title: 2012 Ukrainian parliamentary election

text: Denys Kovrizhenko of the International Foundation for Electoral Systems – Ukraine stated the sum of money spend could be up to 10 times more than what parties report afterwards. According to OPORA “In general, candidates spend about three times more than they officially report to spend”. Political scientist Artem Bidenko estimated other figures; he believed that the Party of Regions had spent around $850 million, Ukraine – Forward some $150 million, and the election campaigns of the rest of the political parties $350 million, while candidates in majority constituencies had spent some $900 million on the election campaign. About half of the single-constituency candidates submitted reports about their campaign spending.


title: 2012 Ukrainian parliamentary election

text: In October 2008 Ukrainian experts estimated that a small political party who wants to win seats in parliament would spend up to US$30 million on the campaign and large political parties would spend up to $100 million. Political analyst Pavlo Bulhak stated then that a party's election budget will be spent on advertising on television, bribing voters, organizing rallies and party propaganda.


title: 2012 Ukrainian parliamentary election

text: On 8 November the Central Election Commission of Ukraine completed and released all results of the nationwide party list the constituencies (the elections took place on 28 October). Meanwhile, the Central Election Commission refused to establish the election results for the first-past-post results in 5 constituencies.


title: 2012 Ukrainian parliamentary election

text: The Central Election Commission of Ukraine finalized the vote count on 12 November 2012 but simultaneously ordered - on recommendation of the Verkhovna Rada - repeat elections (on a yet unknown date) in five troubled single-mandate constituencies where it could not establish results. Because of occurrences in these five constituencies. Hence, on 12 November 2012 445 deputies had been elected of the 450 seats in parliament. On 8 February 2013 the Supreme Administrative Court of Ukraine deprived 2 more deputies of power. They were banned from parliament on 3 July 2013. On 5 September 2013 the Verkhovna Rada itself set the date of all 7 re-elections to 15 December 2013.


title: 2012 Ukrainian parliamentary election

text: Next to the 87 political parties 1150 independent candidates took part in the 225 electoral districts.


title: 2012 Ukrainian parliamentary election

text: Several lawmakers elected into the new parliament have family ties with other lawmakers or other family members in the executive branch of Ukrainian politics.


title: 2012 Ukrainian parliamentary election

text: The total voter turnout in the election was 57.99%; about average for parliamentary elections in Ukraine. On election day turnout had reached 22.43% by noon local time. The number of reported participating voters varied somewhere between 20.76 million and 20.78 million, while the number of invalid ballots accumulated to about 1.2 million (5.74%) for party list voting and voting at districts.


title: 2012 Ukrainian parliamentary election

text: The lowest turnout was in Crimea (with 49.46%), the highest in Lviv Oblast (67.13%). Local disparities in turnout did occur: for example, the voting turnout figures in two adjacent districts in Donetsk were 39.8% and 84.5%.


title: 2012 Ukrainian parliamentary election

text: On 9 December President Viktor Yanukovych nominated Mykola Azarov for a new term as Prime Minister. This nomination was approved by parliament on 13 December 2012. 252 deputies of the 450 deputies supported the nomination; the whole factions of Party of Regions (210 deputies) and Communist Party (32 deputies) and ten independent deputies.


title: 2012 Ukrainian parliamentary election

text: Fatherland, UDAR and Svoboda stated 12 November they did not recognize the results and will challenge them in local and international courts. In a joint statement the three parties vowed to work towards the impeachment of President Viktor Yanukovych, the resignation of the Azarov Government and chief prosecutor Viktor Pshonka, and the release from jail of Yulia Tymoshenko "and other political prisoners".


title: 2012 Ukrainian parliamentary election

text: Prime Minister Mykola Azarov and President Yanukovych praised the elections; Azarov claimed “neither democratic norms nor legal democratic procedures were in fact violated” and according to Yanukovych the elections "took place well from the technical viewpoint".


title: 2012 Ukrainian parliamentary election

text: Party leader Petro Symonenko of the Communist Party of Ukraine believed on 8 November that the new parliament could not work better than the present one, as "there will be a confrontation between the financial, political and clan groups who got seats in the new parliament." He also stated then that his party will not form any coalition with other groups in the new parliament.


title: 2012 Ukrainian parliamentary election

text: Civil movement "Chesno" stated on 5 December 2012 that 331 out of the 450 deputies elected on 28 October fell short of its criteria for honesty; according to "Chesno"'s parameters, 114 of them violated the rights and freedoms of citizens, 30 earlier changed their political position while working in parliament or on local councils, 233 had been involved in corrupt practices, 185 had nontransparent incomes and expenses, 156 did not personally take part in voting in previous parliaments, and 101 had shirked work in parliament.


title: 2012 Ukrainian parliamentary election

text: Party of Regions politician Sergei Tigipko stated in December 2012 "the parliamentary elections showed that politics in Ukraine is becoming more ideological".


title: 2012 Ukrainian parliamentary election

text: European Union – On 12 November 2012 the High Representative of the Union for Foreign Affairs and Security Policy Catherine Ashton and European Commissioner for Enlargement and European Neighbourhood Policy Stefan Fule stated "We express our concern about the conduct of the post electoral process, which was marred by irregularities, delays in the vote count and lack of transparency in the electoral commissions". The also expected to see "swift and determined action" to bring Ukraine's electoral legislation "into line with European norms and standards on the basis of an Election Code".


title: 2012 Ukrainian parliamentary election

text: On election day (28 October) there were 3,500 accredited foreign observers. The observers from the European Academy for Elections Observation (most of whom where European Parliament members), stated it was "a good election, not perfect but clearly acceptable", and that it was "in compliance with democratic norms". On 29 October the Organization for Security and Co-operation in Europe (OSCE) (who had monitored the election with 600 observers) stated in a preliminary report that "certain aspects of the pre-election period constituted a step backwards compared with recent national elections" and that the election was marred by "the abuse of power and the excessive role of money". It complained of "a lack of a level playing field, caused primarily by the abuse of administrative resources, lack of transparency of campaign and party financing, and lack of balanced media coverage". This contrasted sharply with the international observers' conclusions on Ukraine's February 2010 presidential election, judged then to have been transparent, unbiased and an "impressive display" of democracy.


title: 2012 Ukrainian parliamentary election

text: Ten thousand foreign observers where expected to observe the elections. Some 100 long term observers from OSCE member states arrived in Ukraine starting from the middle of September 2012, followed by 600 short-term observers who will arrive a week before the elections to monitor the election process at voting stations.


title: 2012 Ukrainian parliamentary election

text: Poland is to send observers to Ukraine to monitor the elections, Polish Foreign Minister Radosław Sikorski stated on 8 February 2012. German Ambassador to Ukraine stated "Germany is planning to send a numerous group of official supervisors" on 13 March 2012.


title: 2012 Ukrainian parliamentary election

text: The total number of registered observers on October 9, was 1053 persons. The largest mission of international observers from CIS-EMO was 197 people.


title: 2012 Ukrainian parliamentary election

text: On 2 October 2012 CIS-EMO observers presented the Interim report of the CIS-EMO Election Monitoring Mission. The report, in particular, noted that "The majority of detected violations are connected not with a political struggle of party lists but with the struggle of single-seat candidates". An impression that “antidemocratic power” clash with “democratic opposition” imposed by European and world society has a very relative nature that, as a rule, doesn’t distinct the real situation. In nowadays Ukrainian “peripheral capitalism” model such classes as “power” and “opposition” are conventionality. When the “Power Elite” is unconsolidated and disconnected and there is an open internal war between leading financial-industrial groups and corporations of Ukraine to get leverage of real state authority, all existing political parties only play the role of institutionalized political framework of realization of oligarchs’ economic interests.


title: 2012 Ukrainian parliamentary election

text: On 5 October 2012 the CIS-EMO report was presented at the annual meeting of the OSCE Office for Democratic Institutions and Human Rights. Shortly before the presentation of CIS-EMO interim report web-site of CIS-EMO had been subjected to a massive DDoS-attack. The report was published on the official website of the OSCE in English and Ukrainian and also in Russian.


title: 2012 Ukrainian parliamentary election

text: The ENEMO (European Network of Election Monitoring Organizations) mission for the 2012 parliamentary elections in Ukraine began its work on 23 July 2012 with the arrival of four Core Team members. ENEMO is the first international election observation mission registered for the Parliamentary Elections 2012 by the Central Election Commission (CEC). 35 LTOs (long-term observers) arrived to Kyiv on 5 August 2012 and were deployed throughout Ukraine. Long-term observer teams cover one or two oblasts of Ukraine. On E-day, October 28, ENEMO deployed 43 STO (Short-term observer) teams throughout all oblasts of Ukraine.


title: 2012 Ukrainian parliamentary election

text: According to the amendment to parliamentary regulations adopted in November 2012, the smallest faction of parliament can be formed out a party with the smallest number of deputies elected by a party list and a single constituency vote. That amendment to regulations can also be interpreted as "either or" meaning that the smallest faction can be formed either based on party list or a single constituency election. In that case the smaller parties' deputies that were elected to the parliament will be able to form factions of their own, making it more challenging to form a coalition in the Ukrainian parliament.


title: 2012 Ukrainian parliamentary election

text: On 27 November 2012 Party of Regions parliamentary leader Oleksandr Yefremov claimed that 223 members of the Verkhovna Rada had already expressed their desire to work in his party's fraction; according to earlier press reports 38 of the 43 unaffiliated politicians elected into parliament would join the Party of Regions faction.


title: 2012 Ukrainian parliamentary election

text: Since 8 February 2013 four parliamentarians have been deprived of their mandate by the Higher Administrative Court of Ukraine.


title: 2012 Ukrainian parliamentary election

text: In contrast with the 2007 parliamentary elections, candidates in this election could be elected on party lists or through self-nomination. There were 87 parties registered for the elections to compete in electoral districts. For the nationwide list the voters could choose between 22 parties. Several parties united together under "umbrella" parties. For example, the election list of All-Ukrainian Union "Fatherland" included members of Reforms and Order Party, People's Movement of Ukraine, Front of Changes, For Ukraine, People's Self-Defense, Civil Position and Social Christian Party. This electoral list was the result of negotiations within the opposition Dictatorship Resistance Committee.


