Monday, September 30, 2019

American Spanish war in 1898, Spain Loses Colonies

It is quite difficult to make a conclusion on the particular incident that lost 258 American sailors on board the battleship USS Maine, not because of the complexity of the incident but because of the lack of sufficient findings of the case. Even some writers address the incident as â€Å"The USS Maine mysteriously blew up. † The USS Maine was sent to Havana harbor with a mission to protect US citizens in Cuba. According to Phillip Oppenheim â€Å"The Spanish immediately apologized† but â€Å"what evidence there was pointed to an accidental explosion in the Ship’s magazine† (p.  101).The findings however was, the cause of the tragedy was an accidental explosion as a result of spontaneous combustion in the coalbunker near the powder magazine. This finding was particularly concluded by Hyman G. Rickover, a US Navy Admiral and a scientist, published in 1976. Hyman’s findings may be convincing, but then Reckover’s findings according to a wikipe dia article have been disputed by US Naval History Center (Wikipedia).My conclusion on the Cuba incident was the USS Maine was intentionally blown up either by some pro Spanish group such as the â€Å"Spanish Voluntarios† or by Cuban independence fighter in order to spark the war between the United State and Spain. Citing Captain Sigsbee, the commanding officer of the Maine, Evelina Gleaves Cohen pointed out Captain Sigbee’s message reporting that the USS Maine was destroyed by a Mine. Sigbee’s message stated, â€Å"I surmise that her berth was one planted previous to her arrival, perhaps long ago† (Cohen, p. 63).It would be reasonable to believe in the survivor’s account as they have witnessed in detail what exactly had happened. It was intentional as the mine could not be there if it was not planted for that purpose. The only thing that maybe difficult to establish was who were behind this incident. Nonetheless, it serves its purpose. The Origin of the War The origin of Spanish American war cannot be attributed to the so called â€Å"Cuba incident† as the USS Maine were sent to protect US citizens from the hostilities that were orchestrated by pro Spanish Voluntarios which gave the United States a basis to launch in the warship USS Maine.According to Wikipedia article, the war started after Spain rejected the American demand to resolve peacefully the Cuban struggle for independence. The explosion of the USS Maine may have ignited the already smoking conflict but it was the interest of the United States on Spain’s overseas territories that led to them to participate in the Cuban political struggles (Wikipedia). The USS Maine According to Oppenheim the USS Maine â€Å"sailed provocatively into Havana harbor†¦Ã¢â‚¬  (p. 101).An internet article entitled Increasing Spanish-Cuban tensions: Late 19th Century, mentioned that when the conflict broke out in Cuba in 1895, Spain sent 200,000 troops under the infam ous general Weyler, also known as â€Å"the Butcher,† to squash the insurrection. Weyler imprisoned large number in concentration camps under the harsh and inhuman condition causing prisoners rapid death especially from disease. This outraged portions of the US public that called out for immediate action which the provoked the US to issue an ultimatum to the Spanish authorities.With Spain’s refusal to oblige, the US congress passed a declaration of was against Spain prior to the destruction of the USS Maine (The Spanish American War 1898-1901). Consequences of the Confrontation The consequences of the confrontations on the Spanish authorities were enormous as most of their remaining ships were destroyed aside from many lives that were lost in the battle. But most importantly, Spain losses all its overseas colonies including their most treasured possession, Cuba. It also marked the collapsed of Spain’s power.However, the consequences of war on the United States w ere rather positive. The United States became a world power after it acquired the Spanish colonies (Spanish American War). What loosing Cuba meant for Spain? Basically, it seemed that politically and economically Cuba does not really have such importance for Spain than any of their colonies in Asia and all other part of the world. Perhaps the importance of Cuba for Spain was that it was during the Cuban rebellion that led to war against the United States, which eventually led to the loss of the remaining overseas colonies of Spain.Cuba was the last image of Spanish greatness and pride thus Spain was determined to keep the country under their control despite pressure from the United States to grant independence to the beleaguered colony. What other Colonies were lost by Spain The American victory against Spain enables the United States to acquire Spanish colonies such as the Philippines, Guam, and Puerto Rico. The Philippines was acquired by the United States after the Spanish forces in the Philippines surrendered manila to Admiral George Dewey in battle of Manila Bay (Spanish American War).The American forces needed the support of Filipino rebels particularly of Emilio Aguinaldo before finally subduing the Spanish forces in the Philippines. After American victory in the Philippines, Spain lost Guam to the United States with out a fight. Spanish Authorities in Guam According to the internet article Spanish American War were unaware that the war had started until American warship arrived in Guam on June 20, surprised; the authorities surrendered the island without a fight. Another colony that Spain lost to the United States due to their defeat in the war was Puerto Rico.According to the article, the invasion of Puerto Rico began on afternoon of July 21 from the Guantanamo bay. The invasion was spearheaded by battleship Massachusetts, Dixie, Gloucester, Colunbia and Yale, under the command of Captain of Frances J. Higginson with 3,500 U. S Army troops. Although t he US Army encountered pierce resistance but they subsequently over power the Spanish Forces depending the country. Other colonies lost by Spain through treaty and sale to the United States were Hawaiian Islands, The Guantanamo Bay, the Virgin Islands, and part of the Samoan Archipelago. ConclusionThe Spanish American war was the classic encounter between the declining super and the rising world power. The war seemed to be that turned over of power by the exiting world power to the United States as the emerging world power. But the lesson that the war may have taught Spain, and the United States was that war was not only a means for settling disputes, but it was also an expression of unsatisfied cravings for more. The Spanish American War (1898-1901) tp://www. sparknotes. com/history/american/spanishamerican/section1. html Spanish American war http://www. conservapedia. com/Spanish-American_War

