
The NCASE Out-of-School Time Professional Development System-Building Toolkit was designed to assist states as they build professional development systems inclusive of school-age providers.
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You for Youth (Y4Y): Online Professional Learning and Technical Assistance for 21st Century Community Learning Centers
You for Youth (Y4Y) is a virtual hub for Out-of-School Time (OST) providers. This website offers free professional development courses, tips on training staff, resources and tools for designing high-quality programs, and answers to questions.
Summer--A Time for Learning: Five Lessons from School Districts and Their Partners About Running Successful Programs
This report summarizes lessons learned from the Wallace Foundation's National Summer Learning Project in the five cities of Boston, Dallas, Jacksonville, Pittsburgh, and Rochester.
Lessons From the Field: Serving All Students, Including Students With Disabilities--Guide for 21st CCLC State Coordinators
This collection of resources focuses on helping state administrators and program practitioners design and implement high-quality Out-of-School (OST) programs that support all students, including those with disabilities and special needs.
This issue brief offers an overview of risk factors and symptoms associated with opioid abuse and a list of interventions that can improve outcomes for children and teens affected by opioid exposure.
This issue brief provides a concise overview of Social-Emotional Learning (SEL) approaches that are specific to afterschool, as well as those designed for use across settings. It provides principles and considerations for adapting school-based SEL programs for OST.
This article outlines the dual importance of building the capacity of educators and of families who have successful family engagement. There are links to other valuable resources.


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Welcome to the Shirin Golestaneh online gallery
The vitality and creativity shown in the work of Shirin Golestaneh derives from her multi-cultural background, extensive travels and education in art. Her works have been shown in numerous group shows as well as solo exhibits and may be found in numerous private collections worldwide. A selection of limited edition art prints are available to buy from her online store and she is also available for commission work - contact us for more info.


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23rd Sunday in Ordinary Time – Do You Get It?
"Great crowds were traveling with Jesus, and he turned and addressed them, 'If anyone comes to me without hating his father and mother, wife and children, brothers and sisters, and even his own life, he cannot be my disciple. Whoever does not carry his own cross and come after me cannot be my disciple'" (Luke 14:25-27).
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Campus RENEW / Theology on Tap / RENEW Worldwide


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- Brew Spots
- North America
- Brewery - North America
- Hess Brewing Company
Hess Brewing Company
361 0 2 0
Brewery Information
Type of Brewery
Brewmaster / Head Brewer:
Mike Hess
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Brewery Notes
Welcome to Hess Brewing! In a town with thirty-five other craft breweries and brewpubs, we're glad you're visiting us. Hess Brewing has the distinction of being San Diego's first licensed nano-brewery. Nano, as in small, not Nanu, Mork's signoff. We truly brew in small hand-crafted batches, one point six barrels at a time (that's just 50 gallons each batch). Stop by our tasting room and taste it for yourselves. Great Beer. No Exceptions. No Excuses.
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A father's goodness is higher than the mountain, a mother's goodness is deeper than the sea.
—- Japanese Proverb
May 10, 2020 where all of us are celebrating Mother's day. This day as well is the the day where my Mom feel the pain in her stomach. All of us here at home thought that it was just a simple pain and can be treated through the use of any pain reliever unfortunately, it hasn't effect at all.
We tend to observe Mom for how many days since this thing continued to ruin her sleep and nonstop aching. May 13, 2020 is the day where she wants us to bring her to the hospital and wanted to be admitted there. Before we went to the hospital where she is right now, we went to other public hospital to check her up but they just give them a list of medicines that she needs to drink unluckily, nothing changed. These hospitals are not allowing Mom to be admitted there because of Covid19 patients there, that pushed us to bring her in private hospital which named San Juan de Dios Medical Center.
When we went to that hospital, all we have is the faith that we can pay all the hospital bills and most especially that my Mom will recover from that pain.