title: 2012 Ukrainian parliamentary election

text: The Central Election Commission of Ukraine had registered 22 parties who would participate on the nationwide list. On 15 October 2012 Ukrainian Platform "Assembly" withdrew itself from the national list (it had received ballot number 1) but the other ballot numbers did not change. So the ballot numbers were:


title: 2012 Ukrainian parliamentary election

text: Note that on 17 November 2011 the Ukrainian Parliament approved an election law under which 225 members of Parliament would be elected under party lists and 225 would be winners of constituencies. Simultaneously the option to vote "Against all" had been made defunct; furthermore candidates could be elected on party lists or through self-nomination.


title: Dushyant Chautala

text: Dushyant Singh Chautala (born 3 April 1988) is a Jannayak Janta Party politician and current Deputy Chief Minister of Haryana. He is the president and co-founder of the Jannayak Janata Party. He represents Uchana Kalan constituency in Haryana Legislative Assembly, and was sworn-in as Deputy Chief Minister of Haryana after making an alliance with Bhartiya Janata Party in the 2019 Haryana Legislative Assembly election.


title: Dushyant Chautala

text: He also served as the Member of Parliament in the 16th Lok Sabha representing Hisar Lok Sabha constituency in Haryana. In 2019 MP election he lost his seat to BJP. On 6 October 2020, he was diagnosed with COVID-19 and had to be in home isolation for two weeks.


title: Dushyant Chautala

text: Dushyant Chautala was born in Daroli, Hisar District, Haryana, on 3 April 1988 to Ajay Chautala and Naina Singh Chautala. He is the grandson of Om Prakash Chautala and the great grandson of former Deputy Prime Minister Chaudhary Devi Lal. He has a younger brother, Digvijay Chautala. He comes from one of the political dynasties of Haryana and his family belongs to the Jat community.


title: Dushyant Chautala

text: Dushyant Chautala completed his initial schooling from St. Mary School, Hisar and The Lawrence School, Sanawar, Himachal Pradesh. He completed his B.Sc., (Business Administration) (Management), from California State University, Bakersfield, California, USA. He has done 'Masters of Law' from National Law University, Delhi. He married Meghna Chautala on 18 April 2017.


title: Dushyant Chautala

text: In 2014 Lok Sabha Elections, Dushyant Chautala defeated Kuldeep Bishnoi of the Haryana Janhit Congress (BL) by a margin of 31,847 votes to become the youngest ever elected Member of the Parliament for which he holds a record in the 'Limca Book of Records'. In 2017, Chautala became the first Indian to be conferred with the highest civilian honor by the Cooperation Commission of Arizona, USA.


title: Dushyant Chautala

text: On 9 December 2018, Dushyant Chautala launched the new party Jannayak Janata Party (JJP) after differences in the family led to his expulsion from Indian National Lok Dal.


title: Dushyant Chautala

text: Jannayak Janata Party was formed by supporters of Dushyant Chautala in Jind, Haryana on 9 December 2018. The name of JJP party was inspired from the legacy of former Deputy Prime Minister of India,


title: Dushyant Chautala

text: Dushyant Chautala was in a turf war over leadership of the Indian National Lok Dal (INLD) with his uncle Abhay Chautala. Matters came to a head when Abhay Chautala dissolved the student wing of the INLD, the INSO, which triggered Dushyant to announce the formation of the JJP. Youth employment, senior citizen pension, fair support price for farmers, and women safety are the main issues of JJP.


title: Dushyant Chautala

text: Under the leadership of Dushyant Chautala, Jannayak Janata Party fought its first election for Jind legislative assembly seat by-election. In the Jind by-election, JJP got 37631 votes and secured the second position.


title: Dushyant Chautala

text: Chautala was a Member, Standing Committee on Urban Development, 2014–2016. He was also a Member, Consultative Committee, Ministry of Skill Development and Entrepreneurship, 2015-2018; and a Member, Standing Committee on Commerce, 2016-2019.


title: Dushyant Chautala

text: Chautala holds the position of President, Table Tennis Federation of India. He also is a Member, Executive Council, Indian Olympic Association.


title: Tony Award for Best Actress in a Musical

text: The Tony Award for Best Performance by a Leading Actress in a Musical is awarded to the best actress in a musical, whether a new production or a revival. The award has been given since 1948, but the nominees who did not win have only been publicly announced since 1956.


text: The award was not presented in 1947 or 1985. Ken Mandelbaum wrote about the 1985 season: "Things get bad enough musically to require the elimination of the Best Musical Actor and Actress categories, as well as the choreography prize." There have been three ties in this category, in 1958, 1962 and 1968.


text: In 1965, Liza Minelli, age 19, became the youngest actress to win the award, a record she still holds today. She is followed by Lea Salonga, age 20, in 1991. In 2017, Bette Midler, age 71, became the oldest actress to win the award, a record she still holds today. She is followed by Ruth Brown, age 61, in 1989.


title: WWE 2K14

text: WWE 2K14 is a professional wrestling video game developed by Yuke's and published by 2K Sports for the PlayStation 3 and Xbox 360. It was released on October 29, 2013, in North America, October 30, 2013, in Japan, October 31, 2013, in Australia, and November 1, 2013, in Europe and India. The game's box art features The Rock as the cover athlete.


title: WWE 2K14

text: Succeeding 2012's "WWE '13", "2K14" is the first game in the "WWE 2K" series, and is the first game to be published after Take-Two Interactive gained the license for WWE video games from THQ in a bankruptcy filing. It was also the last video game to use WWE's "scratch" logo that first appeared in the Attitude Era.


title: WWE 2K14

text: "2K14"' is primarily an update of "WWE '13", featuring various changes to modes and mechanics, along with new several features.


title: WWE 2K14

text: Improvements have been made to the navigation system, allowing for more fluid walking, running and dragging motions. Characters also move faster than previously; before running, characters display "starting up" animations, to prevent players from spamming running attacks. All chain reversals now result in offensive attacks, to make for quicker matches by avoiding continuous reversal stalemates. Catapult finishers can now be used offensively. Some characters can launch an opponent into the air and catch them for a catch finisher. Seven new "OMG!" moments have been added, allowing certain finishers to be done on two opponents, and players to interact with the arena environment. The nearfall system has been improved with more two counts. A "Slobberknocker Mode", adapted from "The Streak" season mode, had been added as a gauntlet match.


title: WWE 2K14

text: "Create-a-Superstar" now features expanded character save slots for up to 100 created superstars. The mode also introduces the ability to use existing superstars as a template for new custom variants. "Create-a-Championship" has been expanded after being limited in "WWE '13".


title: WWE 2K14

text: "WWE 2K14" features a single player campaign called "The 30 Years of WrestleMania", which recreates nearly three decades of WWE history. Similar to "WWE '13"'s "Attitude Era mode", "30 Years of WrestleMania" spans 45 matches centered around various characters, alternate gimmicks, and the use of classic WWE footage. The storyline's distinctly follow characters who were involved in memorable WrestleMania matches.


title: WWE 2K14

text: In "Wrestlemania mode", matches have primary objectives that required to completed; and bonus historical objectives to recreate iconic moments. In some cases, the player will follow a guided sequence of inputs, rather than freely control their character. Storylines featured include; "Hulkamania Runs Wild", which focuses on Hulk Hogan in early WrestleMania events; and "The New Generation", showcasing the rise of Bret Hart and Shawn Michaels in the mid-1990s. In addition, the mode's "Attitude Era" chapter brings back storylines featured in "WWE '13"s "Attitude Era" mode alongside new storylines. The "Ruthless Aggression" chapter focuses on the departure of The Rock, lessened focus on Triple H and rise of John Cena. The final "Universe Era" chapter focuses on the rise of Randy Orton and the returns of The Rock and Brock Lesnar.


title: WWE 2K14

text: The game has a mode that focuses on The Undertaker's WrestleMania winning streak of 21 matches at the time of the game's release. As The Undertaker, the player can either battle waves of opponents attempting to break the streak. The player can also select any character and challenge The Undertaker at WrestleMania themselves. The difficulty level is higher than in any previous "WWE" game. The Undertaker can chokeslam the player if grappled at the head; submit the player with the Hell's Gate when The Undertaker is grounded; and can appear once behind the player, in an animation previously used for if the Undertaker interferes in a match, if he has a finisher stored.


title: WWE 2K14

text: "WWE Universe" is overhauled, carrying over features from previous games, while introducing new features of its own. The player can customize existing WWE Shows, bring back retired series, or create their own original shows. They can choose the superstars participating on these shows and the titles featured on them. The ability to choose the status of a WWE Superstar, whether assigned to one show, several, a legend or a free agent is also available.


title: WWE 2K14

text: A new feature introduced is the Rivalry Manager. Corroborating with an updated statistics tracker, "Rivalry Manager" can track all rivalries as well divide storylines into periods based on dates, during which period the rivalry will continue depending on in-ring decisions. Previous "Universe" storylines from earlier games have been revamped to use the "Rivalry Manager".


title: WWE 2K14

text: Casey Collins, WWE Executive Vice President of Consumer Products, revealed on June 4 at the WWE Global Business Partner Summit, that The Rock would be featured on the cover of "WWE 2K14". The official cover and trailer were revealed on the June 24 episode of "WWE Raw".


title: WWE 2K14

text: In July, The Ultimate Warrior was announced as a pre-order exclusive playable character. On August 1, 2K Games announced a special "Phenom Edition" which included Undertaker-themed extras, including the "American Badass" gimmick as a playable character.


title: WWE 2K14

text: "WWE 2K14" received positive reviews, with the Xbox 360 version receiving "generally favorable" reviews", while the PS3 version received "average" reviews from critics, according to review aggregator Metacritic which gave the Xbox 360 version a score of 75/100 based on 42 reviews and the PlayStation 3 version a score of 74/100 based on 21 reviews.