Sunday, September 29, 2019

Experiential Knowledge versus Intellectual Knowledge Essay

The Adventures of Huckleberry Finn has for a long time stirred the issue on the tug between experiential knowledge (the sort of knowledge that is gained in the â€Å"streets† and practiced mostly by Huck) and intellectual knowledge (the kind of knowledge being taught in schools and by people like Widow Douglas and Miss Watson). The issue can most of the time be phrased as that between being logical and following the practical consequences of one’s logic as opposed to following the dictates of society. This is a theme that was developed early on in the book and extends up to the end. Huck, for example, defies society and chooses his own logic in Chapter 1 when he told Widow Douglas that he would prefer to go to hell since this would mean a change of scenery and being with Tom. It is known for a fact that â€Å"heaven† should be the de facto choice of destination for everyone. To choose to go to hell, with our without reasons for wanting to do so, plainly means going against what is conventional. Time and again, Huck has dealt with the part of his conscience that told him that keeping and cuddling Jim, a â€Å"property† of Miss Watson versus his natural sympathy for the man (Bennett 3). These and many other instances in Huckleberry Finn illustrate the clash between the obviously wrong societal teaching that racism and slavery is good and having sympathy and compassion for the slaves as bad versus the instinctive knowledge that sympathy and compassion towards a slave is worthwhile. In this paper, this clash between experiential knowledge, i. e. , knowledge gained by oneself through the exercise of personal logical induction and deduction gathered through experience, and intellectual knowledge, i. e. , knowledge gained through different societal instruments, shall be dealt with. More specifically, this paper shall address the issue of which of these two â€Å"knowledges† has more importance. Being an issue that is of no light matter, this paper would need to look beyond Huckleberry Finn for aid. As such, Philosophy, Ethics, and Education seem to be the most promising areas of knowledge that address the issue. Hence, this paper shall look in these directions to settle the issue. Specifically, this paper shall have the following parts: on wisdom and knowledge as personal or societal; morality as inauthentic or authentic; and educations as geared towards making the person â€Å"fully† come out versus education as socialization. The paper shall end with a conclusion. Wisdom as Personal or Societal Philosophy has dealt with the question on the source of wisdom a number of times and through different thinkers. Thomas Aquinas and Aristotle are known to deal extensively about this issue, and as such, their philosophies shall be utilized. Since Aquinas is known for extensively working on Aristotle’s works, merging the works of these two thinkers shall not pose any problems. Before anything, it would be best to first give a definition of wisdom. At least in the Aristotelian-Thomistic tradition, wisdom is a kind of knowledge that is â€Å"of paramount importance in directing human existence towards its purpose or end† (Artigas 17). It is that kind of knowledge that aids man to be a better human being, not only by providing particular knowledge, but most specially a universal knowledge that speaks of the human being’s nature, purpose and end. In the end, wisdom ought to lead to the human being’s happiness, happiness defined as a life that is flourishing. All these ideas seem to be abstract, so it would be best to concretize a bit. At least for Aristotle, living a life that is full of human flourishing means living a virtuous life in a community that allows for the continuous development of the individual. According to the Aristotelian philosopher Martha Nussbaum, this refers to a life wherein virtues, human relations, reason and other physical capabilities are allowed to flourish by the society (Nussbaum 76-78). More concretely, this means experiencing real friendship, practicing justice, exercising prudence and a host of many other virtues that Aristotle spoke of in the Nicomachean Ethics in a society that value and nurture these. It is allowing a person to have meaningful relations, to engage in activities that nourish one’s â€Å"senses, imagination, and thought,† to have bodily health, to engage in play, to have autonomous control over one’s environment and so on (Nussbaum 76-78). So far, it seems that wisdom ought to be acquired for the benefit of the individual that would most probably emanate into the good of society. That is well and good, nevertheless, we still have not answered the question as to how wisdom itself is acquired. In this respect, Aquinas has an answer. Thomas Aquinas is known for the Natural Law Theory. The theory states that â€Å"man is born with the natural facility to know the basic truths or principles or the moral order as ‘the good is to be done and promoted and the evil to be avoided’† (Panizo 56). In this respect wisdom, i. e. , knowledge about what is good and what is to be avoided that ought to lead to happiness and human flourishing, is not only something that man is capable of; in fact, man is born with this natural facility. Human beings are born with the disposition to want what is good and to avoid what is evil. Thinking about it, this medieval theory seems to make a lot of sense. Is it not true that no human being ever does something which for her/him is plainly without good or any sort of benefit? Even actions that may be considered as evil by many still have some sort of perverted â€Å"goodness† in it. Actions such as murder, drug trafficking, etcetera, still give â€Å"pleasure† to those who engage in them. But, does this mean that these actions are morally good? Aquinas would not agree. He would say that though nature has granted man the capacity to know what is good and evil and to want good over evil, still, error may happen. Error occurs once the basic principle, â€Å"good is to be done and sought after, evil is to be avoided† (Aquinas 197) is applied. In fact, there is a hierarchy of difficulty when it comes to the application of this basic principle, the most difficult application of it called â€Å"remote conclusions† are described as â€Å"not easily drawn by ordinary people, for they involve education in theology and philosophy, and deep reflection† (Panizo 59). These involve judgments on issues like euthanasia, divorce, abortion, etcetera. We have reached a point then when natural wisdom, i. e. , wisdom depending on reason alone, becomes insufficient. Life is so full of instances when â€Å"remote conclusions† are needed and called for. The sad thing is, this knowledge is hard to come by and a human being is left with no option but to listen to the dialogues of the people in the academe. For Aquinas and Aristotle, experiential knowledge is not enough. It could only get us so far. This then brings us to the discussion of the place of â€Å"intellectual knowledge† in Philosophy. According to Aristotle, human beings need a role model to live a flourishing life. An excellent person is considered the standard for most of us who are still aiming for human flourishing, for a life of virtue. An excellent person is defined as he/she whose wishes â€Å"will be what is wished in reality† (Aristotle 65), i. e. , the wishes of the excellent person is that which is truly good for the human being. An excellent person is the exact opposite of the base person to whom â€Å"pleasure would seem to cause deception since it appears good when it is not† (Aristotle 65). Thus, modeling is Aristotle’s system of knowing what is worth imitating and what is not. To add to this, it must be recalled that for Aristotle (as with the other Greek thinkers), education has an indispensable role in bringing an individual to perfection. This is the very reason why the Academy and the Lyceum were established. In these schools, individuals from different cities merge to further their knowledge, to share each other’s knowledge and in this sense socializing each other. Hence, at least in Aristotle and Aquinas’ philosophy, though natural wisdom or experiential knowledge may be the starting point, this is not enough. Intellectual knowledge is still necessary since remote conclusions are always called for to ultimately be happy and live a flourishing life. Authentic and Inauthentic Morality Beyond the epistemology of Aristotle and Aquinas is the perspective that morality or ethics may be inauthentic or authentic. This is the very idea of Michael Moga in the book, Toward Authentic Morality. According to Moga, one’s sense of right and wrong can either be wholly dependent on one’s culture (i. e. , inauthentic morality) or it could come from one’s personal choice (i. e. , authentic morality). This is the very same clash between the self and the society that we have been talking about. According to Moga, most people ascribe to inauthentic morality. This is the sort of morality that gives in to social pressure, that kind of pressure that forces us to act and think in a particular way without exactly knowing why such an action or thought should be considered moral. We would not have to go very far to understand inauthentic morality. Most adolescents and teenagers are susceptible to peer pressure when it comes to many facets of their lives. The very persistence of racism and discrimination speak of a poorly reasoned morality that rest on social acceptance. In fact, Moga sets out the characteristics of inauthentic morality. The following are the characteristics of this type of morality. Inauthentic morality is characterized by being based on certain rules and values affirmed by culture; it is universal in its application, i. e. , it is valid for everyone; they impact individuals as set of morality that is external, i. e. , the source of morality is something outside the self; these laws are anonymous; the individual is haunted by fear and shame; the moral obligation is something that comes from authority; and it is fluctuating in influence (Moga 35-39). This is the sort of morality experienced by the typical teenager who follows his/her group’s choices. Such an individual follows rules not her own, a set of rules she may find difficult to follow since it is something external, nevertheless the breaking of such group rules result to fear and shame. This teenager considers the lead of the group as the one vested with authority to enforce such rules. Though this morality is most stark among teenagers, adults may very well be living this sort of morality. We would only have to look around shopping malls to see how many adults go with the flow without thinking why. Supposedly at the other extreme is authentic morality. This morality results from one’s personal decision to accept a set of values and morals after necessary reflection. Again, this sort of morality has characteristics: it is personally chosen and accepted; it is based on a rational appreciation; it is not based on fear or shame; morality as an expression of one’s freedom; and it is based on what one personally cares for, i. e. the very principles that one values (Moga 39-41). This is the sort of morality of individuals who have taken enough time to think over his/her morals. This would be represented by an individual who does an action and could very likely explain and be personally involved in the very principle of one’s actions. This would be the individual whose sense of morality is not dependent on â€Å"what others will say† but rather on a clear set of personally chosen moral principles. Though individuals must all aim for authentic morality, Moga insists that both moralities are important. In the first place, all human beings undergo the inauthentic morality stage where parents become the sole authority from whom morality emanate. Nevertheless, we should not stay this way. After being exposed to different sets of moralities, it is the individual’s responsibility to think and chose which of these moralities shall be made personal. Thus, at least in the Ethical perspective, the social and the personal ought to go together, though in the end, the social should be for the personal. Conclusion We have seen that at least in Philosophy and Ethics, there really is no real clash between the personal and the social, between intellectual knowledge and experiential knowledge. Clashes happen in Philosophy when error exists in the mind and nothing is done to correct the error. This error may of course exist not only with individuals but also in groups such as those in the academe. Nevertheless, we have clearly stated above that intellectual knowledge is there not to ram down society on the throats of individuals but rather to further perfect experiential knowledge for the sake of human flourishing. The same may be said in the field of ethics. Both authentic and inauthentic moralities are there and both have uses in society. Nevertheless, in the end, inauthentic morality ought to be the material source of inputs for the eventual authentic morality of a person. Morality only becomes stagnant when there is no interaction between the inauthentic and authentic. To answer the question which of the two knowledges is more important, we could qualifiedly say that both are important as long as there is minimal error and that the ultimate purpose is human flourishing.

Saturday, September 28, 2019

The Impact of Unemployment on the Economy Term Paper

The Impact of Unemployment on the Economy - Term Paper Example The success of a business relies on not only the own particular market and its own decisions but also the macroeconomic environment it operates within. The macroeconomic environment has a direct effect on the profitability and success of a business. This paper aims at dealing with one of the essential aspects of the macroeconomic environment of business, i.e. unemployment. This paper will deal with unemployment in detail and will include aspects like the meaning of unemployment, and the costs of unemployment. Also, a focus will be on the labor markets and unemployment. The study will also touch upon the two main types of unemployment, i.e. Disequilibrium unemployment and Equilibrium unemployment. Here an attempt will be made to explain the two types of unemployment and the various subcategories of these will also be touched upon. However, before moving on, it is essential to understand the meaning of a few terms like labor force, number unemployed, unemployment rate, and unemployment . Claimant Unemployment: This refers to the people who receive unemployment-related benefits (Sloman and Sutcliffe). This mainly measures all those who receive the unemployment-related benefits and claim the benefits to cover their expenses until they have a job. Standardized Unemployment Rate: This is an unemployment rate that is used by the International Labor Organization and the Organization for Economic Co-Operation and Development (Sloman and Sutcliffe). Here unemployed refers to people of the working age and who are without work. b) Costs of unemployment: Unemployment leads to numerous costs and these costs do not only influence the person unemployed but others as well. There are three main costs that are involved with unemployment are as follows: i) The first and most obvious costs involved are that incurred by the unemployed themselves.

Friday, September 27, 2019

Business Law Assignment Example | Topics and Well Written Essays - 250 words - 19

Business Law - Assignment Example It becomes a parole because it was an oral agreement made before the final written contract was made. I therefore agree with the court for rejecting Canopy’s evidence. It is against the principles of parole evidence rule which categorically states that there should not be a parole to a written contract. Meaning, evidence made prior to a written contract ca not be accepted for consideration in case of a dispute. It is therefore appropriate for the court to make such a decision it is in compliance with the law. Apart from being oral evidence made prior to the actual contract, it contains evidence which contradicts the written contract itself. Despite Canopy not being a party to the written contract, it went ahead to give this evidence. This is uncalled for and should not be entertained. Instead, the court should go ahead to consider the case filed by Novell Inc to protest against the deductions made by Canopy because it breaches its contract with Caldera

Thursday, September 26, 2019

Analysis of the Film Star Trek Essay Example | Topics and Well Written Essays - 750 words

Analysis of the Film Star Trek - Essay Example Technology has played a big role in shaping global politics and global powers, which in turn affects the global economy. It is evident that technological advancements in a country determine its international economic influence. For instance, the US holds its current position in global politics and economy due to its state of technology. Other nations such as China and India have invested a lot in technology to gain international recognition. The film also illustrates the key sectors that countries invest their technology. The first area of interest is communication. Unlike past technology, modern communication devices have numerous capabilities and therefore numerous implications for the governance of a country. The film indicates the greater development of technology and therefore greater impacts on governance. Since the time of the scientific revolution, the government has played a great role in the development of science and technology (Asherman 134). For instance, the most sophis ticated technology is applied to the production of military types of equipment. In addition, the current mobile technology was applied by the military before communication devices for civilians were made. This indicates the influence that political governments have on science and technology. Space science the other aspects of technology that is of interest to the global leaders. Different world powers have a keen interest in space technology at their own capacity. America was the first country to conduct successful space explorations with the 1960 s landing on the moon been their climax in space exploration. This made Russia initiate its own space exploration programs aimed at countering the efforts of the US. Their 1970 s landing on the moon came as a surprise attack to the US. Tensions and rivalry between the US and Russia heightened during the cold war and each of these powers used its space exploration programs to demonstrate its military capabilities. Since the end of the cold war, space exploration has not received much progress and enthusiasm. This is a contradiction since missions conducted in the 1960 s and 70s did not involve the state of the art technology that is available in the modern world (Asherman 34). This indicates that political systems in the world are critical to such discoveries. Recently the Chinese and Indians have shown their interests in continuing the works initiated by Americans and Russians. China and India have launched their own satellites into space and they intend to send astronauts to the moon. The progress has been made by China and India indicates the shift of political and economic power from the west to the east. Although the film depicts the capabilities that technology has over governance, it also shows the negative aspect of technology on governance. The film demonstrates incidences of attacks on communication systems. Cyber attacks are the next battlefield in the modern world. Incidents of cyber attacks have been repo rted in various countries. This shows the role that technology plays in shaping global politics. Iran has reported cyber attacks on computers that operate its controversial nuclear facilities. According to BBC news agencies, the cyber attacks that were carried out on Iranian nuclear facility have the capabilities of slowing Iran’s nuclear ambitions for a period of five years.  Ã‚  

Wednesday, September 25, 2019

How organised is Organised Crime Essay Example | Topics and Well Written Essays - 3000 words