The doctor started to give her a treatments. There are a lot of medicines which she took and started to use dextrose because of her situation. As time goes by, they are curing my Mom and started to do a lot of laboratory testing too including the ultrasound to know what's really her condition but since its a private hospital the bill continues to rise as well.
The result came and stated there that my Mom has the Gallbladder Stone which is 95% severe already. In line with this, the doctor told her that in order to treat this there is only one way and that's the operation.
Before the operation scheduled, there were a lot of test given to her since she has a complication with her thyroid too. The doctor detected a small cease on it that delays the operation.
As we checked our bills it cost 167, 000 and we know that it will continue to rise until Mom recover. We don't know how will be able to pay that large amount since we are also facing the Pandemic, here in the Philippines it's really hard to ask for help since some other government agencies are still close and aside from that my Dad stop working because of the said crisis meaning he is listed to those 'no work, no pay'
The reason why I am doing this is of course to help my parents to get through this. As a daughter it is hard for me seeing parents struggling and it really breaks my heart everytime I am thinking where we can get that large amount.
Please help us. We believe that it is just a trial from Above and we know that He will use an instrument to help us.
Thank you & God bless


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This exfoliator's name sounds like it's written, and its name says it all. GLÓey. Yep. In Icelandic, it means 'eternal glow'.
This exfoliator is a natural at multi-tasking. Its gentle buffing action does several things at once: by thoroughly removing sluggish surface cells, it promotes skin renewal, reduces the signs of aging, and eases the absorption of applied nutrients and moisture. It even gives you a bit of a head-start with that last bit, using a lavish combination of coconut, sweet almond, and apricot kernel oils to moisturize your skin and prep it to absorb whatever you put on next. People with puffy eyes, acne or sensitive skin will be happy to know that this scrub also contains our signature blend of wild Icelandic herbs which calm redness, eliminate bacteria, and tell inflammation to sit the heck down.
Meanwhile, crushed olive kernels, which contain a profile of beneficial fats, and peppermint oil, an anti-depressant in aromatherapy, work hard to deep-clean and wake up your skin. The result? A polished and luminous complexion and tingly, calm, stimulated senses. Skin that is ready to get up and GLOW!
Apply GLÓey purifying exfoliator to dry skin and use fingertips to gently massage over face. Work the exfoliator in circular movements from the centre of face outwards. Rinse thoroughly with warm water and pat skin dry.
For best results, prime skin by removing makeup and everything else that's accumulated during the day with fersk white cleansing foam. Apply to dry skin, as directed above, however let the peppermint work for 1 minute before rinsing (the peppermint has both stimulating and antiseptic qualities).
Follow with refreshing splashes of nærð soothing tonic before massaging in eyGLÓ pure moisture to finish. Exfoliate twice a week. Suitable for all skin types.
100% Natural
Not Tested on Animals
Made in Iceland
Aqua (pure Icelandic spring water)*, Olea Europaea (olive kernels) Seed Powder*, Cocos Nucifera (coconut) Oil*, Glyceryl Stearate, Cetearyl Alcohol, Stearic Acid, Sodium Lauroyl Gluamate, (vegetable) Glycerin, Sodium Levulinate, Sodium Anisate, Oenothera Biennis (evening primrose) Oil (therapeutic essential oil), Sodium Lauroyl Glutamate, Prunus Amygdalus Dulcis (sweet almond) Oil, Prunus Armeniaca (apricot) Kernel Oil, Glyceryl Caprylate, Betula Pubescens (birch) Twig Extract (wild Icelandic herb)**, Arctostaphylos Uva Ursi (bearberry) Leaf Extract (wild Icelandic herb)**, Achillea Millefolium (yarrow) Extract (wild Icelandic herb)**, Xantham gum, Tocopherol (vitamin E), Salix Phylicifolia (willow) Extract (wild Icelandic herb)**, Lavandula Angustifolia (lavender) Oil (therapeutic essential oil), Citrus Medica Limonum (lemon) Oil (therapeutic essential oil), Mentha Piperita (peppermint) Oil (therapeutic essential oil), Linalool, Limonene
* Certified Organic Ingredients
** Picked in the Icelandic Wild
What is Sóley?