title: WWE 2K14

text: IGN gave the game an 8.7 out of 10 saying ""It still lacks the brains to deliver competent AI and commentators, but WWE 2K14 has more than enough brawn to make up for it. 30 Years of Wrestlemania provides the strongest campaign backbone the series has had in a long time, the in-ring action is faster and more fluid than it's been in years, and thanks to WWE 2K14's continually expanding creation suite, we're swimming in more options than we ever knew we wanted. It is indeed "time to play the game"". GameSpot rated the game a 6 out of 10, saying that the game was clunky, ""It's a shame the wrestling isn't up to par in WWE 2K14 because the elements surrounding it are so interesting... For anyone who grew up loving professional wrestling, be prepared to be swept away in a tide of nostalgia. If only the core action could have been as compelling.""


title: Apollo Automobil

text: Apollo Automobil (previously known as Gumpert Sportwagenmanufaktur) is a German sports car manufacturer headquartered in Denkendorf. Roland Gumpert, who founded Gumpert Sportwagenmanufaktur in 2004, once held the position of director of Audi Sport. Under his management, Audi won a total of 25 World Rally Championship rallies and four World Rally Championship titles.


title: Apollo Automobil

text: In 2001, Roland Gumpert proposed a new generation of sports car, one that would be race-ready yet also street-legal. After Gumpert returned to Germany from China at the end of 2001, his former colleague at Audi and founder of Motoren Technik Mayer, Roland Meyer, asked him to assist in building a prototype sports car. Audi approved Gumpert's involvement in this project on the condition that the new sports car would be a series product and not a prototype.


title: Apollo Automobil

text: Altenburg GmbH". The technical guidelines were defined and the first designs of the car were drawn by Marco Vanetta. Upon Vanetta's completion of this process, the first 1:4 scale model of Gumpert's car was produced in 2002.


title: Apollo Automobil

text: Gumpert continued with the development of the car now called the Apollo, along with the Technical University of Munich and the Ingolstadt University of Applied Sciences. They assisted him with the construction work, computer simulations, and wind tunnel tests. This research and development helped form the blueprint for the first full-scale model. Finally two prototype cars were constructed. The production of the Apollo started in October 2005. Many variants of the Apollo were introduced throughout its production cycle.


title: Apollo Automobil

text: On July 27, 2008, an Apollo Sport was featured on the UK automotive show "Top Gear". One of the presenters, Richard Hammond and professional driver the Stig drove the car. With a lap time of 1:17.1, the Apollo Sport became the new leader on the Power Lap Board, 0.2 seconds faster than the former lap leader, the Ascari A10. The Apollo was faster than the Bugatti Veyron and the Pagani Zonda around the "Top Gear" test track. It was later beaten with a time of 01:16.8 by the Bugatti Veyron Super Sport.


title: Apollo Automobil

text: In 2011, the company introduced a concept car in collaboration with Carrozzeria Touring Superleggera, the Gumpert Tornante. The car was not put into production.


title: Apollo Automobil

text: In August 2013, the company filed for bankruptcy and went into liquidation after an anonymous backer pulled out of a deal that could have saved the company.


title: Apollo Automobil

text: In January 2016, the company was purchased by Hong Kong consortium Ideal Team Venture which is also owner of the De Tomaso marque. The company was renamed Apollo Automobil GmbH after the acquisition by its new owner.


title: Apollo Automobil

text: At the March 2016 Geneva Motor Show, Apollo unveiled the Arrow, a sports car that is powered by a twin-turbocharged 4.0-litre V8 engine rated at . The Arrow can accelerate from 0–100 km/h (62 mph) in 2.9 seconds, and has a projected top speed of .


title: Apollo Automobil

text: In November 2016, the company announced that former owner and founder Roland Gumpert was no longer associated with the company or its current or future projects and also announced a new model (project name ‘Titan’) would be unveiled at the June 2017 Goodwood Festival of Speed. The new model is named Intensa Emozione (Intense Emotion in Italian) and is powered by the 6.3 L naturally-aspirated V12 engine. The car has radical styling inspired by insects in nature. The Intensa Emozione is built in collaboration with HWA AG, the same company involved in the construction of the Mercedes-Benz CLK-GTR.


title: Apollo Automobil

text: During April 2005, the Apollo made its racing debut in the Divinol Cup. This Apollo was driven by the Belgian race driver Ruben Maes. Maes finished third on the Hockenheimring race track. Three years later Gumpert announced that they would enter a hybrid electric version of the Apollo in the 2008 24 Hours Nürburgring, driven by 2004 winner Dirk Müller and former Formula One racer Heinz-Harald Frentzen. Three months passed between the first discussions and the finished hybrid Apollo. The Apollo was driven in the 24 Hours Nürburgring in May 2008. The hybrid Apollo can deliver up to , powered with a 3.3 litre V8 bi-turbo engine coupled with a electric motor. The car has the ability to recharge the battery under braking.


title: Bad faith (existentialism)

text: In the philosophy of existentialism, bad faith ("mauvaise foi") is the psychological phenomenon whereby individuals act inauthentically, by yielding to the external pressures of society to adopt false values and disown their innate freedom as sentient human beings. Bad faith also derives from the related concepts of self-deception and "ressentiment".


title: Bad faith (existentialism)

text: A critical claim in existentialist thought is that individuals are always free to make choices and guide their lives towards their own chosen goal or "project". This claim suggests that individuals cannot escape this freedom, even in overwhelming circumstances. For instance, even an empire's colonized victims possess choices: to submit to rule, to negotiate, to commit suicide, to resist nonviolently, or to counter-attack.


title: Bad faith (existentialism)

text: Although external circumstances may limit individuals (this limitation from the outside is called facticity), they cannot force a person to follow one of the remaining courses over another. In this sense the individual still has some freedom of choice. For this reason, an individual may choose in "anguish," fully aware that this will have consequences. For Sartre, to claim that one amongst many conscious possibilities takes undeniable precedence (for instance, "I cannot risk my life, because I must support my family") is to assume the role of an object in the world, not a free agent, but merely at the mercy of circumstance (a "being-in-itself" that is only its own facticity, i.e., it "is" inside itself, and acts there as a limitation). For Sartre, this attitude is manifestly self-deceiving.


title: Bad faith (existentialism)

text: According to this philosophy, humans are always aware that they are more than what they are aware of. In other words, they are not whatever they are aware of. In this sense, humans cannot be defined as "intentional objects" of consciousness that includes the restrictions imposed by facticity, personal history, character, bodies, or objective responsibility. Thus, as Sartre often repeated, "Human reality is what it is not, and it is not what it is." An example of what he means is being a doctor but wishing to "transcend" that to become a pig farmer. One is who one is not: a pig farmer, not who one is, a doctor.


title: Bad faith (existentialism)

text: One can only define oneself negatively, as "what it is not", and this negation is the only positive definition of "what it is."


title: Bad faith (existentialism)

text: From this we are aware of a host of alternative reactions to our freedom to choose an objective situation, since no situation can dictate a single response. We pretend that these possibilities are denied to us by assuming social roles and value systems external to this nature . But this is itself a decision made possible by our freedom and our separation from these things.


title: Bad faith (existentialism)

text: Sartre cites a café waiter, whose movements and conversation are a little too "waiter-esque". His voice oozes with an eagerness to please; he carries food rigidly and ostentatiously; "his movement is quick and forward, a little too precise, a little too rapid". His exaggerated behaviour illustrates that he is play-acting as a waiter, as an object in the world: an automaton whose essence is to be a waiter. But that he is obviously acting believes that he is aware that he is not (merely) a waiter, but is rather consciously deceiving himself.


title: Bad faith (existentialism)

text: Another of Sartre's examples involves a young woman on a first date. She ignores the obvious sexual implications of her date's compliments to her physical appearance, but accepts them instead as words directed at her as a human consciousness. As he takes her hand, she lets it rest indifferently in his, "neither consenting nor resisting – a thing" – refusing either to return the gesture or to rebuke it. Thus she delays the moment when she must choose either to acknowledge and reject his advances, or consent to them. She conveniently considers her hand only a thing in the world, and his compliments as unrelated to her body, playing on her dual human reality as a physical being, and as a consciousness separate and free from this physicality.


title: Bad faith (existentialism)

text: Sartre suggests that by acting in bad faith the waiter and the woman are denying their own freedom, by using their freedom to do so. They manifestly know they are free, but are actively choosing not to acknowledge it. Bad faith is paradoxical in this regard: when acting in bad faith, a person is actively denying their own freedom, while relying on it to perform the denial.


title: Bad faith (existentialism)

text: De Beauvoir described three main types of women acting in bad faith: the "Narcissist" who denies her freedom by construing herself as a desirable object; the "Mystic", who invests her freedom in an absolute; and the "Woman in Love", who submerges her identity in that of her male object.


title: Bad faith (existentialism)

text: She also considered what she called the "Serious Man", who subordinated himself to some outside cause, to be in bad faith inasmuch as he denies his own freedom.


title: Bad faith (existentialism)

text: Sartre claims that the consciousness with which we generally consider our surroundings is different from our reflecting on this consciousness, i.e., the consciousness of "ourselves being conscious of these surroundings". The first kind of consciousness, before we think about, or reflect on, our previous consciousness, is called "pre-reflective". Reflecting on the pre-reflective consciousness is called "reflective" consciousness. But this cannot be called unconsciousness, as Freud used the term. Sartre gives the example of running after a bus: one does not become conscious of "one's running after the bus" until one has ceased to run after it, because until then one's consciousness is focused on the bus itself, and not one's chasing it.


title: Bad faith (existentialism)

text: In this sense consciousness always entails being self-aware ("being for-itself"). Since for Sartre consciousness also entails a consciousness of our separation from the world, and hence freedom, we are also always aware of this. But we can manipulate these two levels of consciousness, so that our reflective consciousness interprets the factual limits of our objective situation as insurmountable, whilst our pre-reflective consciousness remains aware of alternatives.