How organised is Organised Crime - Essay Example ?How organized is Organized Crime?†, it is difficult to provide a straightforward answer, given the complexities and flexibility that signify these groups. Hence, this essay will try to present to the reader those aspects of Organized Crime groups that is well organized and also point to those elements in it that is more fluid. One of the notorious crime groups of the twentieth century is the Medellin Cartel of Columbia. The perennial political instability of Columbia is a key factor for the evolution of this group. The civil war of 1948-1958 had the harshest impact on the country and its surrounding areas. The civil war was essentially one of struggle between poor campesinos and the rich landowners. It is no coincidence that most of the populace of Medellin are poor and are à ©migrà ©s from the countryside. The industrial city of Medellin served as the operating base for the Medellin Cartel, whose founders include Pablo Escobar, the Ochoa clan, and Carlos Lehder-Rivas. The city is also notorious for smuggling and picks pocketing (Griswold 2005). Some of the leaders of the Medellin cartel were even involved in active politics, which ironically gave the cartel an air of legitimacy. In 1982, Escobar was elected as an alternate Colombian representative in Envigado, a region nearby Medellà ­n. There he established himself as a saviour of the underprivileged by implementing construction projects for slum dwellers and soccer fields for the youth. He even had his own newspaper, which acted as his public relations equipment. It portrayed him as an up-from-the-slums statesman. Escobar enjoyed immunity from arrest as long as he was a public representative. Hence, in this Columbian example, organized crime was part and parcel of mainstream politics. In this sense, we can call the cartel a sophisticated, powerful and well organized group. (Griswold 2005) Having said so, not all underworld groups achieve popular recognition the way Medellin cartel did. For most

Tuesday, September 24, 2019

Computed Tomography Assignment Example | Topics and Well Written Essays - 1250 words

Computed Tomography - Assignment Example lues based on dispersed dose quantities while on the other side, the NCRP technique demonstrated an overestimation of the least vital obstacle of depth. Breast shielding method is another shielding method. It helps in reducing radiation dose. The main side effect of breast shielding is that it produces low quality images during the study. Bismuth shielding method on the other side has also contributed to reduce doses effects to patients of CT such as breast, thyroid and eye lens. (Jankowski et al., 2004). Bismuth shielding method is also easy to use compared to other methods. Radiation protection shielding helps in reducing exposed body parts which are sensitive such as thyroid and gonads and the breast from radiation. Having gone through several findings about computed tomography radiation protection shield, it is our concern to consider different body parts that experiences radiation effects. The reviews specify a favorite shields for computed tomography angiography versus ventilat ion perfusion scanning in the diagnosis of Pulmonary Embolus to the patients with lung disease (Jankowski et al., 2004). The nature of likeness is geared with a number of factors that varies between the institutions and the selection of the patient. Shielding calculations for computed tomography system is based on British Institute of Radiology and institute of physics in Engineering in Medicine (BIR-IPEM). Studies reveal that people are much affected by computed tomography (Jankowski et al., 2004).

Monday, September 23, 2019

Assassinations to Sustain Governments Essay Example | Topics and Well Written Essays - 500 words

Assassinations to Sustain Governments - Essay Example So, Stalin was evidently using all the harassments against his rivals to sustain his government that otherwise would have lost the public support. 2. Sergei Kirov was one of Stalins closest supporters on the Politburo and was in 1934, the party boss of Leningrad. At the 1934 Party Congress, Kirov changed side and began criticizing Stalin and his cruel policies. Fearless ones agreed with Kirov while other less daring ones stayed silent. Stalins position in the Central Committee was under doubt as Kirov pocketed highest number of votes while Stalin got zero. So, Stalin decided to take action against Kirov, the emerging rival for leadership in the Party. On 1st December 1934, Stalin had Kirov assassinated. On the same day, Stalin passed a law that ordered anyone accused of terrorism and plots against the government was to be arrested and executed immediately after conviction (Furia 8 - 9). 3. Stalin feared if Sergei Kirov would grab power from him. So, he tried to persuade Kirov to be loyal to him. Stalin asked Kirov to leave Leningrad to join him in Moscow. Stalin wanted Kirov in a place where he could keep a close eye on him. When Kirov refused, Stalin decided to have him assassinated (Furia 8 - 9). 4. Kirov was a potential rival in the party against Stalin. He used to disagree with Stalin over the issue of democracy within the party. Stalin feared if Sergei Kirov would topple him down from power. So, he tried to persuade Kirov to be loyal to him. Stalin asked Kirov to leave Leningrad to join him in Moscow. Stalin wanted Kirov in a place where he could keep a close eye on him. When Kirov refused, Stalin decided to have him assassinated. He was shot dead on December 1st 1934 by a party member called Leonid Nikolayev (Furia 8 - 9). 5. The assassination of Kirov turned out as expected by Stalin. Whatever Stalins specific role in the assassination of his political rival Kirov, he used the murder as an alleged reason for eliminating

Sunday, September 22, 2019

Henderson The Rain King Essay Example for Free

Henderson The Rain King Essay The great book ‘Henderson the Rain King’ is a masterpiece creation of an imperative American writer who in addition became the source of inspiration for many other writers in the era of 1950s. The author, Saul Bellow’s triumph has been striking enough for he stirred other writers a new-fangled kind of idol and a new type of expressive fashion (High, 12). Bellow’s lead character lives dynamically within his own intellect. In scripting his hero, Saul Bellow has a few characteristic qualities assembled in his works. In this book he crafts a character who at all times seeks various exposures. In this paper I will discuss how Henderson has some pre-arranged stereotypes about Africa and the people there, what he learns from them in the end, how does Henderson `find` him self in Africa and will support all this with examples from the book. This book begins with a radiant portrayal, the thought of a determined victim, the personality of Henderson, and his declaration of having resolved a trouble. Henderson is actually an American hero probing toward maturity, hesitant between a desire to be loved and abandonment from a world which does not care for him as he needs; he is unripe and a victim of his own thoughts and desires. Bellow has sketched a hero who seems to be disgruntled with the truth of his existence. He is suffocating beneath the accumulative specifics of his life even though he appears to contain what people valor wish for; that is assets and position, wealth and love, as he is described by the people of his times. Many feel that the author has actually carved out a character that is none else but the author himself. Many believe that Saul had a mindset or more specifically stereotypes about Africa and its natives that he inks out through this book. In the book through satire and spoof, Bellow provides ridiculous loads of its banalities. Henderson is a mockery of the bizarre, aggressive, artist-hero of the Stephan Daedalus range. Fiddler and pig grower, he is described as a menopausal social outcast and that is what Bellow had the stereotype about the Africans (High, 33). A straight caricature of the Hemingway narcissist, he is solemn, thoughtful, solipsistic, clumsy, and self-centered. He supposes with his Eliotic fisher king forbears that the land is cursed. As Bellow had stereotyped the Africans, the hero in his book, is in reality Bellows reply to an age group of recent writers who retorted with overstated discontent to the botched assurances of Rousseauistic idealism (Ophdal, 62). It is in addition a notable investigation into the incompatible codes of maleness that bothers the contemporary American gentleman. Henderson merges the idealistic maverick, rich capitalist, rough warrior, schlemiel, unattractive American, and spiritual quester in his character of Henderson which speaks volumes about Bellow’s stereotype of the native Africans. Considerably, we find that once when he has been embraced by African classic mother-goddesses, and has taken training from a lioness, he is competent to suppress his previous aggressiveness to his housekeeper whom he has screamed to demise, his daughter whom he has overlooked, and Lily whom he has disgraced and mistreated for years (Bellow, 59). He is after everything else seen taking pride in his lately attained spiritual balance, taking on an orphan kid on the glacial ice cap of Newfoundland. As a final point, the I desire influence in his heart is at rest. Nevertheless, we are left to ponder whether he can uphold this stability found in the simple loneliness of a glacial ice cap inside the collective circumstances of his family unit. It illustrates the distinct survival wit of the Eastern European shtetl and its stereotypes. Bellow in this book claims that literary innovation has formed novels bursting of the communal disorders of our daytime and urbanized a common sense of catastrophe. Bellow, particularly in ‘Henderson The Rain King’ cultivated for American literature a few of the humorist postures, stereotypes, and mythology of Yiddish literature. His principal work of domestication of Yiddish fable is the utilization of comedy to mutually steal from self-pity and augment the actual existential problem of the hero through the wit shambling pursuit depicted in Henderson’s role (Ophdal, 77). Bowel embarks on a journey to defy racially prejudiced legends and uphold racial synchronization. Henderson commences his pursuit sharing in white prejudices against Africans. Though Bellow believed that they were just prejudices, they were deep-rooted in his opinion and tend to propose lucid ineptitude on the part of Africans (Bellow, 87). They contributed in the primitivist national troops of Africa that was suggested by Conrads Heart of Darkness. Ultimately, nevertheless, Henderson is exposed to his love of Western Civilization and takes a massive fabled jump in time. It is a three-part hunt relating sin, penance, and escape. If we analyze how Henderson evolved throughout the narration, we find that there were till the end some traces of the deep- rooted stereotypes present in his personality but as in the novel when it finally started to rain, it actually depicts that Henderson had freed himself from his thoughts and burdens of the images that he always had. It may well be that he in reality resembles other wastrels who have attempted to flee from themselves on voyages to remote places, but, for all his bristle and self-worth, all his sympathy and humbleness, all his obscure references to fine art, writing and times gone by, Henderson remains only a weary cursed with for the most part uneasy stream of fancy chatter in a store of current fiction. He is finally seen to have found peace within himself. The continuous â€Å"want† â€Å"want† screams within him that lead him to the painful journey, were in the end crushed as he contends with the surroundings and learns to accept things that he cannot change. Many readers though still question, whether a character like Henderson can stay content with the peace he found for long. The conclusion of the movements is the track in the stillness of love and decision, the agitated man, the battered animal, and the stray children who have all accomplished shared comfort and salvation.Prayers for rainfall are responded to, the impatient traveler turns in the direction of abode, and the long nights voyage finally reaches day. Works Cited Bellow, Saul (1976) Henderson the Rain King. New York: Viking Press Publishers. High, Peter (1986) An Outline of American Literature. New York: Longman Inc. Ophdal, Keith Michael (1978) The Novel of Saul Bellow: An Introduction. Pennsylvania: The Pennsylvania University Press. Majdiak, Daniel. (1991). â€Å"The Romantic Self and Henderson the Rain King† in Bucknell Review: A Scholarly Journal of Letters, Arts and Sciences.