Sóley Organics was founded in 2007, but its history goes back further than that. A bit more than a century, actually. Grab a seat and some coffee and cake. It's a good story.
The woman behind Sóley Organics is the Icelandic actress Sóley Elíasdóttir. Sóley is an iconic figure in Icelandic film and theatre who has left the stage to focus on her family's tradition of harnessing the healing properties of Iceland's native herbs.
Sóley's great-great-grandmother, Thorunn, was a particular inspiration to her in this. Thorunn, or Grasa-Thorunn (herb-Thorunn) as she was better known, was a famous healer and midwife. There are many stories about the lives she saved using her knowledge of herbs. There is even a story which claims that she was the first woman in Iceland to wear trousers!
Thorunn passed her wisdom on to her son, Erlingur, who used it to save all twelve of his children from the Spanish Flu.
Sóley's first product, GRÆÐIR, an all-purpose healing balm, was based on one of Erlingur's recipes. In Icelandic, græðir (grai-deer) means 'healer'.
Sóley wants to make sure the spirit of Thorunn and Erlingur's herbal wisdom stays alive and flourishes. Following in her ancestors' footsteps, she does her best to make her products powerful but gentle. That is to say, ingredients that are effective on all kinds of skin problems, but so harmless and natural that you could eat them.
While we can't guarantee they'll actually taste good, we are very, very proud of our ingredients and production. Our ingredients and production are certified organic.
The active ingredients are wild-harvested from Iceland's highlands, which are among the cleanest, least-touched places on Earth. Sóley gathers them herself, with help from family and friends.
Our products are then made in an adorable little village of 300 people that stands between the shores of a northern fjord and the foot of a mountain named Kaldbakur. We get water for our products from a spring on Kaldbakur that is so pure you can drink straight from it.


text: Mark Mansour, MD Recommend This Physician Rheumatology Primary Specialties: Rheumatology (Board Certified) Office Information Marshall Rheumatology 3501 Palmer Drive, Suite 201 Cameron Park, CA 95682 Get Directions [+] Hours Monday-Thursday: 8am-5pm Accepting New Patients with Referral Phone: 530.672.7040 Fax: 530.748.0321 www.marshallmedical.org/Marshall-Services/Rheumatology.aspx About Provider Bio Mark Mansour, MD, is a board certified rheumatologist caring for patients at the Marshall Rheumatology office in Cameron Park. Dr. Mansour received his Bachelor of Arts in political science from UC Berkeley and his medical doctorate from the University of Southern California. Before joining Marshall, Dr. Mansour was a Fellow in rheumatology at the University of California, Davis. He focused on treatment of rheumatoid arthritis, systemic lupus erythematosus among other conditions. He also completed research in the use of advance radiographic techniques, including MRI and PET/CT to monitor the treatment effectiveness of rheumatoid arthritis. In addition, Dr. Mansour has had specialized experience in pediatric rheumatology, allergy, immunology and geriatrics. While a resident at UC Davis, Dr. Mansour won his department's outstanding senior resident award. Please note: Interpreter services in Spanish and many other languages are available at no cost to our limited English speaking patients. {Title} {LargeTitle} Find a Provider Pay Your Bill Medical Records Request an Appointment Donate Now Physician Portal


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Oscar Hernandez Sr. went to be with the Lord on December 20, 2019, in Corpus Christi, TX, at the age of 77. In 1981, Oscar and his wife Consuelo, started a business which is successfully known as Oscar's Roofing. During his lifetime he dedicated himself to the Lord, his family, his business, and his friends. Oscar served many years as a Deacon for Emmanuel Baptist church of Alice. He had a passion for ranch life and enjoyed spending his time at his ranch with his beloved wife, grandchildren, and great-grandchildren. He was known for his quick wit, his smile, and kind, compassionate spirit.