title: Bad faith (existentialism)

text: One convinces oneself, in some sense, to be bound to act by external circumstance, in order to escape the anguish of freedom. Sartre says that people are "condemned to be free": whether they adopt an "objective" moral system to do this choosing for them, or follow only their pragmatic concerns, they cannot help but be aware that they are not – fundamentally – part of them. Moreover, as possible intentional objects of one's consciousness, one is fundamentally "not" part of oneself, but rather exactly what one, as consciousness, defines oneself in opposition to; along with everything else one could be conscious of.


title: Bad faith (existentialism)

text: Fundamentally, Sartre believes humankind cannot escape responsibility by adopting an external moral system, as the adoption of such is in itself a choice that we endorse, implicitly or explicitly, for which we must take full responsibility. Sartre argues that one cannot escape this responsibility, as each attempt to part one's self from the freedom of choice is in itself a demonstration of choice, and choice is dependent on a person's wills and desires. He states "I am responsible for my very desire of fleeing responsibilities."


title: Bad faith (existentialism)

text: As a human, one cannot claim one's actions are determined by external forces; this is the core statement of existentialism. One is "condemned" to this eternal freedom; human beings exist before the definition of human identity exists. One cannot define oneself as a thing in the world, as one has the freedom to be otherwise. One is not "a philosopher", as at some point one must/will cease the activities that define the self as "a philosopher". Any role that one might adopt does not define one as there is an eventual end to one's adoption of the role; i.e. other roles will be assigned to us, "a chef", "a mother". The self is not constant, it cannot be a thing in the world. Though one cannot assign a positive value to definitions that may apply to oneself, one remains able to say what one is not.


title: Bad faith (existentialism)

text: This inner anguish over moral uncertainty is a central underlying theme in existentialism, as the anguish demonstrates a personal feeling of responsibility over the choices one makes throughout life. Without an emphasis on personal choice, one may make use of an external moral system as a tool to moralize otherwise immoral acts, leading to negation of the self. According to existentialism, dedicated professionals of their respective moral codes – priests interpreting sacred scriptures, lawyers interpreting the Constitution, doctors interpreting the Hippocratic oath – should, instead of divesting the self of responsibility in the discharge of their duties, be aware of their own significance in the process. This recognition involves the questioning of the morality of all choices, taking responsibility for the consequences of one's own choice and, therefore, a constant reappraisal of one's own and others' ever-changing humanity. One must not exercise bad faith by denying the self's freedom of choice and accountability. Taking on the burden of personal accountability in all situations is an intimidating proposition – by pointing out the freedom of the individual, Sartre seeks to demonstrate that the social roles and moral systems we adopt protect us from being morally accountable for our actions.


title: Inquilab Zindabad

text: Inquilab Zindabad (; ) is a Hindustani phrase, which translates to "Long live the revolution". It is a slogan used by revolutionary Indians before independence.


title: Inquilab Zindabad

text: This slogan was coined by the Islamic scholar, Urdu poet, Indian freedom fighter and a prominent communist leader Maulana Hasrat Mohani in 1921.


title: Inquilab Zindabad

text: It was popularized by Bhagat Singh (1907–1931) during the late 1920s through his speeches and writings. It was also the official slogan of the


title: Inquilab Zindabad

text: Hindustan Socialist Republican Association, and the slogan of Communist Consolidation as well as a slogan of the All India Azad Muslim Conference.


title: Inquilab Zindabad

text: In April 1929, this slogan was raised by Bhagat Singh and his associate B. K. Dutt who had shouted this after bombing the Central Legislative Assembly in Delhi.


title: Inquilab Zindabad

text: Later, for the first time in an open court, this slogan was raised in June 1929 as part of their at the High Court in Delhi.


title: Inquilab Zindabad

text: Since then, it became one of the rallying cries of the Indian independence movement. In Indian political novels chronicling the independence movement, a pro-independence sentiment is often characterized by characters shouting this slogan.


title: Ostalgie

text: In German culture, Ostalgie () is nostalgia for aspects of life in Communist East Germany. It is a portmanteau of the German words "Ost" (east) and "Nostalgie" (nostalgia). Its anglicised equivalent, ostalgia (rhyming with "nostalgia"), is also sometimes used. Another term for the phenomenon is GDR nostalgia ()


title: Ostalgie

text: Social scientist Thomas Ahbe argues that the term ‘ostalgia’ is often misunderstood as a lack of willingness to integrate, an uproar to reverse German reunification and reinstate the GDR. However, Ostalgia is rather an integration strategy used by East Germans who wanted to retain their own original experiences, memories and values incompatible with those of the West German majority.


title: Ostalgie

text: As with other cases of Communist nostalgia, there are various motivations, whether ideology, nationalism, wistfulness for a lost sense of social status or stability, or even aesthetics or irony.


title: Ostalgie

text: Ostalgie is a complex term that should not be described as a simple emotion of nostalgia. As Ostalgie relates back to the history of the Cold War, it is better to examine this term in the context of history and current influence in Western society; in doing so, the meaning of this term becomes clearer.


title: Ostalgie

text: The division of Germany into East and West for over 35 years engendered the formation of distinct identities between the two regions. Despite their shared language and history, the capitalist FRG and socialist GDR differed in many obvious political, economic and cultural respects; thus, their respective societies cultivated cultural identities distinct to each region. These pre-existing differences were then exposed during and after the reunification process.


title: Ostalgie

text: After the fall of the Berlin Wall in 1989 and the following German reunification a year later, many of the symbols of the German Democratic Republic were swept away. The process of unification gave rise to feelings of resentment and nostalgia amongst former GDR citizens. They felt short-changed by a unification process which they equated to a colonial take over. One particular focus of Ostalgie centred around unemployment. Officially, unemployment had not existed in the GDR, but this employment security disappeared with reunification and unemployment became endemic at around 20% of the workforce. The social security provided by the work place in the GDR was a great focus of Ostalgia. Kolinsky presents reunification as characterised by Easterners' disaffection. The mass experience of unemployment emerged as a key tenet of a re-forged East German identity based on the collective experience of employment-loss and the perceived economic destruction of their region. Subsequently, many constructed a retrospective image of the GDR as a stable and caring environment. Unification was felt to have been to their disadvantage and to have isolated them as second-class citizens.


title: Ostalgie

text: Reunification presented a particular challenge to women. This was particularly true for working women who had enjoyed organised healthcare and equal pay in the GDR and who faced the greatest unemployment post-Wende. Approximately 70% of East German women lost their job after 1990. Women were laid off faster than men, as well as suffering the consequences of the collapse of state-run childcare facilities and traditional ideals of female domesticity and consumerism were reinvoked, having been challenged by the state in the GDR.


title: Ostalgie

text: Ostalgie was also felt for commodities of the GDR. Almost all GDR brands of products disappeared from the stores and were replaced by Western products. However, after some time many Eastern Germans began to miss certain aspects of their former lives (like culture or the known brand marks). "Ostalgie" particularly refers to the nostalgia for aspects of regular daily life and culture in the former GDR, which disappeared after reunification.


title: Ostalgie

text: Ostalgie is expressed in present day Germany through commodities and products reminiscent of the East-German era.


title: Ostalgie

text: Many businesses in Germany cater to those who feel "Ostalgie" and have begun providing them with artifacts that remind them of life under the GDR; artifacts that imitate the old ones. Available again are brands of East German food, old state television programmes on video tape and DVD, and the once widespread Wartburg and Trabant cars.


title: Ostalgie

text: Another example of commercially memorialising East Germany would be the musealization of Halle-Neustadt. Halle-Neustadt, a city constructed by the East German Government, is now a kind of living museum for East German memory. But more than the meaning of living museum, tourism in Halle-Neustadt is evidence of commercialisation of Ostalgie. In this case, musealization of Ostalgie is somehow connected with a consumerist attitude. Ostalgie in this sense is not a realistic or pragmatic term. It is the artifacts, rather than the social life of East Germany, that play the main role in this commercialization. If the social life of East Germany is more complex than artifacts and symbols, it would be fair to say that musealization of Ostalgie in Halle-Neustadt creates a stereotype of East German life. That is to say, reflection of Ostalgie in Halle-Neustadt should not be considered as an accurate representation of East Germany.


title: Ostalgie

text: Those seeking the preservation of East German culture banded together to save the "Eastern Crosswalk Man" (Ost-Ampelmännchen), an illuminated depiction of a man wearing a "perky", "cheerful" and potentially "petit bourgeois" hat (inspired by a summer photo of Erich Honecker in a straw hat) in crosswalk lights. Many German cities in and near the former East German border, including Berlin, Lübeck and Erfurt, still retain the use of the "Ampelmännchen" at all or some pedestrian crossings due to its cultural relevance, and many souvenirs sold in the new states and in Berlin make use of the icon.


title: Ostalgie

text: Life in the GDR has also been the subject of several films, including Leander Haußmann's "Sonnenallee" (1999), Wolfgang Becker's internationally successful "Good Bye, Lenin!" (2003), and Carsten Fiebeler's "Kleinruppin forever" (2004).


title: Ostalgie

text: Ostalgie could be inspired by the longing of the "Ossis" (German for "Easterners", a term for former GDR citizens) for the social system and the sense of community of the GDR. When "Der Spiegel" asked former GDR-inhabitants whether the GDR "had more good sides than bad sides" in 2009, 57% of them answered yes. To the statement of the interviewing journalist that "GDR inhabitants did not have the freedom to travel wherever they wanted", respondents replied that "present-day low-wage workers do not have that freedom either".


title: Ostalgie

text: According to Dominic Boyer, the concept of nostalgia has been described for several centuries. Nostalgia is connected with nationalism; longing for the former homeland generates love for everything associated with it. This evokes negative feelings toward "foreign" products, customs or cultural influences. Boyer says that "ostalgie" is more than East German nostalgia, examining nostalgia in the context of the Second World War and "Vergangenheitsbelastung" ("the burden of the past"). The division of East and West Germany was not punishment for Germany's war crimes. Nazi Germany has made the German postwar generation shameful and anxious about its past. West and East Germany claimed that the other side was more "German", and more responsible for war crimes; this created a symbiotic relationship, which was eliminated by German reunification.