Saturday, September 21, 2019

Coronary Heart Disease Essay Example for Free

Coronary Heart Disease Essay Coronary Heart Disease (CHD) is the leading cause of death in the United States. There are many types of heart diseases that fall into this title. Two of the most popular forms of cardiovascular diseases are heart attack and stroke. The increasing amount of exposure of known risk factors for these diseases to young adults is why I feel it is necessary to promote what it takes to lead a heart healthy lifestyle in order to avoid becoming another statistic. I feel as though I did not choose this topic as much as it chose me, as 2 years ago my Father was hospitalized and underwent a Quadruple Heart By-pass surgery in order to remove the blood clots in his 4 main arteries. Knowing that this disease is partly hereditary I feel as though it is important to educate myself and others with early intervention steps that could keep you from being affected by any heart diseases. In my research I plan to introduce how heart diseases are caused and also the best prevention techniques to ensure that the number of people affected by Coronary Heart Diseases, specifically Heart Attacks, is falling each year instead of climbing. In my research I came across an article provided by the ProQuest Research Library entitled â€Å"Coronary Heart Disease: Primary and Secondary Prevention†. This article is a published study done by The College of Pharmacy and Drug Topics of the University of Florida and discusses the many â€Å"do’s† and â€Å"don’ts† in order to lead a heart healthy life. The focus of this article is to prevent your body to become a future hot spot for a heart disease. The article counters these risk factors with ways to prevent the â€Å"modifiable factors† from occurring. The article states that risk factors are classified as modifiable or non-modifiable. â€Å"Non-modifiable risk factors include age, family history, and gender. Modifiable risk factors include smoking, diet, obesity, physical inactivity, hypertension, dyslipidemia, diabetes mellitus, and metabolic syndrome† (Brenner, Michael, and Allison Butcher). Most of these factors are obvious but some may be less known. Hypertension is the occurrence of high-blood pressure in your body, while dyslipidemia is the occurrence of high cholesterol. Diabetes mellitus can increase the risk of developing a heart disease by 2 to 4 times as likely. A second article I found through ProQuest was the scholarly journal provided by The New England Journal of Medicine titles â€Å"Cardiac rehabilitation and secondary prevention of coronary heart disease†. This article provides a more detailed look into some prevention techniques used in order to stay healthy in both the physical sense, but in the long term heart health. An idea that this article brought the table was the â€Å"Prescription of Exercise†. â€Å"Preliminary data suggest that a regimen of low-intensity, prolonged, daily exercise, called â€Å"high-caloric training† because it maximizes the expenditure of calories, results in greater fat loss and greater modification of risk factors than does a regimen of more intense but briefer exercise sessions.† (Ades, Philip A) As mentioned in the statement, maximizing the length of time that you are exercising maximizes the fat/calories being burned in your work-out. This in the long run brings my researc h back to the facts stated in my first source, which states that improving the modifiable factors like obesity and physical inactivity can greatly reduce your risk if developing a heart disease. A third article that I found through the ProQuest Research Library was a scholarly journal published by the British Medical Journal entitled â€Å"Triggering a heart attack†. This article allowed me to shine a different light on my research as it discusses momentary impacts on your heart. This article was done in response to numerous news headlines that involved fatalities due to unexpected heart attacks and strokes during a physically and/or emotionally strenuous activity. This study focused on activities like jogging, shoveling snow, and swimming that have been commonly lead to cardiac death due to vigorous physical effort. This idea relates very similarly to that of the â€Å"Prescription of Exercise† idea stated in my other source. The relation between the two stems from the idea of the less beneficial short and strenuous activities and exercise in correlation to the recommended longer low-intensity activities and exercise. This article is proving that not only are the more strenuous and shorter periods of activity less beneficial, but they can also become fatal when asking the body to do too much. Coronary Heart Disease is the leading cause of death in The United States which is why I believe that it is crucial to educate others about the many risks that factor into such a group of fatal diseases in the heart. Thru ought my research I learned that it is often the less suspecting individual that can become a victim of a Coronary Heart Disease simply because he/she did not know what steps to take to lead a heart healthy lifestyle. In order to stop the constantly rising number of fatalities caused by heart disease, we must first become educated on how to prevent them from occurring in the first place. Works Cited Ades, Philip A. Cardiac Rehabilitation and Secondary Prevention of Coronary Heart Disease. The New England journal of medicine 345.12 (2001): 892-902. ProQuest Research Library. Web. 23 Oct. 2012. Brenner, Michael, and Allison Butcher. Coronary Heart Disease: Primary and Secondary Prevention. Drug Topics 153.12 (2009): 50-9. ABI/INFORM Complete; ProQuest Research Library. Web. 25 Oct. 2012. Know Your Facts. York Weekly Record: 14. Jun 13 2006. ProQuest Research Library. Web. 23 Oct. 2012 Petch, M. C. Triggering a Heart Attack. British medical journal 312.7029 (1996): 459-. ProQuest Research Library. Web. 23 Oct. 2012. Study: Treatment Reduces Risk of Heart Attack by 70 Percent. FDA consumer 2002: 7-. ProQuest Research Library. Web. 23 Oct. 2012 .