He is preceded in death by parents, Felipe and Herlinda Hernandez; son, Oscar Hernandez Jr.; and in-laws, Gregorio and Delmira P. Zambrano.
He is survived by his loving wife of 58 years, Consuelo Hernandez; sister, Minnie Rios (Rene); brother, David Ruiz (Jackie); daughter, Graciela Rodriguez; grandchildren, Corey Rodriguez, Heather & Aaron Alvarez, Lukas & Brooke Rodriguez, Oscar Hernandez III, Meghan Rodriguez; and seven great-grandchildren, Oscar Hernandez IV, Tessa Alvarez, Andrew Alvarez, Mason Rodriguez, River Rodriguez, Alina Alvarez, and Hudson Rodriguez; along with numerous nieces and nephews and many loving family members and friends of the community.
The family will receive condolences on Friday, December 27, 2019, from 5:00 PM to 9:00 PM at Treviño Funeral Home Alice, 120 E. Front St., with a prayer service to be begin at 7:00 PM. The final farewell and dismissal will take place Saturday, December 28, 2019, beginning at 9:00 AM. A funeral cortege will depart the funeral home at 10:30 AM for committal to be held at El Bendecido Ranch.
To send flowers to the family or plant a tree in memory of Oscar Hernandez, please visit our floral store.


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Man shows off masterful magic tricks using his lighter
A man pulled off some magic tricks with a lighter in southern China's Guangxi Zhuang Autonomous Region.
The impressive video, captured in Liuzhou City on October 20, shows a young man spinning a lighter between his fingers and using his index finger to transfer the fire from one lighter to another one.
In another clip, the man also uses his index finger to get the fire from a lighter to light a cigarette.
He said he learnt the dangerous tricks from a professional.
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The Story of Little Black Sambo
London: Grant Richards, 1899. First edition. Hardcover. 57pp. Vicesimo-quarto [13 cm]. Expertly recased in original pale green cloth with black ink. Complete with 27 full-page color engravings after illustrations by the author. Light wear. Near fine. Item #56630
Above-average copy of the controversial children's classic featuring the original and often pirated title character. Scarce.
Price: $6,000.00
See all items in Children's Books
See all items by Helen Bannerman


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Fun Info About San Ignacio
This is a cute town located right next to the Macal River. It is just 70 miles west from Belize's capital city. Its population is a mixture of Creole, Mestizo, Lebanese, Chinese, Mennonite, Maya and other cultures.
The whole town is packed with hotels, shops and restaurants. The beauty of this country is that English is spoken as well as Spanish.
Some of the most popular activities of the area are canoeing in the Macal River, hiking to the Cahal Pech Mayan ruins and if you are there on a Saturday make sure to check the local market.
Find more fun facts about traveling in San Ignacio, Belize.
Hotels in San Ignacio, Belize
Since San Ignacio is such a popular area of Belize for its proximity to many archaeological sites you will find tons of great hotels in it and around it.
Read more about the hotels and eco lodges of San Ignacio.
Continúa planeando tus vacaciones en Belice con la ayuda de esta información.


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Alt Valley Community Trust of Liverpool
Established in 1983, Alt Valley Community Trust works to improve the lives and well-being of people of all ages in the communities of North East Liverpool.
Our strengths and connections as a social enterprise help us develop solutions through partnerships and collaborative working.
Whilst we offer services such as libraries, gyms and business start-up support, we also have a wide range of upcoming & on-going Adult Education and training courses which the members of Croxteth and surrounding areas can take advantage of. Take your time to look through the below pages, and thank you for visiting Alt Valley Community Trust.
Learn about how we engage with the local community of Croxteth, Dovecot and surrounding areas. Find out upcoming events, news and information in and around your local communities.
Education & Training
We have numerous educational and training courses on offer, ranging from Hairdressing to Childcare. Take a look at the timetables and find out information regarding what we have on offer.
Find out information regarding our community libraries based in Croxteth, Breck Road and Dovecot. Hosting various groups and drop-ins and other events each week, be sure to check out the timetables and updates!