title: Ostalgie

text: According to Boyer, West German opinion dominates the discourse about the West-East relationship and refuses to take the opinions of former East German members seriously. Boyer writes that "ostalgie" has created a "no-place" East Germany, which is only "realistic" from a West German perspective. The East German perspective (despite its individual history, policy, structure, way of life, and outlook) is invalid, and unable to challenge the "Western" image of East Germany. Enns Anthony wrote that understanding "ostalgie" should go "beyond the simple question of whose representation of the GDR is more valid or authentic"; what matters is the situation of former residents of the GDR.


title: The Nice

text: The Nice were an English progressive rock band active in the late 1960s. They blended rock, jazz and classical music and were keyboardist Keith Emerson's first commercially successful band.


title: The Nice

text: The group was formed in 1967 by Emerson, Lee Jackson, David O'List and Ian Hague to back soul singer P. P. Arnold. After replacing Hague with Brian Davison, the group set out on their own, quickly developing a strong live following. The group's stage performances featured Emerson's Hammond organ showmanship and abuse of the instrument. Their compositions included radical rearrangements of classical music themes and Bob Dylan songs.


title: The Nice

text: The band achieved commercial success with an instrumental rearrangement of Leonard Bernstein's "America", following which O'List left the group. The remaining members carried on as a trio, releasing several albums, before Emerson decided to leave the band in early 1970 in order to form Emerson, Lake & Palmer. The group briefly reformed in 2002 for a series of concerts.


title: The Nice

text: The Nice evolved from Gary Farr and the T-Bones, which keyboardist Keith Emerson and bassist Keith "Lee" Jackson were both members of before the band dissolved in early 1967. Emerson then briefly played with the VIPs, who toured the Star-Club in Hamburg, and his playing style became influenced by the organist Don Shinn, including standing up to play the instrument and rocking it on stage. Meanwhile, P. P. Arnold, a performer who reached a higher level of popularity in the UK than her native US, was unhappy with her backing band, the Blue Jays, and wanted a replacement. Her driver suggested Emerson would be able to put together such a group. Emerson agreed, but only on the condition the band could perform on their own as a warm-up act. Since it effectively meant getting two bands for the price of one, manager Andrew Loog Oldham readily agreed. Emerson recruited Jackson, drummer Ian Hague and ex-The Attack guitarist David O'List, the latter by recommendation from journalist Chris Welch. The name came from Arnold saying, "Here comes the Naz", which the group misheard as "the Nice".


title: The Nice

text: The band played its first gig in May 1967, and had its first major break at the 7th National Jazz and Blues Festival in Windsor on 13 August. Oldham had managed to secure a separate set for the group in a side tent away from also accompanying Arnold on the main stage, where they gained attention. The next week, Welch wrote in the "Melody Maker" that "it was the first time I had seen a group actually in the act of winning its first following in quite dramatic circumstances". When Arnold went back to her family in the US shortly afterwards, Oldham offered the group a contract of their own. Hague was not interested in the "progressive" direction the group wanted to go in, so he was replaced by former Mark Leeman Five and Habits drummer Brian Davison.


title: The Nice

text: Now a band in their own right, the Nice expanded their gear, recruiting roadies Bazz Ward and Lemmy, the latter of whom provided Emerson with a Hitler Youth ceremonial dagger to stick into the keys on his Hammond organ. They spent the end of 1967 on a package tour with Jimi Hendrix, Pink Floyd, the Move and Amen Corner. Pink Floyd's then leader, Syd Barrett, missed several gigs and O'List had to stand in for him. The group's first album was recorded throughout the autumn of 1967, and in October of that year they recorded their first session for John Peel's radio show "Top Gear". The album included classical and jazz influences including extracts from Leoš Janáček's "Sinfonietta" and a rearrangement of Dave Brubeck's "Blue Rondo a la Turk" renamed as "Rondo", changing the time signature from the original 9/8 to 4/4 in the process. The group clashed with producer Oldham in the studio over the length of the track, but eventually won the argument; the full eight-minute piece was included on the album. After the album was released, the group realised that Oldham had a conflict of interest as manager and record company owner, so they recruited sports journalist Tony Stratton-Smith to take over management duties.


title: The Nice

text: For their second single, the Nice created an arrangement of Leonard Bernstein's "America" which Emerson described as the first ever instrumental protest song. The track used the main theme of the Bernstein piece (from "West Side Story") but also included fragments of Dvořák's "New World Symphony". The single concludes with Arnold's three-year-old son speaking the lines "America is pregnant with promise and anticipation, but is murdered by the hand of the inevitable." The new arrangement was released under the title "America (Second Amendment)" as a pointed reference to the US Bill of Rights provision for the right to bear arms. In July 1968, Immediate Records publicised the single with a controversial poster picturing the group members with small boys on their knees, with superimposed images of the faces of John F. Kennedy, Robert F. Kennedy and Martin Luther King Jr. on the children's heads. A spokesman for the band said: "Several record stores have refused to stock our current single ... the Nice feel if the posters are issued in United States they will do considerable harm". During the tour that followed the release of their second album in July, the group spawned controversy when Emerson burned an American flag onstage during a performance of "America" at a charity event, "Come Back Africa" in London's Royal Albert Hall. The group were subsequently banned from ever playing the venue again.


title: The Nice

text: By summer 1968, the group had become concerned about O'List's reliability and matters came to a head following a gig in Croydon's Fairfield Hall in September. According to Ward, O'List had an altercation with him in mid-performance. Emerson subsequently called a band meeting with Jackson and Davison and stated flatly that O'List should be sacked. They agreed, and immediately after their performance at The Ritz, Bournemouth in October, he was fired by Stratton-Smith with the rest of the band present. O'List, however, claims that he left the band voluntarily because he was upset at Stratton-Smith's decision to make Emerson the front man, saying: "I left the band and waited for Keith to get in contact... I should have gone straight to Keith, but I didn't."


title: The Nice

text: The Nice briefly considered looking for a replacement, with Steve Howe trying out at an audition. Howe got on well with the rest of the band, but a week later had second thoughts and decided not to join. Emerson tried to learn guitar so he could cover some of O'List's old parts, but gave up after one gig.


title: The Nice

text: The band's second LP "Ars Longa Vita Brevis" featured an arrangement of the Intermezzo from the "Karelia Suite" by Jean Sibelius, which the band's friend Roy Harper had recommended they cover, and the album's second side was a suite which included an arrangement of a movement from J.S. Bach's Brandenburg Concerto No. 3. The group used an orchestra for the first time on some parts of the suite. The band were on the bill at the 1969 Isle of Wight Festival and briefly toured Ireland with Yes and Bonzo Dog Doo-Dah Band which, by all accounts, was fraught with logistical problems.


title: The Nice

text: The third album, titled "Nice" in the UK and "Everything As Nice As Mother Makes It" in the US, featured one side recorded live on their American tour and one side of studio material. As with previous albums, it included arrangements of classical material, in this case the Third Movement of Tchaikovsky's Sixth Symphony ("Pathetique"), and rearrangements of Bob Dylan's "She Belongs to Me" and Tim Hardin's "Hang on to a Dream".


title: The Nice

text: In 1969, the band found time to contribute to other projects. Emerson performed as a session player for Rod Stewart and the Faces, while the whole group provided instrumental backing for the track "Hell's Angels" on Roy Harper's 1970 album "Flat Baroque and Berserk". Mid-year, tour promoter Michael Emmerson asked the Nice to write some music for the Newcastle upon Tyne Arts Festival. The result was the "Five Bridges" suite. The group premièred the piece on 10 October 1969 at Newcastle City Hall. A complete version with an orchestra was performed at the Fairfield Hall, Croydon on 17 October, which was recorded for the album of the same name. The title refers to the city's five bridges spanning the River Tyne, and Jackson's lyrics refer to his Newcastle childhood and the St James' Park football ground.


title: The Nice

text: By late 1969, Emerson thought the Nice had progressed as far as it could musically, and was particularly dissatisfied with Jackson's limited vocal style. He asked Jack Bruce and Yes' Chris Squire about forming a new band, but both turned Emerson down. While on tour in the US with King Crimson, Emerson held a meeting with Stratton-Smith and declared "the Nice had outlived its usefulness". By the end of the year, Emerson and Crimson's Greg Lake had decided to form a band together. The group carried on touring into 1970, but sometime early in the year, Emerson told Jackson that he would be leaving the band. Matters were not helped by Immediate Records filing for bankruptcy; the band later said they received no royalties from the label while an active group.


title: The Nice

text: In February 1970, the group collaborated with the Los Angeles Philharmonic Orchestra led by Zubin Mehta. This was broadcast in the following month as part of the "Switched-On Symphony" program. Following standard television procedure of the day, the Nice's contribution (a version of "America") was recorded ahead of time and the band mimed for the cameras.


title: The Nice

text: By March, the group had confirmed they would split, and a report on the band's decision was printed in "Melody Maker". The group played their last British concert on 22 March at the Fairfield Hall, Croydon, and after a short German tour the band broke up, playing their last gig on 30 March at the Berlin Sportpalast.


title: The Nice

text: Emerson and Lake recruited Carl Palmer from Atomic Rooster and formed Emerson, Lake & Palmer (ELP). In 1971, the posthumous Nice album "Elegy" was released. It included different versions of previously released tracks, two being studio versions and two live from the 1969 US tour. Emerson had no involvement with compiling the album, which was done by Jackson, Davison and Charisma Records. The album reached No. 5 in the UK.


title: The Nice

text: Jackson formed Jackson Heights which released five albums between 1970 and 1973. Emerson supported the band and became a fan. Davison formed "Every Which Way" which released an album in 1970. Both Jackson and Davison formed Refugee with keyboardist Patrick Moraz in 1974, but Moraz left the group after one album to replace Rick Wakeman in Yes.


title: The Nice

text: After over three decades of inactivity, the Nice reformed in 2002 for a series of concerts. A three-CD set "Vivacitas" was released, with the third CD being an interview with Emerson, Jackson and Davison. O'List did not attend the reunion and was replaced by guitarist Phil Hilbourne. Davison died on 15 April 2008 aged 65 in Horns Cross, Devon, from a brain tumour. Emerson died on 11 March 2016 in Santa Monica, California, of a self-inflicted gunshot wound to the head.