Friday, September 20, 2019

Importance of chemical reactor

Importance of chemical reactor INTRODUCTION The most important unit operation in a chemical process is generally a chemical reactor. Chemical reactions are either exothermic (release energy) or endothermic (require energy input) and therefore require that energy either be removed or added to the reactor for a constant temperature to be maintained. Exothermic reactions are the most interesting systems to study because of potential safety problems (rapid increases in temperature, sometimes called ignition behavior) and the possibility of exotic behavior such as multiple steady-states (for the same value of the input variable there may be several possible values of the output variable). In this module we consider a perfectly mixed, continuously stirred tank reactor (CSTR), shown in Figure 1. The case of a single, first-order exothermic irreversible reaction, A > B. We will show that very interesting behavior that can arise in such a simple system. In Figure 1 we see that a fluid stream is continuously fed to the reactor and another fluid stream is continuously removed from the reactor. Since the reactor is perfectly mixed, the exit stream has the same concentration and temperature as the reactor fluid. Notice that a jacket surrounding the reactor also has feed and exit streams. The jacket is assumed to be perfectly mixed and at a lower temperature than the reactor. Energy then passes through the reactor walls into the jacket, removed the heat generated by reaction. There are many examples of reactors in industry similar to this one. Examples include various types of polymerization reactors, which produce polymers that are used in plastic products such as polystyrene coolers or plastic bottles. The industrial reactors typically have more complicated kinetics than we study in this module, but the characteristic behavior is similar. The Modeling Equations For simplicity we assume that the cooling jacket temperature can be directly manipulated, so that an energy balance around the jacket is not required. We also make the following assumptions Perfect mixing (product stream values are the same as the bulk reactor fluid) Constant volume Constant parameter values The constant volume and parameter value assumptions can easily be relaxed by the reader, for further study. Parameters and Variables A Area for heat exchange CA Concentration of A in reactor CAf Concentration of A in feed stream cp Heat capacity (energy/mass*temperature) F Volumetric flowrate (volume/time) k0 Pre-exponential factor (time-1) R Ideal gas constant (energy/mol*temperature) r Rate of reaction per unit volume (mol/volume*time) t Time T Reactor temperature Tf Feed temperature Tj Jacket temperature Tref Reference temperature U Overall heat transfer coefficient (energy/(time*area*temperature)) V Reactor volume DE Activation energy (energy/mol) (-DH) Heat of reaction (energy/mol) r Density (mass/volume) The parameters and variables that will appear in the modeling equations are listed Overall material balance The rate of accumulation of material in the reactor is equal to the rate of material in by flow-the material out by flow. Balance on Component A The balance on component A is where r is the rate of reaction per unit volume. Energy Balance The energy balance is where Tref represents an arbitrary reference temperature for enthalpy. State Variable form of Dynamic Equations We can write (1) and (2) in the following state variable form (since dV/dt = 0) where we have assumed that the volume is constant. The reaction rate per unit volume (Arrhenius expression) is where we have assumed that the reaction is first-order. Steady-State Solution The steady-state solution is obtained when dCA/dt = 0 and dT/dt = 0, that is To solve these two equations, all parameters and variables except for two (CA and T) must be specified. Given numerical values for all of the parameters and variables we can use Newtons method (chapter 3) to solve for the steady-state values of CA and T. For convenience, we use an à «sà ­ subscript to denote a steady-state value (so we solve for CAs and Ts). Dynamic Behavior We noted in the previous section that were three different steady-state solutions to the case 2 parameter set. Here we wish to study the dynamic behavior under this same parameter set. Recall that numerical integration techniques were presented in chapter 4. The m-file to integrate the modeling equations iscstr_dyn.m, shown in Appendix 2. The command to integrate the equations is [t,x] = ode45(cstr_dyn,t0,tf,x0); wheret0is the initial time (usually 0),tfis the final time,x0is the initial condition vector.tis the time vector andxis the state variable solution vector. Before performing the integration it is necessary to define the global parameter vectorCSTR_PAR. To plot only concentration or temperature as a function of time, useplot(t,x(:,1))andplot(t,x(:,2)), respectively. Initial condition 1 Here we use initial conditions that are close to the low temperature steady-state. The initial condition vector is [ conc , temp] = [9,300]. The curves plotted in Figure 2 show that the state variables converge to the low temperature steady-state. Initial condition 2 Here we use initial conditions that are close to the intermediate temperature steady-state. The initial condition vector for the solid curve in Figure 3 is [conc, temp] = [5,350], which converges to the high temperature steady-state. The initial condition vector for the dotted curve in Figure 3 is [conc, temp] = [5,325], which converges to the low temperature steady-state. If we perform many simulations with initial conditions close to the intermediate temperature steady-state, we find that the temperature always converges to either the low temperature or high temperature steady-states, but not the intermediate temperature steady-state. This indicates to us that the intermediate temperature steady-state isunstable. This will be shown clearly by the stability analysis in section 5. Initial condition 3 Here we use initial conditions that are close to the high temperature steady-state. The initial condition vector is [conc, temp] = [1,400]. The curves plotted in Figure 4 show that the state variables converge to the high temperature steady-state. In this section we have performed several simulations and presented several plots. In section 6 we will show how these solutions can be compared on the same à ¬phase planeà ® plot. Linearization of Dynamic Equations The stability of the nonlinear equations can be determined by finding the following state-space form and determining the eigenvalues of theA(state-space) matrix. The nonlinear dynamic state equations (1a) and (2a) are let the state, and input variables be defined in deviation variable form Stability Analysis Performing the linearization, we obtain the following elements forA where we define the following parameters for more compact representation From the analysis presented above, the state-space A matrix is The stability characteristics are determined by the eigenvalues ofA, which are obtained by solving det (lI-A) = 0. det (lI-A)=(l-A11)(l-A22)-A12A21 =l2-(A11+A22)l+A11A22-A12A21 =l2-(trA)l+det (A) the Eigen values are the solution to the second-order polynomial l2-(trA)l+det (A) =0(13) The stability of a particular operating point is determined by finding theAmatrix for that particular operating point, and finding the Eigen values of the A matrix. Here we show the Eigen values for each of the three case 2 steady-state operating points. Input / Output Transfer Function Analysis The input-output transfer functions can be found from G(s)=C(sI-A)-1B(14) where the elements of theBmatrix corresponding to the first input (u1 = Tj-Tjs) are the reader should find the elements of the B matrix that correspond to the second and third input variables (see exercise 8) Here we show only the transfer functions for the low temperature steady-state for case 2. The input/output transfer function relating jacket temperature to reactor concentration (state 1) is and the input/output transfer function relating jacket temperature to reactor temperature (state 2) is Notice that the transfer function for concentration is a pure second-order system (no numerator polynomial) while the transfer function for temperature has a first-order numerator and second-order denominator. This indicates that there is a greater à ¬lagà ® between jacket temperature and concentration than between jacket temperature and reactor temperature. This makes physical sense, because a change in jacket temperature must first affect the reactor temperature before affecting the reactor concentration. Phase-plane Analysis In section 4 we provided the results of a few dynamic simulations, noting that different initial conditions caused the system to converge to different steady-state operating points. In this section we construct a phase-plane plot by performing simulations for a large number of initial conditions. The phase-plane plot shown in Figure 6 was generated usingcstr_run.mandcstr.mfrom the appendix. Three steady-state values are clearly shown; 2 are stable (the high and low temperature steady-states, shown as à «oà ­), while one is unstable (the intermediate temperature steady-state, shown as à «+à ­). Notice that initial conditions of low concentration (0.5 kgmol/m3) and relatively low-to-intermediate temperatures (300 to 365 K) all converge to the low temperature steady-state. When the initial temperature is increased above 365 K, convergence to the high temperature steady-state is achieved. Now, consider initial conditions with a high concentration (9.5 kgmol/m3) and low temperature (300 to 325 K); these converge to the low temperature steady-state. Once the initial temperature is increased to above 325 K, convergence to the high temperature steady-state is achieved. Also notice that, once the initial temperature is increased to around 340 K, a very high overshoot to above 425 K occurs, before the system settles down to the high temperature steady-state. Although not shown on this phase-plane plot, higher initial temperatures can have overshoot to over 500 K before settling to the high temperature steady-state. This could cause potential safety problems if, for example, secondary decomposition reactions occur at high temperatures. The phase plane analysis then, is able to à ¬point-outà ® problem initial conditions. Also notice that no initial conditions have converged to the intermediate temperature steady-state, since it is unstable. The reader should perform an eigenvalue/eigenvector analysis for theAmatrix at each steady-state (low, intermediate and high temperature) (see exercise 3). You will find that the low, intermediate and high temperature steady-states have stable node, saddle point (unstable) and stable focus behavior (see chapter 13), respectively. It should be noted that feedback control can be used to operate at the unstable intermediate temperature steady-state. The feedback controller would measure the reactor temperature and manipulate the cooling jacket temperature (or flowrate) to maintain the intermediate temperature steady-state. Also, a feedback controller could be used to make certain that the large overshoot to high temperatures does not occur from certain initial conditions. Understanding Multiple Steady-state Behavior In previous sections we found that there were three steady-state solutions for case 2 parameters. The objective of this section is to determine how multiple steady-states might arise. Also, we show how to generate steady-state input-output curves that show, for example, how the steady-state reactor temperature varies as a function of the steady-state jacket temperature. Heat generation and heat removal curves In section 3 we used numerical methods to solve for the steady-states, by solving 2 equations with 2 unknowns. In this section we show that it is easy to reduce the 2 equations in 2 unknowns to a single equation with one unknown. This will give us physical insight about the possible occurance of multiple steady-states. Solving for Concentration of A as a function of Temperature The steady-state concentration solution (dCA/dt) = 0) for concentration is We can rearrange this equation to find the steady-state concentration for any given steady-state reactor temperature, Ts Solving for Temperature The steady-state temperature solution (dT/dt = 0) is The terms in (17) are related to the energy removed and generated. If we multiply (17) by VrCp we find that Qrem=Qgen Energy Removed by flow and heat exchange Heat Generated by reaction Note the form of Qrem Notice that this is an equation for a line, where the independent variable is reactor temperature (Ts). The slope of the line is and the intercept is. Changes in jacket or feed temperature shift the intercept, but not the slope. Changes in UA or F effect both the slope and intercept. Now, consider the Q gen term Substituting (16) into (20), we find that Equation (21) has a characteristic S shape for Q gen as a function of reactor temperature. From equation (18) we see that a steady-state solution exists when there is an intersection of the Q rem and Q gen curves. Effect of Design Parameters In Figure 6 we show different possible intersections of the heat removal and heat generation curves. If the slope of the heat removal curve is greater than the maximum slope of the heat generation curve, there is only one possible intersection (see Figure 6a). As the jacket or feed temperature is changed, the heat removal lines shifts to the left or right, so the intersection can be at a high or low temperature depending on the value of jacket or feed temperature. Notice that as long as the slope of the heat removal curve is less than the maximum slope of the heat generation curve, there will always be the possibility of three intersections (see Figure 6b) with proper adjustment of the jacket or feed temperature (intercept). If the jacket or feed temperature is changed, the removal line shifts to the right or left, where only one intersection occurs (either low or high temperature). This case is analyzed in more detail in section 7.3. Multiple Steady-State Behavior In Figure 7 we superimpose several possible linear heat removal curves with the S-shaped heat generation curve. Curve A intersects the heat generation curve at a low temperature; curve B intersects at a low temperature and is tangent at a high temperature; curve C intersects at low, intermediate and high temperatures; curve D is tangent to a low temperature and intersects at a high temperature; curve E has only a high temperature intersection. Curves A, B, C, D and E are all based on the same system parameters, except that the jacket temperature increases as we move from curve A to E (from equation (7) we see that changing the jacket temperature changes the intercept but not the slope of the heat removal curve). We can use Figure 7 to construct the steady-state input-ouput diagram shown in Figure 8, where jacket temperature is the input and reactor temperature is the output. Note that Figure 8 exhibits hysteresis behavior, which was first discussed in chapter 15. The term hysteresis is used to indicate that the behavior is different depending on the direction that the inputs are moved. For example, if we start at a low jacket temperature the reactor operates at a low temperature (point 1). As the jacket temperature is increased, the reactor temperature increases (points 2 and 3) until the low temperature limit point(point 4) is reached. If the jacket temperature is slightly increased further, the reactor temperature jumps (ignites) to a high temperature (point 8); further jacket temperature increases result in slight reactor temperature increases. Contrast the input-output behavior discussed in the previous paragraph (starting at a low jacket temperature) with that of the case of starting at a high jacket temperture. If one starts at a high jacket temperature (point 9) there is a single high reactor temperature, which decreases as the jacket temperature is decreased (points 8 and 7). As we move slighly lower than the high temperature limit point (point 6), the reactor temperature drops (also known asextinction) to a low temperature (point 2). Further decreases in jacket temperature lead to small decreases in reactor temperature. The hysteresis behavior discussed above is also known asignition-extinctionbehavior, for obvious reasons. Notice that region between points 4 and 6 appears to be unstable, because the reactor does not appear to operate in this region (at least in a steady-state sense). Physical reasoning for stability is discussed in the following section. Conclusion and future work Finally the conclusion is that a small study on the continuous stirred tank reactor and its model equation after going through we come to know its importance in the chemical engineering field and also its significance as a chemical reactor The future work is that we have to calculate and prove the equation of the continuous stirred tank reactor using Laplace transformation and check it using the MATLAB he equation of the continuous stirred tank reactor using Laplace transformation and check it using the MATLAB

Thursday, September 19, 2019

Militarism Caused WWII Essay -- World War II WWII WW2

Militarism On Sunday June 28, 1914, a member of the terrorist group The Black Hand, assassinated Archduke Franz Ferdinand. Many historians say that this event was the cause of World War I. There is also a theory that the assassination of the Archduke was only a trigger and that the war itself was caused by numerous other historical events and developments including imperialism, militarism, and alliances. Militarism was the leading factor in the outbreak of war. Militarism is the philosophy that a country’s significance is shown through its military might. Such a violent ideal promotes a unnecessarily strong military force and an aggressive demeanor while negotiating national interests. Without it the World War I would not happen on such a grand scale, if it would have happened at all. Militarism has always been present in countries around the world, but it had never become such a major force until the new Kaiser of Germany, William II, rose to power. He grew up as a cadet in Potsdam and it was there that he acquired a fondness for military pomp. While receiving his education, instead of insight and wisdom, it filled him with bigoted and absurdly romantic notions of war (Schulezed et al 69). Although Bismark, the previous prime minister, dismissed the new youthful Kaiser, he was forced out of power, marking the turning point of when German militarism moved to a forefront and became the ideal of the nation, and all rational calculations were put on the back burner (Schulezed et al 70). When Germany began to build its army, there was no going back. The Social Democratic Party, the main political party at the time, was unsuccessful in opposing naval growth because military provided the working class with tens of thousands o... ...l in times of peace. He argued that military elites had too much power in European countries and World War I was a consequence of their desire for the military power and disdain of democracy. He supported the removal of rulers such as Wilhelm II, an end to aristocracy, and militarism in any shape or form. Unfortunately his ideas were implemented only after the world suffered through the second World War when history had repeated itself without anyone learning their lesson. Bibliography â€Å"Naval Rivalry.† Europe. 3rd ed. 5 vols. Beresford, Charles W., Volker R. Berghahn, Herwig H. Holger, Lambert A. Nicholas, Arthur J. Marder, Jon T. Sumida, and Lawrence Sondhaus. Farmington Hills: Tomson Gale, 2006 Schulze, Hagen. German - A New History. Massachusette: Harvard University Press, 1998. Stratachn, Hew. The First World War. New York: Penguin Group, 2004

Wednesday, September 18, 2019

Relational Database Model :: essays research papers

Comparing and Contrasting the Relational Database Model and OO Model The relational database model is based upon tables or relations. In this model, the physical implementation of the database is abstracted away from the user. Users query the database using a high-level query language, such as SQL. The relations are made up of columns, which have headings indicating the attribute represented by that column. Tables have key fields, which can be used to identify unique records. Keys relate tables to each other. The rows of the relation are also called tuples, and there is one tuple component for each attribute – or column – in that relation. A relation or table name, along with those relation’s attributes, make up the relational schema. Relational Database models are server-centric.   Ã‚  Ã‚  Ã‚  Ã‚  When designing a Relational Database, you must create a table for each entity type, choose or invent a primary key for each table; add foreign keys to represent one-to-many relationships; create new tables to represent many-to-many relationships; define referential integrity constraints; evaluate schema quality and make necessary improvements; and choose appropriate data types and value restrictions for each field (if necessary).   Ã‚  Ã‚  Ã‚  Ã‚  The real power of relational systems lies in the ability to perform complex queries over the data. Relational systems are well understood, and can be highly optimized in terms of queries, scalability, and storage. There is a uniqueness of table rows and primary keys, as well as ease of implementing future data model changes – flexibility and maintainability. To build an effective and efficient application in the relational model, the developer must have a comprehensive knowledge of the tables, and any relationships among them.   Ã‚  Ã‚  Ã‚  Ã‚  Object oriented database management systems are viewed as an alternative approach to meeting the demands of more complex data types. The need to handle complex object-centric data as the main data element is the driving force behind Object Oriented database models. These systems attempt to extend Object Oriented programming languages, techniques, and tools to provide a means to support data management tasks. Object Oriented models are client centric. Object Oriented databases uses attributes containing object identifiers to find objects that are related to other objects.   Ã‚  Ã‚  Ã‚  Ã‚  When designing an Object Oriented model, you must first determine which classes require persistent storage; define persistent classes; represent relationships among persistent classes; and choose appropriate data types and value restrictions for each field.   Ã‚  Ã‚  Ã‚  Ã‚  Object Oriented database models approach from the opposite direction (a programming language itself) to solve the problem of handling complex data types.