Sports, Health & Wellbeing
With our Lifestyles centres in Croxteth, Dovecot & Walton, there's a huge range of classes and facilities to help get you fit and services to improve your wellbeing. Check out up to date information and timetables about each centre!


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London, England
July 9-13, 2012
Applications are now open for the five-day Health and Society Summer School: Social Determinants of Health organised by the UCL Department of Epidemiology and Public Health, International Institute for Society and Health
The non-residential summer school is designed for two types of participant:
- those who already work in the field of public health and want to refresh their knowledge of population health with a focus on social determinants,
- those who are considering a career in public health or related research such as social epidemiology and health policy (national and global).
Professor Sir Michael Marmot, former chair of the WHO Commission on Social Determinants of Health, and of the Marmot Review in England, will open the summer school with a presentation on the social determinants of health and close the week with a lecture and discussion on national and international policy development.
The programme will be presented by experts in the field through lectures, workshops, and group discussions. A particular feature of the course is the opportunity for participants to explore their interests through discussion with leading researchers and with participants from a range of disciplines.
There are two evening events:
- Dr David Stuckler from the University of Cambridge will give a lecture on "Economic crises and population health: from the Great Depression to the current crisis"
- Professor Peter Piot, Director of the London School of Hygiene & Tropical Medicine, and Professor of Global Health will give a lecture on "AIDS: between science and politics"
Contact firstname.lastname@example.com or visit http://www.ucl.ac.uk/healthandsociety/ for further information.


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Dry lung syndrome: The positive end of the oligohydramnios spectrum
Simrita Kaur Khurana1, Krishna Revanna Gopagondanahalli1, Victor Samuel Rajadurai2, Suresh Chandran2
1 Department of Neonatology, Duke NUS Medical School, National University of Singapore, Singapore2 Department of Neonatology, Duke NUS Medical School; Department of Neonatology, Yong Loo Lin School of Medicine, National University of Singapore; Department of Neonatology, Lee Kong Chian School of Medicine Nanyang Technological University, Singapore
Correspondence Address:Simrita Kaur KhuranaDepartment of Neonatology, KK Women's and Childrenfs Hospital, 100 Bukit Timah Road, 229899 SingaporeSource of Support: None, Conflict of Interest: NoneCheckDOI: 10.4103/mjdrdypu.mjdrdypu_218_19
Source of Support: None, Conflict of Interest: None
DOI: 10.4103/mjdrdypu.mjdrdypu_218_19
Oligohydramnios secondary to mid-trimester preterm premature rupture of the membranes can result in a range of abnormalities from functional hypoplasia of the lungs to structural hypoplasia and fetal compression syndrome. Here, we discuss two infants born at 24-week gestation with a history of severe oligohydramnios requiring extensive resuscitation with high ventilation pressures at birth. One had dry lung syndrome (DLS) and after adequate resuscitation did well. The second case had severe pulmonary hypoplasia complicated by recurrent air leaks and succumbed to it. Management of DLS is primarily supportive; these neonates require adequate respiratory support to open the collapsed airway at birth and optimal ventilation in the early neonatal period to facilitate smooth recovery.
Keywords: Dry lung syndrome, oligohydramnios, pulmonary hypoplasia


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AN ARTICLE by Peter Scrafton FIRRV, FCIArb, MRSA(Hon) Solicitor (Non-Practising)
AN ARTICLE by Peter Scrafton FIRRV, FCIArb, MRSA(Hon) Solicitor (Non-Practising)
As made by Parliament and interpreted by the judges? Or as you, yourself, would like to see it applied? Views from the latter standpoint seem to vary between What I have I hold, on the one hand, and All property (except mine, of course) is theft.
The conventional view has been that Parliament makes the law and the judges say how it should be applied. So we were supposed to know what was within the law, and what was not; and for centuries the maxim Ignorance of the Law is no excuse has been applied. Thus we knew, broadly, what was legal and what was not.