title: The Nice

text: The Nice were primarily a live band. Their stage performances were bold and violent, with Emerson incorporating feedback and distortion. He manhandled his Hammond L-100 organ, wrestling it and attacking it with daggers (which he used to hold down keys and sustain notes during these escapades). Emerson's playing was inspired by Jimi Hendrix, Billy Ritchie of Clouds, and Don Shinn as well as earlier figures such as pianist Jerry Lee Lewis.


title: The Nice

text: The group's early sound was geared more towards psychedelic rock with only occasional classical influences. Following O'List's departure, Emerson's control over the band's direction became greater, resulting in more complex music. The absence of a guitar in the band and Emerson's redefining of the role of keyboard instruments in rock set the Nice apart from many of its contemporaries. He used a combination of Marshall Amplification and Leslie speakers in order to project a full sound to compensate for the lack of a guitarist.


title: The Nice

text: Jackson never considered himself a great singer, partly because the group chose poor keys for his vocal range, but his bass playing, with heavy use of a plectrum, was a distinctive part of the band's overall sound. He was influenced by Bob Dylan, whose songs were often covered at the time; the Nice interpreted several of them, typically reducing them to three or four verses and featuring a long improvised middle section, such as "She Belongs to Me".


title: The Nice

text: Though noted in rock history primarily as the band which brought Keith Emerson into the spotlight, the Nice were one of the pioneering progressive rock bands and their fusion of styles strongly influenced the movement into the 1970s. Their commercial success on Charisma Records was key to establishing the label, which went on to include several other progressive acts, including Genesis and Van der Graaf Generator. Genesis were fans of the Nice and "The Knife" from their album "Trespass" was directly inspired by the band. Though the Nice were not the first to combine a rock band and orchestra, they did inspire similar attempts by other groups, such as Pink Floyd's "Atom Heart Mother".


title: The Nice

text: The group have often been compared to ELP, but there were important differences between them. Emerson's showmanship was more important in the Nice, and he mostly used just a Hammond organ live as opposed to a wider range of keyboards, including the Moog synthesizer, in ELP. John Peel, an early champion of the Nice, called ELP "a waste of talent and electricity".


title: Ghost Story Games

text: Ghost Story Games, LLC is an American video game developer based in Westwood, Massachusetts, and led by Ken Levine. The studio is the rebranding of Irrational Games as announced in February 2017, and while still the same business subsidiary under Take-Two Interactive, the rebranding was considered a fresh start by the founders as they move into more emergent narrative-driven titles compared to the larger titles they had made under Irrational.


title: Ghost Story Games

text: Irrational Games had a history of several successful titles, including "BioShock" and "BioShock Infinite", both helmed by Levine. Levine expressed how much stress completing a large title was at the conclusion of work of "BioShock Infinite", and decided that he would drastically trim down the studio "to refocus my energy on a smaller team with a flatter structure and a more direct relationship with gamers. In many ways, it will be a return to how we started: a small team making games for the core gaming audience." While Levine had considered founding a new startup for this endeavor, Take-Two convinced Levine that they would still be the best place for his studio. On February 18, 2014, the studio was restructured: Levine kept about 15 others, with Take-Two, 2K Games, and the studio helping to find positions for the other 75 employees. At this point, Irrational was effectively shut down, though over the next few years, it would continue to provide new job openings.


title: Ghost Story Games

text: In October 2016, several video game journalists noted that Take-Two had filed a trademark for the name "Ghost Story", related to video games, but otherwise not clear what this was for. On February 22, 2017, the studio announced it had rebranded itself as Ghost Story Games, though they were treating it as a fresh start as a newly founded studio. It was founded by 12 of the former Irrational members with Levine still as president and creative director. The studio's focus is "to create immersive, story-driven games for people who love games that ask something of them"; the name was chosen as ghost stories "are immersive, exciting, and steeped in community", similar to their design philosophies. As of this point, the studio had about 25 employees.


title: Ghost Story Games

text: While details of their first game have yet to be made public, Levine has spoken on elements that they are trying to develop for it. At the 2014 Game Developers Conference following the restructure, Levine presented his idea of "narrative Legos" that he wanted to explore with this studio. Levine stated that in this concept, they can distill narrative elements to key aspects that the player can learn, act upon, and affect a non-linear narrative story, and then combine them in a way to make a player-driven, highly-replayable game. In January 2015, Levine said that their first game with the narrative Legos concept will be a "first-person sci-fi" game. During a presentation at the March 2017 EGX Rezzed conference, Levine said that this game uses a system inspired by the Nemesis System within "", which he found provided a way to include a larger metanarrative in a game without having to customize a lot of story or dialog for it. Further, he said they included the idea of "radical recognition", in which the game's world responds in some way to actions that the player makes in a more programmatic manner, in contrast to the narrative approach used by Telltale Games which simply features branching decisions. Levine also anticipated the game will not be as "smooth" for players in contrast to the "BioShock" games, in that he does not anticipate that they will explain how the game's mechanics work directly to the player but require the player to figure out as they go.


title: Ghost Story Games

text: By the start of 2022, "Bloomberg News" reported that work on the studio's first game had fallen into development hell, having been in progress for at least seven years. Employees of the studio, speaking to "Bloomberg", stated that the development had been setback by several reboots of the game and changes in direction made by Levine, as well as Levine's management style which had led to employee burnout.


title: Ghost Story Games

text: The studio's first game, "Judas", was announced at The Game Awards 2022. It is planned for release on PlayStation 5, Xbox Series X/S and Windows.


title: M9 bayonet

text: The M9 Bayonet, officially known as the M9 Phrobis III, is a multi-purpose knife and bayonet officially adopted in 1986 by the United States. It has a blade and is issued with a sheath designed to double as a wire cutter.


title: M9 bayonet

text: The M9 bayonet was designed and developed by Charles A. "Mickey" Finn at his R&D company, Qual-A-Tec. It is a refined copy of the Russian AKM 6H3 bayonet. He later produced it under the Phrobis III name, filling a military contract for 325,000 units. Buck Knives was contracted to make 300,000 units and sold a commercial version under their own name. Finn's designs proved extremely popular, and were widely counterfeited and sold illegally by other makers. In 1989, Finn received , however, unlicensed copies continued to flow unchecked into the United States from Asia and Mexico, cutting into legitimate sales.


title: M9 bayonet

text: After the Phrobis III bayonet contract was completed, rights to the M9 reverted to the United States Army and there were many subsequent versions from other companies. It is issued by the armed forces of the U.S. and other countries, and has also been sold commercially in various versions.


title: M9 bayonet

text: Some production runs of the M9 have a fuller and some do not, depending upon which contractor manufactured that batch and what the military specs were at the time. The M9 Bayonet partially replaced the older M7 Bayonet, introduced in 1964. Although it has been claimed that the M9 may be more prone to breakage than the older M7, the M9 bayonet has a 20% thicker blade and tang (0.235" vs. 0.195") and a 75% greater cross-sectional area of steel in the blade than the M7.


title: M9 bayonet

text: The M11 knife (not strictly a bayonet as it has no mounting catch or muzzle ring; more of a revision to the Buckmaster 184/188 knife, which was the basis for the Phrobis XM-9 prototype bayonet), or M11 EOD is a version of the M9 specialized for explosive ordnance disposal (EOD). It has some extra features, such as a hammer pommel, but uses the same blade and sheath as the M9.


title: M9 bayonet

text: There have been five main makes of M9s: Phrobis, Buck (subcontracted by Phrobis III during the original Army contract), LanCay, Ontario and Tri-Technologies. Starting in 1987, Phrobis subcontracted Buck, finishing up in 1989. It was around this time that Buck sold commercial M9s as well, which it did up to 1997.


title: M9 bayonet

text: LanCay got its first contract in March 1992 (taking over production from Buck) for 30 (later 50) thousand knives (with General Cutlery as a subcontractor); in 1994, there was another contract issued for about 100,000 improved M9 models. In 1999, a contract for 25,000 knives was split between LanCay and Ontario (12,500 each).


title: M9 bayonet

text: Ontario Knife Company also participated in later contracts, and is one of the current (as of 2005) contractors for producing them. These can be identified by the blades, which are marked "M-9 / ONTARIO / KNIFE CO / USA".


title: M9 bayonet

text: The M7 bayonet, introduced in 1964, was used as a bayonet on the M16 rifle and as a fighting knife. The M9 multipurpose bayonet system is used as a bayonet on the M16 series rifle, on the M4 series carbine, as a fighting knife, as a general field and utility knife, as a wire cutter when used on the sheath, and as a saw. The M9 also fits the Mossberg 590 Special Purpose shotgun.


title: M9 bayonet

text: An overview of M9 types made by Buck Knives, one of the manufacturers of M9 bayonets. The 5,000 for the U.S. Marines are included under the U.S. Army numbers in this listing.


title: Rod Laver Arena

text: Rod Laver Arena is a multipurpose arena located within Melbourne Park, in Melbourne, Victoria, Australia. The arena is the main venue for the Australian Open, the first Grand Slam tennis tournament of the calendar year.


title: Rod Laver Arena

text: Replacing the aging Kooyong Stadium, construction on the arena began in 1985. It was undertaken by Civil & Civic was completed in 1987 at a cost of AU$94 million. It opened on 11 January 1988 for the 1988 Australian Open.


title: Rod Laver Arena

text: Originally known in 1988 as the National Tennis Centre at Flinders Park, the arena has officially changed its name twice. First in 1996, when it was known as the Centre Court, and again on 16 January 2000 to honour Rod Laver, a three-time winner of the Australian Open and one of the world's greatest tennis players.


title: Rod Laver Arena

text: Rod Laver Arena has a seating capacity of 14,820, with a capacity of 15,400 for sports such as basketball, when extra seats are added around the court, and up to 14,200 for concerts with floor seating. The arena currently attracts over 1.5 million visitors per year.