Tuesday, September 17, 2019

Kafka

This simple yet ingenious quote by Kafka does make one stop and think, is life really that meaningless? How can one concur if life is meaningless or not? Before these questions can be answered, one must ask, what is meaning? Amazingly enough, meaning is something we create ourselves. We attach meaning to everything around us whether it be language, a person, an item, or even a pencil.Meaning comes from within us, making us the sole contributor to our own existence. Therefore, nothing has meaning unless one was to ttach meaning to it, and to attach meaning to anything proves one has created an identity, and that identity allows one to exist. Mortal life by definition comes to an end whether one likes it or not, and because of this, we are always facing the pressure of extinction. The way we cope with this pressure is by giving meaning to the things we do, the things we love, and all the other things which matters in ones life.To give ourselves an identity in which we exist in this wor ld and to leave behind a trace of our existence. Although it is truly evident that meaning comes from within the individual, others might think differently. One of the main arguments against meaning coming from the individual is that we were already given meaning since birth, given a set of beliefs and morals to follow, so how does one create meaning if it was already given to us from generation through generation?What they do not know is that meaning is something we gain through experience, and experience is not something we have from birth. Another valid argument would be that this universe does not need meaning and therefore it is not important to have meaning or create meaning. However, meaning is all around us and whether one likes it or not, we were built to reate meaning in order for us to exist, and for us to be able to create an identity. Before we dive deeper into the topic of how we gain meaning, we first have to question what is meaning?Clare Carlisle quotes Kierkegaard and explains, â€Å"Even though all sorts of things exist, for Kierkegaard the word â€Å"existence† has a special meaning when applied to human life. This meaning arises from the fact that we always have a relationship to ourselves. † (Carlisle, What does it mean to exist? ) To go into more thorough detail, meaning is the stem of everything human. Meaning come rom us because like stated above in the quote by Kierkegaard, we are the only ones can have a relationship to ourselves.Humans only truly exist through identity, identity is gained through experience, and experience is what use to create meaning. Many other individuals would like to believe that meaning does not come within us, but rather given to us, passed down to us from our past generations. For an example, Annie Druyan, wife of astronomer/philosopher Carl Sagan (1934 – 1996) remembered a conversation her husband had with a young man and it goes, â€Å"At the end of it, a young man came up to him and he said: What do you give us in return? Now that you've taken everything from us?What meaning is left, if everything that I've been taught since I was a child turns out to be untrue? Carl looked at him and said, ‘Do something meaningtul. ‘ † (Sagan. ) Without meaning this world would b complete chaos. A person needs to grow up with meaning as a supporting factor, or else their world would become chaotic and by definition, meaningless. The young man in the flashback is a person who struggles with the belief that he grew up with meaning given to him and therefore once he comprehend the truth and reality of it all, there would be no significance left.Carl Sagan tries to make this young man understand that in truth, meaning is something we can create anytime, anywhere, and anyplace. Sagan's simple and brief quote ‘Do something meaningful' gives us hope because it illustrates that meaning does not stem from the beginning of our lives, but something we have to exp erience and something we have to do in order to gain meaning. Although there are many others out there like the young man depicted in Annie Druyan's flashback, they would have to know that meaning is not something in which they are given, but is gained through their Journey and understanding of life.This is significant because it is imperative for ones knowledge to understand that no matter how lost or confused one might be, they could always create their own meaning instead of relying or is biased on the thought that meaning was created for us. If one was to be biased on that thought, their total reliance on the meaning at which was given to them would collapse when they learn the undeniable truth that meaning has always been within their reach. Although meaning is a controversial and conflicting topic to discuss, some might argue that meaning is something we shouldn't try to understand at all.Alex Percival as a strong opinion towards meaning and how he believes the universe does n ot need meaning at all. He states in his own words, â€Å"With modern discoveries, we have found that the meaning of life itself is pointless, but we are extremely lucky to be here because the probability that any one of us being in existence is next to 0%. † (Percival. ) In truth, meaning does matter in this world that we live in. Without meaning we would be lost with no identity, and would have no proof of our own existence.It is important for humans to make meaning for themselves because we want to exist and therefore we should exist. Meaning is not pointless at all, in fact meaning is apart of ones soul, apart of us. Meaning is a tool we strive and depend on to survive, because without it we would feel worthless and needless to say, useless. Despite the many oppositions against the interpretation of meaning, language is one of the many factors in which humans attach meaning to. One blogger give their thoughts on how meaning relates to language and states, â€Å"Language communicates meaning, and the origin of meaning is relationship.In fact; if we use the idea that â€Å"relationship is the origin of meaning† as our lens, it opens up a whole new world eyond the narrow definitions that confine meaning to traditional ideas of language. † (The Wisdom of Life. ) Language in fact does relate to human relationships. To be able to communicate and articulate our thoughts gives us meaning. Without language, humans would not be able to express their thoughts and empty their minds and this is an important process to meaning because how can one attach or create meaning if they cannot express themselves.It is crucial to understand that language does not get it's meaning from others but it is something we attach to it. For n example, as Professor Jacoby has mentioned in class, â€Å"A chair does not have meaning unless we give it meaning. The word chair to another person could mean something much more significant or it could mean nothing depending who this person is and what significant attachment they have given to the chair. † (English 205 Lecture. ) Anyone can give meaning to anything as long as there is a special significance to it.This is how we gain existence and gain identity. It comes through our experience and how we see things in our own eyes and not through what has already been defined for us. When one speaks about language, often we question what is the significance of many languages in this world. As Noam Chomsky says in We Still Live Here, â€Å"A language is not Just words. It's a culture, a tradition, a unification of a community, a whole history that creates what a community is. It's all embodied in a language. † (Chomsky. Language is no longer Just words or different types of languages that people speak around the world, it is what set us apart from others. It is what defines us as a people, it gives us meaning. With many languages around the orld, one could feel lost or troubled because they a re afraid they could lose their identity. Although that is definitely not the case, language could preserve ones true identity because with language comes a culture, a tradition, a community, and a whole history. With all these factors combined, one can find their identity and create meaning to their lives in their own ways and form.To find ones own identity is truly important in terms of existence, and the only way to find ones identity is through finding meaning within themselves. Meaning also attaches itself to forms of exceptionalism, how we interpret and ruly follow this ideal belief is entirely up to the person. In one article by The Globalist, they proclaim, â€Å"And Americans can only be exceptional if we are well informed and willing to make hard choices and take risks. Apathy, ignorance and risk aversion are the death sentence of the American experiment. (The Globalist, The Idea of American Exceptionalism. ) This is not only true to Americans, but also other cultures aro und the world as well. To make one self â€Å"exceptional† the person needs to be able to make well informed decisions on their own accord and take risks by the ips of the their own fingers. This connects to meaning because the only way we can make our own decisions and take our own risks is by attaching our own meaning to what all of these things mean. To be exceptional does not necessarily translate to ignorance, it could also mean it is their only form of survival.To any culture around the world, their identity is found through their culture, history, tradition. They rely on these factors because it is what makes them special, unique, and superior from others. Just like how each of them have their own language, tradition, and beliefs, hey want to preserve this by giving it a name, American Exceptionalism, British Exceptionalism, and Greek Exceptionalism. This way, they have given meaning to these terms which in return protect their identities. As individuals we all have a specific responsibility to be fulfilled once we take our first breaths in this world.One specific sentence which caught my attention in the article by The Globalist was, â€Å"As citizens, we have a sacred duty to conserve government by the active † not passive † consent of the governed. † (The Globalist, The Idea of American Exceptionalism. Even if we are a citizen of American or not, it does not matter, because every human in this Earth has a specific duty, which is to do something meaningful so that can be remembered for what theyVe done. The government is depicted as powertul, and because we see them as powertul, we believe that meaning comes from the government.The governments rules and laws seem to constrain us, but in reality it's constrictions is what tests our understanding of what meaning is. For an example, in The Trial, a relatable quote from the conversation between K. and the doorkeeper goes as this, â€Å"Everyone strives to reach he Law,† sa ys the man, â€Å"so how does it happen that for all these many years no one but myself has ever begged for admit-tance? † The doorkeeper recognizes that the man has reached his end, and to let his failing senses catch the words roars in his ear: â€Å"No one else could ever be admitted here, since this gate was made only for you.I am now going to shut it. † (Kafka 256. ) In The Trial, it is Kafka's intentions to make the court look so powerful, because in this way, K. is forced to look for meaning and search for his own identity instead of trying to search for significant meaning in others. In fact, the court is so powerful that they have already planned everything out for K. K. ‘s future was in their hands and yet he barely even realized this because he was transfixed on trying to get everyone else to help him when the answers was within him.This message is of vital importance to comprehend, because one must know that no matter how powerful the barrier maybe be tween the person and their journey to gain meaning is, their duty as a human allows them to conquer those obstacles and face their own challenges. In The Trial it is evident from the very beginning K. ‘s thoughts were always ethered to what others thought about him and his need to find meaning through them instead of himself. Whenever K. spoke, he would always pay close attention to others, as though their opinions and thoughts were crucial to him, † ‘Intrusive, thoughtless people! ‘ said K. s he turned back into the room. The supervisor may have agreed with him, at least K. thought that was what he saw from the corner of his eye. But it was Just as possible that he had not even been listening as he had his hand pressed firmly down on the table and seemed to be comparing the length of his fingers. † (Kafka 17. Throughout the Trial, K. is repeatedly focusing on what others think of him, how others does not give him attention, and how others gave him mean ing. His mind was constantly affected by the whispers around him and it affected him to the point whereby he was utterly dependent on other people.Kafka's mission was to make us understand that K. was trapped in the wrong place the whole time, in someone else's mind. When a person is trapped in someone else's thoughts, it would be hard for them to understand how important meaning is if they are constantly looking for meaning in the wrong place. One of the great meanings behind Kafka's works was to question one specific word, â€Å"Meaning. † In the text, K. ‘s conversation with the Priest demonstrates how Kafka views the word meaning, miou look for too much help from people you don't know,† said the priest disapprovingly, â€Å"and especially from women.Can you really not see that's not the help you need? † (Kafka 252. ) Kafka used K. as a guide to help him search for or make meaning. K. is constantly seeking and depending on others to be able to survive an d to exist in this world that the meaning to his life soon became xactly that; his reliance on others became his meaning of survival, to exist. Kafka wants us to know that meaning was not already given to us, but we make meaning. We give meaning to people, things, and everything around us so we can feel special, unique, and most importantly to teel I ike we exist.Katka also wants us to know that K was looking for meaning in all the wrong places and to learn from K. ‘s mistakes. K. looked for meaning through his reliance on others, when he was supposed to create meaning within himself. To exist, we first have to rely on our own thoughts and our own ideas. This significant because our thoughts and our own ideas is how meaning is created. If we do not create meaning through our own minds, we do not exist according to Kafka, and that is why K. ies (Kafka 271) at the end because he was not able to realize his whole life depended on someone else, and his sense of meaning came from t he people around him as well which is what makes one exist. Although, this leads to the quote which was stated in the beginning of the essay, â€Å"The meaning of life is that it ends. â€Å"-Franz Kafka. No matter how a person tries define meaning or try to apprehend it, life does end. So why is meaning so important? Meaning not only gives us a sense of security and comfort from the chaotic world we live in, but it also serves as a backbone to our identity and our existence.By us giving meaning to anything and everything, it gives us a sense of comfort knowing that it is significant or in some ways meaningful to us therefore making us feel as though we exist because we gave meaning to something which never had meaning before it came into our lives. To exist, to give meaning, and to gain an identity is all part of what it means to be human. Meaning nowadays is interpreted in many different ways, but one theory seems to tand out more than the rest, and it's that meaning comes from within each individual and not from an external source.We use meaning to create ourselves, find our identities, and sustain our existence through our lifetime. In these modern times, the word meaning has been modified to each persons own interpretations of what meaning is. The problem is, would meaning ever be completely defined? Or is it a word that us humans can attach our own meaning to? It is definitely something to think about as we progress further into the world of constant change and start to lose the roots of our identity and even our existence.