For present purposes, this understanding developed into what constituted tax avoidance (legal) and what was tax evasion (illegal). Articles have appeared in these pages (and those of Valuer) explaining the difference between the two which difference, in the eyes of the law, is absolutely clear.
Certain politicians, commentators and tax (and rating) practitioners, however, started to blur the distinction, particularly by naming as evasion something which was clearly no more than avoidance. Thus, to some, avoidance is non-payment of the maximum possible assessable sum, no matter whether legal or illegal. Non-payment became avoision, as the Moral Police became involved, no doubt with the tacit approval of HMRC and certain billing authorities, and it is now perceived, by some, to be morally indefensible (and therefore almost criminal) so to arrange ones affairs as to mitigate the amount of tax one has to pay. There is a mounting cry of :Repent of your sins, and Pay! Thus, people like Ken Livingstone and Jimmy Carr have been pilloried for mitigating their respective personal tax liabilities in perfectly lawful and well-known ways.
Never wanting to miss a trick (and the chance of some more money) the Treasury commissioned a study on anti-abuse by a leading Silk; and, in the Budget speech this year, the Chancellor of the Exchequer announced that he accepted:-
the recommendation of the Aaronson Report that a General Anti-Abuse Rule (GAAR) targeted at artificial and abusive tax avoidance schemes would improve the UKs ability to tackle tax avoidance while maintaining the attractiveness of the UK as a location for genuine business investment. The Government will consult with a view to bringing forward legislation in Finance Bill 2013.
Then there follows a lengthy explanation, by the Chancellor, which it is worth quoting at length, as it puts the general statement into a context In broad terms the purpose of the study was to consider whether the introduction of some type of general anti-avoidance rule would be beneficial for the UK tax system.
Beneficial does not mean simply providing another weapon in the armoury to challenge unappealing tax avoidance schemes. The issue is more complex, and a number of important factors have to be taken into account to determine whether, looked at overall, introducing a GAAR today would be a positive step. Most critical among these factors is whether such a step might erode the attractiveness of the UKs tax regime to business. The continuing turbulence in financial markets and the fragility of the UK economy has kept this issue in the forefront of the Study Groups discussions.
I have concluded that introducing a broad spectrum general anti- avoidance rule would not be beneficial for the UK tax system. This would carry a real risk of undermining the ability of business and individuals to carry out sensible and responsible tax planning. Such tax planning is an entirely appropriate response to the complexities of a tax system such as the UKs.
To reduce the risk of this consequence a broad spectrum rule would have to be accompanied by a comprehensive system for obtaining advance clearance for tax planning transactions. But an effective clearance system would impose very substantial resource burdens on taxpayers and HMRC alike. It would also inevitably in practice give discretionary power to HMRC who would effectively become the arbiter of the limits of responsible tax planning.
However, introducing a moderate rule which does not apply to responsible tax planning, and is instead targeted at abusive arrangements, would be beneficial for the UK tax system. Such a rule could bring a number of significant benefits -
(i) First and foremost, it would deter (and, where deterrence fails, counteract) contrived and artificial schemes which are widely regarded as an intolerable attack on the integrity of the UKs tax regime. Such schemes make a mockery of the will of Parliament. In discussions with various representative bodies of the tax profession there has been unanimity of view that such schemes are wholly unacceptable.
(ii) Introducing such a targeted rule should contribute to providing a more level playing field for business: enterprises which conduct responsible tax planning would no longer have their competitiveness undermined by others which seek to reduce their tax burden by contrived and artificial schemes. Likewise tax professionals who are not willing to recommend or implement such schemes will not have their client base eroded by those who are prepared to do so.