title: Rod Laver Arena

text: The arena was the first tennis venue in the world and the first arena of any kind in Australia to have a retractable roof installed. The idea for such a roof came about at the suggestion of John Cain, the premier of Victoria around 1980, who came up with the compromise idea after Tennis Australia requested the government to build an open air tennis facility next to a preexisting government project to build a closed roof entertainment center.


title: Rod Laver Arena

text: The Rod Laver Arena is the largest indoor arena in Australia without a permanent roof (not counting the 56,347 seat Docklands Stadium, also in Melbourne, which is classed as a stadium rather than an arena). It is also the second largest indoor arena in Australia behind the 21,032 capacity Sydney Super Dome. The arena's retractable roof allows competitors to continue play during rain or extreme heat.


title: Rod Laver Arena

text: Rod Laver Arena is equipped with the Hawk-Eye electronic system which allows tennis players to challenge the umpire's decision on calls made throughout championships.


title: Rod Laver Arena

text: Rod Laver Arena is the centrepiece of the National Tennis Centre at Melbourne Park, and besides tennis, the arena has hosted basketball, motorbike super-crosses, music concerts, conferences, World Wrestling Entertainment events and ballet. Other than for tennis, during sporting events or concerts, a section of the southern lower seating bowl is retracted to allow space for a stage or special floor level seating.


title: Rod Laver Arena

text: Rod Laver Arena acts as the centre court for the Australian Open tennis championships every year. The player after whom the arena is named, Rod Laver, is a frequent guest of honour at Championships and has presented the trophy to the men's singles champion on several occasions. Laver is widely considered the best player of his generation and amongst the consideration in the best players of all time.


title: Rod Laver Arena

text: Rod Laver Arena was the scene for Australia's famous Davis Cup victories in 2003. The arena hosted the semi-final and Final, at which Australia was successful in recording their 28th Davis Cup title.


title: Rod Laver Arena

text: Aside from tennis, the sport most often held at Rod Laver Arena in the past was basketball. The arena's first basketball game was in 1991 when the Australian Boomers played host to a touring All-Star team headlined by Kareem Abdul-Jabbar, with over 15,000 in attendance.


title: Rod Laver Arena

text: On 3 April 1992, the arena became the home of Melbourne basketball when the Melbourne Tigers (now known as Melbourne United) defeated the Canberra Cannons 112–104. The venue was actually criticised in its early days as a basketball venue due to the poor quality of the backboards and rings used. However, these concerns were quickly addressed and the arena became known as one of the best in the country, especially with anywhere near a full house in attendance. The arena was also home to the South East Melbourne Magic (later renamed the Victoria Titans in 1998 after merging with the North Melbourne Giants) with both teams attracting some of the largest crowds in the history of the NBL. Rod Laver Arena was also the site of the first ever "outdoor" pro basketball game in Australia when the Magic hosted the Adelaide 36ers on 31 December 1997 with the roof open.


title: Rod Laver Arena

text: The largest basketball crowd at Rod Laver Arena was set in 1996 when 15,366 attended a local derby game between the Magic and Tigers. This remains the second largest NBL basketball attendance ever in Australia behind the 17,803 who attended a game between the Sydney Kings and West Sydney Razorbacks at the Sydney Super Dome in 1999. Game two of the 1996 NBL Grand Final series, also between the Magic and Tigers, saw the NBL's largest ever single game Grand Final crowd when 15,064 watched the Magic defeat the Tigers 88–84.


title: Rod Laver Arena

text: 1992 saw the first time two teams from the one city had reached the NBL Grand Final series when the Magic faced fellow Melbourne Park tenants the Tigers. With all games being played at the league's largest venue a record aggregate of 43,605 (average 14,535) fans saw the Magic win their first championship two games to one, coming back to win games two and three 115–93 and 95–88 after losing game one 98–116.


title: Rod Laver Arena

text: In all, Rod Laver Arena hosted 287 NBL games including NBL Championship deciders in 1992, 1996, 1997 and 1999, and played host to its last game in April 2000 before Melbourne Arena opened in 2000 and became the new home of basketball in Melbourne. The arena hosted the Australian Boomers on numerous occasions, including playing against the Magic Johnson All-Stars in 1995, as well as hosting the 1997 FIBA Under-22 World Championship, which Australia won for the first time. The arena also played host to the 1993 NBL All-Star Game with the NBL Stars defeating the Boomers 124–119.


title: Rod Laver Arena

text: On 15 August 2015, Rod Laver Arena played host to the opening game of the 2015 FIBA Men's Oceania Basketball Championship between the Australian Boomers and the New Zealand Tall Blacks. In front of 15,062 fans Australia ran out 71–59 winners.


title: Rod Laver Arena

text: Rod Laver Arena was the centrepiece of the 12th FINA World Aquatics Championships, which were held from 17 March-1 April 2007. A temporary swimming pool, named the Susie O'Neill Pool after Australian swimming champion Susie O'Neill, was built at significant cost.


title: Rod Laver Arena

text: The venue has hosted professional wrestling events such as the WWE, World Championship Wrestling event in October 2000, World Wrestling All-Stars and World Cup skateboarding. In July 2012, the venue hosted its first netball match, when the Melbourne Vixens were forced to move a home semi-final to the arena after their usual home venue was booked for a concert. On 10 February 2019, the venue hosted UFC 234: Adesanya vs. Silva.


title: Rod Laver Arena

text: Rod Laver Arena was one of the host venues, along with Margaret Court Arena and Melbourne Arena, for the second Melbourne Esports Open on the weekend of 31 August to 1 September 2019. It featured three major regional esports tournaments across League of Legends, Overwatch and Rainbow Six Siege.


title: Rod Laver Arena

text: Rod Laver Arena consistently hosts Melbourne's highest-profile musical and entertainment concerts. In 2009, the arena polled 9th out of 50 worldwide top arenas for first-quarter ticket sales, making it the second highest ticket selling venue in Australia, second to Sydney's Qudos Bank Arena, which placed third. In 2012, the arena became Australia's highest selling venue and 4th in the world, based on 2011 ticket sales.


title: Rod Laver Arena

text: Rod Laver Arena's record attendance of 16,183 was set on 18 November 2007 for a Justin Timberlake concert during his FutureSex/LoveShow tour.


title: Rod Laver Arena

text: American singer P!nk performed a record-breaking 18 concerts at the venue in the winter of 2013 with her Truth About Love Tour, beating her own record of 17 shows from the Funhouse Tour in 2009. She is currently the artist who holds the record for most shows at the venue.


title: Rod Laver Arena

text: From 1988 until 2007, the surface of the court at the Australian Open and on Rod Laver Arena was Rebound Ace, which was coloured green and played slowly. The surface was also blamed for many injuries in the Australian Open, with many players claiming that the surface became sticky in hot weather, making it difficult to play on.


title: Rod Laver Arena

text: In 2008, the surface was changed to Plexicushion, and coloured blue. The surface is similar in properties to DecoTurf, the surface used in the US Open. This has more cushioning and more give than Rebound Ace. In 2019 the surface was changed again to Greenset, though retained its blue appearance and similarities to the Plexicushion.


title: Rod Laver Arena

text: It has also had a temporary grass court in use, during the 1993 Davis Cup quarterfinals, 2001 Davis Cup final and the 2003 Davis Cup final.


title: Rod Laver Arena

text: In June 2015, it was announced that the arena would undergo a redevelopment of its exterior facade and interior customer features, such as bars and other facilities. The refurbishment constituted the main aspect of the $338 million second stage of redevelopments that occurred at the Melbourne Park precinct, which included a new pedestrian bridge linking Melbourne Park and Birrarung Marr and a new media and administration centre. Construction began in April 2016. The refurbishment included a new eastern-facing primary entrance, an expanded public concourse space and other amenities designed to "open up" the arena and provide enhanced facilities and entry points for spectators. A new four-level Player Pod was constructed which increased the space for training, treatment, recovery, dining and lounging for athletes at major tournaments such as the Australian Open. In addition, the venue's roof was upgraded to allow for it to be closed for inclement weather in five minutes, dropping from the 30 minutes it took beforehand. The refurbishment was completed in late December 2018.


title: International taxation

text: International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income. The manner of limitation generally takes the form of a territorial, residence-based, or exclusionary system. Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more.


title: International taxation

text: Many governments tax individuals and/or enterprises on income. Such systems of taxation vary widely, and there are no broad general rules. These variations create the potential for double taxation (where the same income is taxed by different countries) and no taxation (where income is not taxed by any country). Income tax systems may impose tax on local income only or on worldwide income. Generally, where worldwide income is taxed, reductions of tax or foreign credits are provided for taxes paid to other jurisdictions. Limits are almost universally imposed on such credits. Multinational corporations usually employ international tax specialists, a specialty among both lawyers and accountants, to decrease their worldwide tax liabilities.


title: International taxation

text: With any system of taxation, it is possible to shift or recharacterize income in a manner that reduces taxation. Jurisdictions often impose rules relating to shifting income among commonly controlled parties, often referred to as transfer pricing rules. Residency-based systems are subject to taxpayer attempts to defer recognition of income through use of related parties. A few jurisdictions impose rules limiting such deferral ("anti-deferral" regimes). Deferral is also specifically authorized by some governments for particular social purposes or other grounds. Agreements among governments (treaties) often attempt to determine who should be entitled to tax what. Most tax treaties provide for at least a skeleton mechanism for resolution of disputes between the parties.


title: International taxation

text: Systems of taxation vary among governments, making generalization difficult. Specifics are intended as examples, and relate to particular governments and not broadly recognized multinational rules. Taxes may be levied on varying measures of income, including but not limited to net income under local accounting concepts (in many countries this is referred to as 'profit'), gross receipts, gross margins (sales less costs of sale), or specific categories of receipts less specific categories of reductions. Unless otherwise specified, the term "income" should be read broadly.


title: International taxation

text: Jurisdictions often impose different income-based levies on enterprises than on individuals. Entities are often taxed in a unified manner on all types of income while individuals are taxed in differing manners depending on the nature or source of the income. Many jurisdictions impose tax at both an entity level and at the owner level on one or more types of enterprises. These jurisdictions often rely on the company law of that jurisdiction or other jurisdictions in determining whether an entity's owners are to be taxed directly on the entity income. However, there are notable exceptions, including U.S. rules characterizing entities independently of legal form.