Monday, September 16, 2019

Administrative Law Rev Essay

Freedom of Information Act 1982 is entirely in the interest of public who can have access to various documents of government of Victoria and its public agencies for verification or for any other useful purpose.   The sole objective of FOI Act is to bring awareness among public whether the functioning and operations of government are in order   and how public analyze the same. Section 22 provides about the charges to be paid for having access to specific documents.   The section provides technical details of payment of fee that is calculated with time that is taken for search of documents.   This is particularly due to the fact that   the time taken for search of documents may vary depending on the date of publication of document. This is also in order to reduce the payment of fee to be paid by public.   All sectors of public may not afford to pay high rate of fees for having access to government documents.   In view of such as these reasons, hourly rate and time taken for search of documents has been included in this section. The section also covers transcription (h)   and routine requests (g)   and in case of inspection of documents no charge shall be calculated (f) in pursuance of Section 8(1) or 11(1). Section 27 clearly states about reasons of refusal of documents by a Minister of state to that effect, applicant shall be informed about the reasons in writing.   This section is somewhat complicated with the fact that a minister or a government official is a servant of public and with that motive, public must be provided access to the documents which is the sole purpose of FOI Act. This section is likely to give rise to conflicts between and may bring a deep dissatisfaction to public. Some of the documents that contain health information are also restricted with the provisions of Health   Records Act 2001, which of these reasons are also to be stated to applicant.   Although there are clauses for applying of review of decisions, launch complain to Ombudsmen, it is both time consuming and   undecisive for applicants to move further with such grievances. Section 50 deals with applications for review which would be pending with Tribunal for decisions.   This may pertain to a request for document, charge made, decision for access, or any other specific request regarding information under FOI Act.  Ã‚  Ã‚   The Tribunal in all respects has to deal with each individual case, giving its due importance of provisions along with genuine reasons. This section is in favor of public, as Tribunal shall reconsiders and reviews the decisions and grants permissions to public in various aspects that are relevant to FOI Act. The Tribunal may refuse the decision of Minister or agency and give an order in favor of public. Those issues or requests for documents which were not considered by Minister, are very well resolved at Tribunal by applicants. Section 51 states that an applicant may apply to Principal officer or Minister for review of decision, which was given in the deemed absence within 28 days   for review of decision or refusing to give access to health documents as per Section 36 of Health Records Act 2001. This section offers powers and opportunities to public   for   reconsideration of requests for having access to documents.   Applicants have to be excessively vigilant in deriving the maximum benefit from the government bodies and officials.  Ã‚  Ã‚   This section is both useful for public and for principal officers to check the veracity of facts in all respects. Section 51A  Ã‚  Ã‚   deals with conciliation of Health Service Commissioner   which state that issues that were deferring in Section 50 and 51 in the matters of health documents, may suitably be taken up by applicant with this section and apply for Health Service Commissioner’s decision.   In case Health Service Commissioner fails to conciliate a request, to that effect an notice in writing must be issued to both applicant and Principal Officer. This appears as a last resort for applicant as the decision of Health Service Commissioner is the final approach for an applicant. Conclusion The enactment of FOI is made with a view of regularizing the functioning and to increase the   working efficiency of governments.   Apart from this fact, the public are also provided an in-depth knowledge about information and working status of governments. Although there are many technicalities involved in FOI Act, each section, sub-section and clause, a significance of reason is attached to it for the benefit of both public and governing bodies.

Sunday, September 15, 2019

Mt 355 Unit 2

Kinshasa Abroad – African Cuisine and Culture Jennifer Johnson MT/355 – Marketing Research Theodore Alex 5/1/2012 Introduction The purpose of this paper is to refer to the case Kinshasa Abroad – African Cuisine and Culture, define the problems that appear regarding this case, and trying to find answers and solutions to these problems. As it can be noticed in the case, there are marketing problems regarding this business. There are two questions that need to be addressed.The first question is about the type of information that needs to be collected to help diagnose the marketing problem in this case. The second question, however, it is interesting because it asks to create a list of probing questions that should be asked the owner of the restaurant to help him specify research problems and also the manager’s decision problem. Kinshasa Abroad The case goes this way. Youlou Kabasella is an African entrepreneur that had a business running in his own country.It was a restaurant that was opened for more that 14 years. However, since the political context was not advantageous, the owner decided to move with his family in the United States. He manages to open the same business he had in his home country, in the downtown area of Columbus, Ohio. However, the strategy chosen by the entrepreneur with respect to his business may not be appropriate since it does not show any positive results. He considered keeping most of the aspects of his business similar to his home country.The paper tries to identify the problem and spot certain solutions through marketing research. Before getting deeper into this concept, the term marketing research must be defined. According to Churchill, Brown, and Suter (2008), marketing research represents the function that connects the consumers to the marketer through information that is used in identifying and defining marketing problems and also opportunities. Marketing research helps generating, refining, and valuati ng marketing actions; it helps monitoring performance and it enhances the understanding of marketing as a complete process. A research consultant requires various valuable data from Mr. Kabasella to identify the problem of his inefficiency. At first, a marketing consultant would require Kabasella information about his advertising and promotion practices, about the local customer preferences and habits, precise information about the prices and his menu and business activities, and other information as well.Here is a list of questions that a marketing consultant addresses Kabasella to help him with his business problems: 1. How come most of your products are African based? 2. Why did you choose to advertise without using the most important advertising mean which is the Internet? 3. Did you consider doing a marketing analysis to determine your potential competition in this area? 4. Did you consider offering free meals or other points of attraction to try and increase the number of cust omers? 5. Did you consider selling more local products?Conclusion These from above are only few of the potential questions that a marketing researcher needs to ask the employer to help him with his problems. The marketing researcher needs to focus identifying the competition for this company; it also needs to focus on advertisements and promotion to include the company in the list of the customers. The will have to find the proper marketing mix, which refers to product, place, price, and promotion (the four Ps of marketing) to help the company become more efficient and profitable.It clearly needs to add more local meals and drinks to its menu; it needs to use and promote local bands in the restaurant because clients would come and serve meals that they are aware of (at first), and then they may try to choose the African specialties. There are many elements to be considered; the solution to this case is not difficult to be identified and implemented. Reference Churchill, G. A. , Brow n, T. J. , & Suter, T. A. (2008). Basic Marketing Research (7th Ed. ). Cengage Learning.

