The Catalans went through 4-2 on aggregate after coming from behind twice to win 3-2 on the night as Atletico were reduced to nine men and were lucky not to be more harshly punished when Arda Turan was only booked for throwing his boot at an assistant referee.“The moment arrived when the game had got ugly and we took off Neymar so it didn’t get any more heated,” said Enrique.“Players ought to be intelligent and know that they are fellow professionals.”Neymar had already put Atletico’s hopes of reaching the last four to the sword well before he was replaced by Pedro Rodriguez 13 minutes from time.The Brazilian levelled with his 20th goal of the season after Fernando Torres had brought Atletico level in the tie with a first minute opener.Raul Garcia then briefly put Atletico back in front from the spot, but Miranda’s own goal made it 2-2 before Neymar pounced again on the counter-attack three minutes before the break.Atletico captain Gabi was then sent-off at half-time and Mario Suarez was also dismissed as the Spanish champions completely lost their heads after the break.“Neymar showed the attitude he always does. He is a player with a lot of confidence and helps us all in all phases of the game. Today he was outstanding,” added Enrique.However, Atletico boss Diego Simeone defended his players despite referee Jesus Gil Manzano showing six yellow cards and two reds to his side during a tempestuous 90 minutes.“I feel proud of my players. In the first-half they were extraordinary and showed an incredible fight.“It was very difficult to attack because the ball was bobbling all the time. Barcelona played on the counter-attack, which is rare for them and they did it very well.”Simeone also accepted the responsibility for his side’s showing after the break as he shut up shop in hope of avoiding a more demoralising scoreline.“In the second-half due to my decision the team played as you saw, without taking any risks so that they didn’t score.“I tried to do the best for my club and my players. We played the most convenient way for us. I am the coach and it is what I thought was the right thing to do.”0Shares0000(Visited 1 times, 1 visits today) 0Shares0000MADRID, January 29 – Barcelona boss Luis Enrique said he had to substitute two-goal star Neymar to prevent the Brazilian from being injured as his side’s Copa del Rey quarter-final, second leg with Atletico Madrid turned nasty.
A study by the Government Accountability Office, released in January, observes a shift in sale of counterfeit goods from “underground” or secondary markets, such as flea markets or sidewalk vendors, “to primary markets, including e-commerce websites, corporate and government supply chains, and traditional retail stores.”Additionally, the physical appearance of counterfeit goods may no longer serve as a red flag that a product is fake, as additional types of bogus products closely resemble genuine goods, according to the GAO report, Agencies Can Improve Efforts to Address Risks Posed by Changing Counterfeits Market.It’s not the only recent study to include a warning to manufacturers to review their brand protection strategy. “The continuous growth of the global counterfeiting industry is a major cause for concern,” according to a recent report by the United States Chamber of Commerce’s Global Intellectual Property Center (GIPC), Measuring the Magnitude of Global Counterfeiting, 2016. “Fueled by the proliferation of Internet use and social media platforms, the magnitude of global physical counterfeiting is estimated to have increased significantly since the beginning of this century.”- Sponsor – The numbers are staggering. Between 2012 to 2014, according to US Customs and Border Protection, the value of seized counterfeit goods in the US averaged $1,351,067,064 annually. The figure only counts the value from seizures, so it surely fails to adequately capture the full scope of trade-related counterfeiting, according the GIPC. As big as the number is, it has to be considered a “floor,” says the group.Counterfeiting has a host of negative repercussions. “First and foremost, counterfeit goods jeopardize consumers and pose a serious safety risk,” warns the GIPC. Fake toys, for example, may contain hazardous and prohibited chemicals and detachable small parts. Counterfeit products also take a toll on the overall health of the economy, due to decreased innovation, loss of revenue and taxation, higher unemployment, and slower economic growth. Finally, a growing body of evidence draws a clear link between physical counterfeiting and terrorist groups, according to the GIPC.A study by the Rand Corporation examined that link. Its review of 14 cases of crime organizations involved in film piracy revealed three cases in which terrorist groups financed their activities from the proceeds of the activity. In one example, an individual known for pirating DVDs and a “global terrorist”—as identified by the US government—transferred $3.5 million to a Hezbollah leader. “These cases, combined with established evidence for the broader category of counterfeiting-terrorism connections, are highly suggestive that intellectual-property theft-a low risk, high-profile enterprise-is attractive not only to organized crime, but also to terrorists, particularly opportunistic members of local terrorist cells,” the Rand