title: International taxation

text: In order to simplify administration or for other agendas, some governments have imposed "deemed" income regimes. These regimes tax some class of taxpayers according to tax system applicable to other taxpayers but based on a deemed level of income, as if received by the taxpayer. Disputes can arise regarding what levy is proper. Procedures for dispute resolution vary widely and enforcement issues are far more complicated in the international arena. The ultimate dispute resolution for a taxpayer is to leave the jurisdiction, taking all property that could be seized. For governments, the ultimate resolution may be confiscation of property, incarceration or dissolution of the entity.


title: International taxation

text: Other major conceptual differences can exist between tax systems. These include, but are not limited to, assessment vs. self-assessment means of determining and collecting tax; methods of imposing sanctions for violation; sanctions unique to international aspects of the system; mechanisms for enforcement and collection of tax; and reporting mechanisms.


title: International taxation

text: Countries that tax income generally use one of two systems: territorial or residence-based. In the territorial system, only local income – income from a source inside the country – is taxed. In the residence-based system, residents of the country are taxed on their worldwide (local and foreign) income, while nonresidents are taxed only on their local income. In addition, a small number of countries also tax the worldwide income of their nonresident citizens in some cases.


title: International taxation

text: Countries with a residence-based system of taxation usually allow deductions or credits for the tax that residents already pay to other countries on their foreign income. Many countries also sign tax treaties with each other to eliminate or reduce double taxation. In the case of corporate income tax, some countries allow an exclusion or deferment of specific items of foreign income from the base of taxation.


title: International taxation

text: The following table summarizes the taxation of local and foreign income of individuals, depending on their residence or citizenship in the country. It includes 244 entries: 194 sovereign countries, their 40 inhabited dependent territories (most of which have separate tax systems), and 10 countries with limited recognition. In the table, "income" includes any type of income received by individuals, such as work or investment income, and "yes" means that the country taxes at least one of these types.


title: International taxation

text: Taxing regimes are generally classified as either residence-based or territorial. Most jurisdictions tax income on a residency basis. They need to define "resident" and characterize the income of nonresidents. Such definitions vary by country and type of taxpayer, but usually involve the location of the person's main home and number of days the person is physically present in the country. Examples include:


title: International taxation

text: Territorial systems usually tax local income regardless of the residence of the taxpayer. The key problem argued for this type of system is the ability to avoid taxation on portable income by moving it outside of the country. This has led governments to enact hybrid systems to recover lost revenue.


title: International taxation

text: In the vast majority of countries, citizenship is completely irrelevant for taxation. Very few countries tax the foreign income of nonresident citizens in general:


title: International taxation

text: A few other countries used to tax the foreign income of nonresident citizens, but have abolished this practice:


title: International taxation

text: In Iran, Iraq, North Korea, the Philippines and Saudi Arabia, citizenship is relevant for the taxation of residents but not for nonresidents.


title: International taxation

text: There are some arrangements for international taxation that are not based on residency or citizenship:


title: International taxation

text: Countries do not necessarily use the same system of taxation for individuals and corporations. For example, France uses a residence-based system for individuals but a territorial system for corporations, while Singapore does the opposite, and Brunei and Monaco taxes corporate but not personal income.


title: International taxation

text: Many systems provide for specific exclusions from taxable (chargeable) income. For example, several countries, notably the United States, Cyprus, Luxembourg, Netherlands and Spain, have enacted holding company regimes that exclude from income dividends from certain foreign subsidiaries of corporations. These systems generally impose tax on other sorts of income, such as interest or royalties, from the same subsidiaries. They also typically have requirements for portion and time of ownership in order to qualify for exclusion. The United States excludes dividends received by U.S. corporations from non-U.S. subsidiaries, as well as 50% of the deemed remittance of aggregate income of non-U.S. subsidiaries in excess of an aggregate 10% return on tangible depreciable assets. The Netherlands offers a "participation exemption" for dividends from subsidiaries of Netherlands companies. Dividends from all Dutch subsidiaries automatically qualify. For other dividends to qualify, the Dutch shareholder or affiliates must own at least 5% and the subsidiary must be subject to a certain level of income tax locally.


title: International taxation

text: Some countries, such as Singapore, allow deferment of tax on foreign income of resident corporations until it is remitted to the country.


title: International taxation

text: Many tax systems tax individuals in one manner and entities that are not considered fiscally transparent in another. The differences may be as simple as differences in tax rates, and are often motivated by concerns unique to either individuals or corporations. For example, many systems allow taxable income of an individual to be reduced by a fixed amount allowance for other persons supported by the individual (dependents). Such a concept is not relevant for enterprises.


title: International taxation

text: Many systems allow for fiscal transparency of certain forms of enterprise. For example, most countries tax partners of a partnership, rather than the partnership itself, on income of the partnership. A common feature of income taxation is imposition of a levy on certain enterprises in certain forms followed by an additional levy on owners of the enterprise upon distribution of such income. For example, the U.S. imposes two levels of tax on foreign individuals or foreign corporations who own a U.S. corporation. First, the U.S. corporation is subject to the regular income tax on its profits, then subject to an additional 30% tax on the dividends paid to foreign shareholders (the branch profits tax). The foreign corporation will be subject to U.S. income tax on its effectively connected income, and will also be subject to the branch profits tax on any of its profits not reinvested in the U.S. Thus, many countries tax corporations under company tax rules and tax individual shareholders upon corporate distributions. Various countries have tried (and some still maintain) attempts at partial or full "integration" of the enterprise and owner taxation. Where a two level system is present but allows for fiscal transparency of some entities, definitional issues become very important.


title: International taxation

text: Determining the source of income is of critical importance in a territorial system, as source often determines whether or not the income is taxed. For example, Hong Kong does not tax residents on dividend income received from a non-Hong Kong corporation. Source of income is also important in residency systems that grant credits for taxes of other jurisdictions. Such credit is often limited either by jurisdiction or to the local tax on overall income from other jurisdictions.


title: International taxation

text: Source of income is where the income is considered to arise under the relevant tax system. The manner of determining the source of income is generally dependent on the nature of income. Income from the performance of services (e.g., wages) is generally treated as arising where the services are performed. Financing income (e.g., interest, dividends) is generally treated as arising where the user of the financing resides. Income related to use of tangible property (e.g., rents) is generally treated as arising where the property is situated. Income related to use of intangible property (e.g., royalties) is generally treated as arising where the property is used. Gains on sale of realty are generally treated as arising where the property is situated.


title: International taxation

text: Gains from sale of tangible personal property are sourced differently in different jurisdictions. The U.S. treats such gains in three distinct manners: a) gain from sale of purchased inventory is sourced based on where title to the goods passes; b) gain from sale of inventory produced by the person (or certain related persons) is sourced 50% based on title passage and 50% based on location of production and certain assets; c) other gains are sourced based on the residence of the seller.


title: International taxation

text: In specific cases, the tax system may diverge for different categories of individuals. U.S. citizen and resident alien decedents are subject to estate tax on all of their assets, wherever situated. The nonresident aliens are subject to estate tax only on that part of the gross estate which at the time of death is situated in the U.S. Another significant distinction between U.S. citizens/RAs and NRAs is in the exemptions allowed in computing the tax liability.


title: International taxation

text: Where differing characterizations of an item of income can result in differing tax results, it is necessary to determine the characterization. Some systems have rules for resolving characterization issues, but in many cases resolution requires judicial intervention. Note that some systems which allow a credit for foreign taxes source income by reference to foreign law.


title: International taxation

text: Some jurisdictions tax net income as determined under financial accounting concepts of that jurisdiction, with few, if any, modifications. Other jurisdictions determine taxable income without regard to income reported in financial statements. Some jurisdictions compute taxable income by reference to financial statement income with specific categories of adjustments, which can be significant.


title: International taxation

text: A jurisdiction relying on financial statement income tends to place reliance on the judgment of local accountants for determinations of income under locally accepted accounting principles. Often such jurisdictions have a requirement that financial statements be audited by registered accountants who must opine thereon. Some jurisdictions extend the audit requirements to include opining on such tax issues as transfer pricing. Jurisdictions not relying on financial statement income must attempt to define principles of income and expense recognition, asset cost recovery, matching, and other concepts within the tax law. These definitional issues can become very complex. Some jurisdictions following this approach also require business taxpayers to provide a reconciliation of financial statement and taxable incomes.


title: International taxation

text: Systems that allow a tax deduction of expenses in computing taxable income must provide for rules for allocating such expenses between classes of income. Such classes may be taxable versus non-taxable, or may relate to computations of credits for taxes of other systems (foreign taxes). A system which does not provide such rules is subject to manipulation by potential taxpayers. The manner of allocation of expenses varies. U.S. rules provide for allocation of an expense to a class of income if the expense directly relates to such class, and apportionment of an expense related to multiple classes. Specific rules are provided for certain categories of more fungible expenses, such as interest. By their nature, rules for allocation and apportionment of expenses may become complex. They may incorporate cost accounting or branch accounting principles, or may define new principles.


title: International taxation

text: Most jurisdictions provide that taxable income may be reduced by amounts expended as interest on loans. By contrast, most do not provide tax relief for distributions to owners. Thus, an enterprise is motivated to finance its subsidiary enterprises through loans rather than capital. Many jurisdictions have adopted "thin capitalization" rules to limit such charges. Various approaches include limiting deductibility of interest expense to a portion of cash flow, disallowing interest expense on debt in excess of a certain ratio, and other mechanisms.


title: International taxation

text: The organization or reorganization of portions of a multinational enterprise often gives rise to events that, absent rules to the contrary, may be taxable in a particular system. Most systems contain rules preventing recognition of income or loss from certain types of such events. In the simplest form, contribution of business assets to a subsidiary enterprise may, in certain circumstances, be treated as a nontaxable event. Rules on structuring and restructuring tend to be highly complex.