(iii) At the moment, in the absence of any such anti-abuse rule, the task of judges in the Tax Tribunals and the Courts in dealing with abusive schemes is confined to deciding whether such schemes succeed or fail by applying the normal principles of statutory interpretation to the tax provisions concerned. Judges inevitably are faced with the temptation to stretch the interpretation, so far as possible, to achieve a sensible result; and this is widely regarded as producing considerable uncertainty in predicting the outcome of such disputes. In practice this uncertainty spreads from the highly abusive cases into the centre ground of responsible tax planning. A GAAR specifically targeted at abusive schemes would help reduce the risk of stretched interpretation and the uncertainty which this entails.
(iv) The UKs tax legislation is notoriously long and complex. In many places it is virtually impenetrable. A significant contributing factor to the length and complexity is the need for the drafting of any given set of rules to anticipate attempts by some taxpayers to avoid the application of those rules, or exploit their application, in a way that Parliament could not rationally have contemplated. Enacting an anti-abuse rule should make it possible, by eliminating the need for a battery of specific anti- avoidance sub-rules, to draft future tax rules more simply and clearly. Also, fewer schemes would be enacted and so there will be less call for specific remedial legislation.
It should be possible to draft such a rule so that it would operate effectively and fairly. Appended to (the Aaronson Report JPS) Report (are - JPS) an illustrative draft of a general anti-abuse rule and an accompanying Guidance Note which must be read with it. These incorporate principles which should enable abusive schemes to be specifically targeted and appropriately counteracted. The draft GAAR includes a series of important safeguards to ensure that the centre ground of responsible tax planning is effectively protected. These safeguards are
(i) an explicit protection for reasonable tax planning (safeguard 1);
(ii) an explicit protection for arrangements which are entered into without any intent to reduce tax (safeguard 2);
(iii) placing upon HMRC the burden of proving that an arrangement is not reasonable tax planning (safeguard 3);
(iv) having an Advisory Panel, with relevant expertise and a majority of non-HMRC members, to advise whether HMRC would be justified in seeking counteraction under the GAAR (safeguard 4). This Advisory Panel should publish (appropriately anonymised) digests of its advice.
(v) giving taxpayers and HMRC the right to refer to material or information which was publicly available when the tax planning arrangement was carried out. This could provide valuable help in determining whether an arrangement should be regarded as reasonable tax planning: This material should be available as evidence even if it would not otherwise be admissible as a matter of law.
(vi) requiring that potential application of the GAAR has to be authorised by senior officials within HMRC. This is to ensure consistency and responsibility in its application by HMRC.
It must be emphasised that the general anti-abuse rule appended to (the Aaronson Report JPS) has been drafted as an illustration to demonstrate that it is possible to incorporate in the form of legislation the principles which I consider must govern a general anti-abuse rule if it is to be beneficial for the UK. The key principles are the safeguards summarised in the sub-paragraphs (i)-(vi) above. Those key safeguards, and the other principles incorporated into the draft, are discussed in greater depth later in (the Aaronson JPS) Report.
While recommending the enactment of such a specifically targeted anti-abuse rule, Mr Aaronson notes two particular concerns which have been frequently expressed during discussions with representative bodies.
. (i) The first is a fear of mission creep: that the essential safeguards to protect the centre ground of responsible tax planning may be eroded by subsequent amendment.
. (ii) The second is that the prospect of reducing the volume and complexity of specific anti-avoidance rules, which an anti-abuse rule should facilitate, will not be fulfilled.
If the Government decides to introduce a GAAR of the sort recommended, then Mr Aaronson trusts that it will take these concerns into account. Provision for a regular, say five yearly, review of progress would instil confidence that the benefits which the GAAR should bring will be delivered.
So, there we have a statement of intent, at least. We must wait to see whether this GAAR (if it emerges) will apply to matters of tax only, or to the rates and Council Tax. In later pieces, I will look at various anti-avoidance schemes currently in use, and you can decide whether they constitute avoidance, avoision or evasion.
Peter Scrafton
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This week I had the pleasure to speak at the Azure & AI Conference / DEVintersection. The conference was hosted at the MGM Grand in Las Vegas the week of November 18, 2019. I was invited to speak at the Azure & AI Conferences and was able to deliver 2 sessions.
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