report concluded.Fake products also take a toll on a company’s reputation. “Counterfeit goods, being of generally inferior quality, damage brands in the opinion of those that buy counterfeit versions unwittingly,” notes a report by Perpetuity Research & Consultancy International (PCRI), Organizing for Brand Protection. Purchases of fake goods also cut into company sales and are unfair competition to legitimate retailers. When consumers knowingly buy fake goods, it threatens retailers’ exclusivity and “results in branded goods becoming visible in inappropriate retail settings.” “Brand owners therefore need to be proactive in protecting their brands,” concludes the PCRI study based on interviews with senior brand protection executives at 26 organizations and representing some of the world’s biggest brands.Case Studies in Brand ProtectionA counterfeiting operation should not elicit the image of a few thieves in some small room making cheap, obvious knock-offs. Such operations do exist, but so do sophisticated ones that look and act like any production facility—except that the sale of their goods directly siphons money away from legitimate manufacturer and sellers.So what security measures have companies taken to successfully fight back? Some retailers are looking to technology as a way to fight fakes. For example, one footwear retailer is reportedly using blockchain and 3D-printed smart tags—that can be scanned by a smartphone—to prove product authenticity. The GIPC has highlighted some of the other strategies used by the world’s leading companies and associations.One solution employed by many companies is to more aggressively pursue legal action against violators. In February, for example, Montblanc won a $32 million judgment from a Virginia federal judge in its lawsuit against a website operator that the German luxury goods company accused of violating trademark laws by selling counterfeit Montblanc products.On February 14, Walmart and another retailer were hit with a lawsuit filed in California federal court by Deckers Outdoor, which alleges the companies infringed on its trademark and patent by selling counterfeit versions of its “Bailey Button” boot.Working with trade partners to make them aware of counterfeit and contraband products—and enforcing company trade policies—is also a popular brand protection strategy. For example, investigators for the brand integrity unit at Altria’s Phillip Morris (PM) USA, regularly purchase PM-branded cigarettes from retail stores, online sellers, and “nontraditional” outlets where tobacco products would typically not be sold. Then they determine their authenticity and origin and take action under its contracts and trade policies against wholesalers and retailers found trading in contraband. In some cases, PM USA has filed suit against retailers, illegal importers, and Internet operators found to be trafficking in contraband.Like some other firms, Unilever has found success in tackling counterfeiting through a multifunctional steering group. Experts suggest that tackling counterfeiting is best attempted through a joint security effort that includes asset protection, legal and sales, supply chain, communications, public affairs, research and development, safety and environmental, IT, and marketing. There are also security-specific solutions that companies are using successfully. Some ideas for brand protection strategy:Since counterfeiters are getting increasingly sophisticated, it’s getting harder to determine fake packaging. To help law enforcement distinguish between real and fake, PM USA’s brand integrity team provides it with a quick guide and other collateral materials that point out the differences.True Religion Brand Jeans employed a similar strategy. They developed an anti-counterfeiting “kit,” which includes genuine parts such as button faces, button backs, labels and tags, as well as tips on how to distinguish real True Religion jeans from counterfeits. It then shares kits with local, state, and federal agencies, including the Federal Bureau of Investigation, Immigration and Customs Enforcement, and Customs and Border Protection.One manufacturer/retail brand says that it aggressively fights the illegitimate product trade with lobbying, legal enforcement, and improving visibility and physical security of its supply chain. However, the company also admitted that it didn’t have a good grasp of the problem because it wasn’t capturing reports of counterfeits in a consistent manner. Subsequent solutions have been more effective since they formulated a consistent process for identifying and reporting supply chain breaches and instances of bogus product. Similarly, in an effort to learn more about the enemy they’re fighting, one company established a hotline for customers to call if they think that they’ve been approached or victimized by telemarketers posing as company sales reps.The National Basketball Association has become a truly global brand, one victimized by hard-goods counterfeiters of popular NBA merchandise such as t-shirts, jerseys, basketballs, and hats. In response, they’ve taken standard anti-counterfeiting strategies such as using holograms to identify authentic NBA merchandise. They’ve also worked on creative partnerships with law enforcement. For example, the NBA participates in a task force in New York City that, “with the help of the NYPD, has succeeded in having fines and other penalties imposed on landlords who repeatedly rent their buildings to counterfeiters,” according to the association’s Ayala Deutsch, who heads up its brand protection effort. The NBA and law enforcement secured the penalties by working closely with city officials, who found building code violations at the buildings that harbored networks of intellectual property criminals.New Balance suffers from consumers who knowingly purchase knock-off shoes and those who mistakenly believe they’re buying the real thing when buying a shoe with nearly identical logos. Both actions contribute to the same problem: brand erosion among consumers and retailers. In response, among other measures, the company deployed a full-time team of investigators to constantly monitor Pacific Rim regions known for counterfeit shoemaking and regularly conducts raids on factories and distributors. Additionally, the company supplies its factories with difficult-to-copy labels with an embedded code that are attached to shoes, which can help spot fakes and unauthorized overruns, and it is considering assigning a unique number to every item, which would make it possible to determine where and when every shoe is made. Stay UpdatedGet critical information for loss prevention professionals, security and retail management delivered right to your inbox. Sign up now
December 31st, 2009 Burton has put together a great report called Collaboration and Content Strategies.It’s an interesting look at how enterprises are coming to grips with the Social Networking phenomena. Most companies feel that they are behind the curve in this area and are missing out, but they also have a hard time coming up with the concrete business benefits that they will be able to derive from using it, and adoption is being slowed because of that.The Burton Group report identifies areas that people in their survey cited as areas where Social Networking could help their enterprises improve:– Better connection between people at remote locations– Breaking down barriers between groups– Centralizing knowledge — what do we know?– Assisting in better collaborationAs a result of the study, Burton classified social networking benefits into four groups:Expertise Location:– Finding who knows what– Finding who knows whomCommunity Building– Sharing best practices amont peers– Building relationships with colleaguesRecruitment and Retention– Providing professional support– Mentoring among employees– Attracting new hires, tapping into experience of alumni and retireesKnowledgebase– Knowledge Mangement– Talent Management Leave a Comment Leave a Reply Cancel reply Your email address will not be published. Required fields are marked *Comment Name *E-mail *Website ‹ ECM: Enterprise Search is a Supplement, not a Replacement, for ECM Enterprise Software: Casualty of the Great Recession › Category: Technology
A portion of a foreign corporation’s capital gain on the redemption of its interest in a U.S. limited liability company (LLC), which was treated as a partnership for U.S. income tax purposes, was not taxable for U.S. purposes because it was not U.S.-source income and was not effectively connected with a U.S. trade or business. Regarding the undisputed portion of the gain that the corporation conceded was U.S. taxable income, the corporation was not liable for the accuracy-related penalty or the additions to tax for failure to file a return and failure to pay tax, because it reasonably relied on the erroneous advice of an experienced certified public accountant.The disputed redemption gain was not U.S.-source income under Code Sec. 865(e)(2)(A) because it was not attributable to a U.S. office or other fixed place of business. The partnership’s U.S. office was not a material factor in the production of the foreign corporation’s disputed gain. To be a “material factor,” the partnership’s U.S. office must have been material to the redemption transaction itself and the gain realized from it, not simply a material factor in ongoing, distributive share income from the partnership’s regular business operations. The foreign corporation’s gain was not realized from the partnership’s trade or business of mining magnesite, but from the distinct sale of its partnership interest. Further, the partnership’s actions to increase its overall value were not an essential economic element in the realization of the income that the corporation received upon the sale of its interest. The redemption was a one-time, extraordinary event, not undertaken in the ordinary course of the partnership’s business.The foreign corporation’s gain on the redemption was from the sale or exchange of an indivisible capital asset: i.e., its interest in the partnership. The argument that in this context the corporate partner’s sale of a partnership interest should be treated as the partner’s sale of separate interests in each asset owned by the partnership was rejected.Comment: The Tax Court did not follow Rev. Rul. 91-32, 1991-1 CB 107, which held that the gain realized by a foreign partner upon disposing of its interest in a U.S. partnership should be analyzed asset by asset, and to the extent the assets of the partnership would give rise to effectively connected income if sold by the entity, the departing partner’s pro rata share of such gain should be treated as effectively connected income. The court pointed out that the ruling did not address when an office or other fixed place of business might be a material factor in the production of redemption gain, and did not mention the “ordinary course” prong of the “attributable to” analysis.Further, the foreign corporation was not liable for the Code Sec. 6662 accuracy-related penalty or the additions to tax under Code Sec. 6651(a)(1) and (a)(2) on the undisputed portion of the gain. The corporation’s partnership investment was its only involvement in U.S. business, and its central financial officer did not understand the concept of a partnership for U.S. tax purposes or that the corporation would be subject to tax in the United States on income from real property located there. The corporation relied on the recommendation of its trusted adviser for to hire a tax professional to comply with U.S. tax laws. The CPA that advised the corporation to not report the gain it had realized on the redemption had sufficient credentials to justify the foreign corporation’s reliance. He was a licensed attorney and CPA who had spent nearly 40 years preparing income tax returns, and had accurately prepared the foreign corporation’s returns for several years before the tax years at issue.Grecian Magnesite Mining, Industrial & Shipping Co., SA, 149 TC —, No. 3, Dec. 60,968Other References:Code Sec. 741CCH Reference – 2017FED ¶25,442.1285Code Sec. 864CCH Reference – 2017FED ¶27,189.40Code Sec. 865CCH Reference – 2017FED ¶27,201.30Code Sec. 875CCH Reference – 2017FED ¶27,383.20Code Sec. 6651CCH Reference – 2017FED ¶39,475.41Code Sec. 6662CCH Reference – 2017FED ¶39,651G.115Tax Research ConsultantCCH Reference – TRC PART: 18,402CCH Reference – TRC INTL: 3,452CCH Reference – TRC INTLIN: 3,104CCH Reference – TRC INTLIN: 3,106.15CCH Reference – TRC INTLIN: 3,106.35
For leading artist Paresh Maity, a globalised painter with an eye for diversity of Indian life, ‘identity is very important for any form of art to flourish’.‘I can be removed from my own heritage, but I cannot lose touch with it. Proper globalisation of Indian art is possible only when heritage meets modernity. If there is no root, you are baseless,’ said Maity.The waterscapes of riverine Bengal, the golden light of the Thar and the cosmopolitan colours of the bustling Capital have all come together on the canvas of Maity, who will be honoured with the Dayawati Modi Award for Art, Culture and Education 2012 in the Capital Monday. Also Read – ‘Playing Jojo was emotionally exhausting’The artist says his journey from Midnapore to Kolkata and then to Delhi, Rajasthan and around the world in the last two decades has changed his colour palette, formats of creative expression and returned him closer to his roots in a strange way.Maity is known for his cutting-edge mechanical Western-style installations, bronze sculptures and giant paintings.‘It is always better to know your roots and build your artistic dimensions around it,’ the artist said. ‘You can have a different language, but the content of your art must be from your culture,’ he said. Also Read – Leslie doing new comedy special with NetflixThe 47-year-old artist is making a 12-foot installation of the seven cities of Delhi for the India Art Summit 2013.‘The installation is six feet in diameter. It portrays how the metropolis of Delhi have evolved over the centuries; how the ancient Tughlaqabad was like and it is now. I am using day-to-day material and lot of colours,’ Maity said.The next year will see Maity reconnect to his core oeuvre of water colour once again at the World Art Fair at the Marina Bay Sands in Singapore. ‘The water colours will be large — some almost 7 X 10 sq ft in size. They will be impressions of the places I have visited in the last 20 years. It is difficult to tackle water colour on large surfaces,’ Maity said.An installation of small boats will lend solidity to the minimal landscapes in water colour, he said. Maity, who began as a landscape painter in Bengal, took to the world the muted colours of the river banks with their silent meditative quality of life. There were no figures in his early landscapes — boats, jetties and laden skies lived in perfect harmony with his dark indigo, green, ochre and cobalt spaces.‘When I migrated to Delhi in 1990, I put the city on to my canvas. My art changed after I went to Rajasthan for the first time, figures started appearing in my paintings. The landscape became more colourful with a riot of yellow, gold, orange, red and green. Rajasthan is bathed in a golden light in winter,’ Maity said.In Delhi, Maity’s passion for big surfaces has grown over the years. ‘Initially, I did not have papers, I joined the papers and made bigger watercolours,’ he said.The artist returned to sculpting six years ago. One of his new age installations that made news around the world was an abstract concept, Procession of 50 Ants, made of 100 motorbike spares. It was exhibited at the Art Stage in Singapore in 2011.‘I broke down the machines (bikes) and reassembled them to resemble large ants, nearly five feet in length.’ Why ants? ‘They are very disciplined, very sensitive and intuitive. They live in small colonies and can sniff disasters,’ Maity said. [IANS]