Saturday, September 14, 2019

Public Ruling

INLAND REVENUE BOARD MALAYSIA INCOME FROM LETTING OF REAL PROPERTY PUBLIC RULING NO. 4/2011 Translation from the original Bahasa Malaysia text DATE OF ISSUE: 10 MARCH 2011 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA CONTENTS 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 11. 14.Introduction Related provisions Interpretation Letting of real property as a business source Letting of real property as a non-business source Commencement date of letting of property All real properties grouped as a single source Expense relating to income of letting of real property Rental income received in advance Capital allowance Industrial building allowance Replacement cost of furnishings Letting of part of building used in the business Effective Date Page 1 1 1 1-4 4-5 5-7 7 – 13 13 – 19 19 – 22 22 – 25 26 26 26 26DIRECTOR GENERAL'S PUBLIC RULING A Public Ruling as provided for under section 138A of the In come Tax Act 1967 is issued for the purpose of providing guidance for the public and officers of the Inland Revenue Board Malaysia. It sets out the interpretation of the Director General of Inland Revenue in respect of the particular tax law, and the policy and procedure that are to be applied. A Public Ruling may be withdrawn, either wholly or in part, by notice of withdrawal or by publication of a new ruling which is inconsistent with it.Director General of Inland Revenue, Inland Revenue Board Malaysia. INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 1. This Ruling explains: (a) (b) Letting of real property as a business source under paragraph 4(a) of the Income Tax Act 1967 (ITA); and Letting of real property as a non-business source under paragraph 4(d) of the ITA. 2. The provisions of the ITA related to this Ruling are paragraphs 4(a) and 4(d), subsections 33(1) and 39(1). The words used in this Ruling hav e the following meaning: 3. â€Å"Arm's length basis† refers to the circumstances, decisions or outcomes that would have been arrived at if unrelated or unconnected persons were to deal with each other wholly independently and out of reach of personal influence . â€Å"Real property† includes any land and any interest, option or other right in or over such land and includes any building on land. â€Å"Person† includes a company, a co-operative society, a partnership, a club, an association, a Hindu joint family, a trust, an estate under administration and an individual, but excludes a unit trust. Letting of real property† means granting the use of a real property or occupation of a real property under an agreement or a term of contract and includes the letting out of part of the real property that is owned or rented. â€Å"Management corporation† means a management corporation established under the Strata Titles Act 1985 (Act 318), the Land (Subsidi ary Title) Enactment 1972 (Sabah No. 9 of 1972) or the Strata Titles Ordinance 1995 (Laws of Sarawak, Chapter 18). Rent† or â€Å"rental income† or â€Å"income from letting† includes any amount received for the use or occupation of any real property or part thereof including premiums and other receipt in connection with the use or occupation of the real property. â€Å"Related company† means the situation where one company holds not less than 20% of the ordinary shares or preference shares of the other. 3. 3. 2 3. 3 3. 4 3. 5 3. 6 3. 7 4. Letting of real property as a business source 4. 1 Letting of real property is deemed as a business source and the income received from it is charged to tax under paragraph 4(a) of the ITA ifIssue: B Page 1 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA maintenance services or support services are provided in relation to the real property. 4. 2 Maintenance services or support services should be comprehensively and actively provided. 4. 2. 1 Maintenance services or support services comprehensively provided means services which include: (a) doing generally all things necessary (eg. leaning services or repairs) for the maintenance and management of the real property such as the structural elements of the building, stairways, fire escapes, entrances and exits, lobbies, corridors, lifts/escalators, compounds, drains, water tanks, sewers, pipes, wires, cables or other fixtures and fittings; and doing generally all things necessary for the maintenance and management of the exterior parts of the real property such as playing fields, recreational areas, driveways, car parks, open spaces, landscape areas, walls and fences, exterior lighting or other external fixtures and fittings; or b) If a person only provides security services or other facilities, that person is not providing maintenance services or support services comprehens ively. 4. 2. 2 Services actively provided means the person who owns or lets out the real property: (a) (b) provides himself; or hires another person or another firm to provide the maintenance services or support services as mentioned under paragraph 4. 2. 1 of this Ruling. Example 1: Suai Sdn Bhd owns three blocks of condominium consisting of 324 units and lets out those units to tenants.Suai Sdn Bhd provides maintenance services of lift, cleaning services, security services, centralized air conditioner and maintenance services of playing fields and car parks. The letting of the condominium units is treated as a business source of Suai Sdn Bhd since maintenance services and support services are comprehensively and actively provided by Suai Sdn Bhd. Issue: B Page 2 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Example 2: Wahida owns a 4-storey building consisting of 32 units that can be used as offices a nd shop lots.All the units are let out to several tenants. Wahida hires Ali Enterprise to provide maintenance services of the structure of the building, maintenance of lift and cleaning services of the building and area outside the building. The letting of the units in the building is treated as a business source of Wahida since maintenance services and support services are comprehensively and actively provided by Wahida. Example 3: Yes Property Sdn Bhd rents one block of office building consisting of 42 units from Zura Sdn Bhd. All the units are let out to a few tenants.Yes Property Sdn Bhd provides cleaning services of the building and area outside the building, centralized air conditioner, maintenance of car park and security services. The letting of the office units is treated as a business source of Yes Property Sdn Bhd since maintenance services and support services are comprehensively and actively provided by Yes Property Sdn Bhd. 4. 3 As long as maintenance services or suppo rt services are comprehensively and actively provided in relation to the real property which is let out, the letting is a business source under paragraph 4(a) of the ITA even though the letting is between related parties.However, if rental charged to the tenant is not at arm’s length basis, the Inland Revenue Board Malaysia would adjust the rental payment accordingly. For the purpose of this Ruling, â€Å"related parties† in relation to: (a) (b) (c) individuals, mean both individuals are related; companies, mean both companies are related companies; a company and an individual, mean one of the parties is in a position to influence or be influenced by the other party, or to control or be controlled by the other party. . 4 Special treatment for letting of a building to an approved Multimedia Super Corridor (MSC) status company Under the Income Tax (Industrial Building Allowance) (Approved Multimedia Super Corridor (MSC) Status Company) Rules 2006 [P. U. (A) 202/2006], ef fective from the year of assessment 2006, the letting of building in the Issue: B Page 3 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIACyberjaya Flagship Zone to an approved MSC status company is regarded as carrying on a business and the income received from it is charged to tax under paragraph 4(a) of the ITA. The building let out: has to be a new building that provides a world-class physical and information infrastructure as determined by the Multimedia Development Corporation Sdn Bhd; must not have been occupied by any company prior to the year of assessment 2006; and does not include building for the purpose of living accommodation. 5. Letting of real property as a non-business source 5. The letting of real property is treated as a non-business source and income received from it is charged to tax under paragraph 4(d) of the ITA if a person lets out the real property without providing maintenance ser vices or support services comprehensively and actively. Example 4: Unggas Property Sdn Bhd lets out one block of office building to a company. Unggas Property Sdn Bhd only provides security services. The letting of the office building is treated as non-business source since Unggas Property only provides security services.Unggas Property Sdn Bhd does not provide maintenance services or support services comprehensively. Example 5: Azran Sdn Bhd lets out a 5-storey building to Aloy Sdn Bhd without providing any maintenance services or support services. The letting of the building is a non-business source since there are no maintenance services or support services provided by Azran Sdn Bhd. Income received from the letting is charged to tax as rental income under paragraph 4(d) of the ITA. Example 6: Facts are the same as in example 3 but maintenance services and support services are provided by Zura Property Sdn Bhd.The letting of the office units is treated as a non-business source of Yes Property Sdn Bhd since maintenance services and support services are not provided by Yes Property Sdn Bhd but are provided by Zura Sdn Bhd. Issue: B Page 4 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 5. 2 The letting of real property is also treated as a non-business source if a person lets out the real property and maintenance services or support services are passively derived from the ownership of the real property.Income received from the letting of the real property is charged to tax as rental income under paragraph 4(d) of the ITA. Example 7: Azrie owns 2 units of apartment and lets out those units to 2 tenants. The tenants are entitled to use the swimming pool, tennis court and other facilities that are provided in the apartment. All the facilities are provided and maintained by the management corporation of the apartment. Azrie only pays maintenance fees to the management corporation of th e apartment. Services enjoyed by the tenants are merely an extension of Azrie’s right as proprietor of the apartment units and are not actively provided by Azrie.Therefore, the letting of the apartment units is a non-business source and the income received from it is charged to tax as rental income under paragraph 4(d) of the ITA. 6. Commencement date of letting of real property 6. 1 The date of commencement of letting of real property treated as a source of rental income under paragraph 4(d) of the ITA is on the date the real property is rented out for the first time. Example 8: Nora buys one unit of apartment on 1. 10. 2009. She renovates and advertises the letting of the apartment on 1. 1. 2010. The apartment is only let out on 1. . 2010. The letting of the apartment commences on 1. 7. 2010 i. e on the date it is rented out for the first time. 6. 2 The date of commencement of letting of real property treated as a business source under paragraph 4(a) of the ITA is on the da te the real property is made available for letting. A real property is made available for letting when the real property is ready to be occupied by tenants and steps to let out the real property have been taken such as advertising the real property for letting or appointing a real property agent to facilitate the letting.Example 9: Muhibbah Sdn Bhd purchases a 12-storey office building on 1. 1. 2010. The company advertises the letting of that building on 1. 4. 2010. The Company provides maintenance services of lift, cleaning services of the building and Issue: B Page 5 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA area outside the building, maintenance services of car park for that building and centralized air conditioner. The building is made available for letting on 1. 6. 2010 after renovation is completed. The building is only let out on 1. 8. 010. The company closes its account on 31 December every year. The letting of the building commences on 1. 6. 2010 i. e on the date the building is made available for letting. Example 10: Facts are the same as in example 9 but the building is only let out on 1. 1. 2011. The letting of the building commences on 1. 6. 2010 that is on the date the building is available for letting. Therefore expenses incurred in the production of rental income for the year of assessment 2010 are allowable and can be carried forward to the year of assessment 2011 (assuming that the company only has this rental business income).However advertisement expenses incurred on 1. 4. 2010 are not allowable since the expenses are incurred to obtain the first tenant. Example 11: Syazril Property Sdn Bhd owns a complex consisting of an office building in Block A and a shopping centre in Block B. The company provides comprehensively and actively maintenance services and support services in relation to the complex. The company advertises the letting of that complex on 1. 6 . 2010. The office building in Block A is made available for letting and is let out on the same date i. 1. 7. 2010. Whereas the shopping centre in Block B is made available for letting on 1. 1. 2011 but is only let out on 1. 2. 2011. The company closes its account on 31 December every year. The letting of the office building commences on 1. 7. 2010. Whereas the letting of the shopping complex commences on 1. 1. 2011 i. e on the date it is made available for letting. Example 12: Kengo Sdn Bhd purchases a 10-storey office building in Kuala Lumpur, a shopping complex in Johor Bahru and 5 units of shop house in Kota Bharu in the year 2010.Both buildings in Kuala Lumpur and Johor Bahru are let out and maintenance services and support services are comprehensively and actively provided in relation to those buildings. Whereas the shop houses are let out without maintenance services and support services. The date of advertisement, the date the real properties are made available for letting a nd the real properties are let out are as follows: Issue: B Page 6 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 Advertisement date 1. . 2010 1. 8. 2010 1. 9. 2010 Date available for letting 1. 9. 2010 1. 11. 2010 1. 11. 2010 Date of letting 1. 12. 2010 1. 1. 2011 1. 2. 2011 INLAND REVENUE BOARD MALAYSIA Real property Building in Kuala Lumpur Building in Johor Bahru Shop houses in Kota Bharu The commencement date of letting of the building is as follows: Real properties Rental business [paragraph 4(a)] Building in Kuala Lumpur Building in Johor Bahru Rental [paragraph 4(d)] Shop houses in Kota Bharu 7. All real properties grouped as a single source 7. Several real properties which are let out can be grouped as one source whether as a business source under paragraph 4(a) of the ITA or a nonbusiness source under paragraph 4(d) of the ITA. If a person lets out several real properties in a year of assessment and the letting of (a) (b) a ll real properties is a business source, all the real properties can be grouped as one business source under paragraph 4(a) of the ITA. all real properties is a non-business source, all the real properties can be grouped as one non-business source under paragraph 4(d) of the ITA. ome of the real properties is a business source and some is a nonbusiness source, income from both sources shall be assessed separately. The income from the business source and the nonbusiness source is assessed under paragraphs 4(a) and 4(d) of the ITA respectively. 1. 2. 2011 1. 9. 2010 1. 11. 2010 Date of commencement of letting (c) Issue: B Page 7 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Example 13: AJ Sdn Bhd owns a 4-storey building in Damansara and a 6-storey building in Bangsar.Both buildings are let out since 2008 and the letting of the buildings is treated as a business source under paragraph 4(a) of the ITA. The gross income, allowable expenses and capital allowances on the furniture in each building for the year of assessment 2010 are as follows: Real property Gross income (RM) 60,000 10,000 70,000 Allowable expenses (RM) 14,000 12,000 26,000 Capital allowances (furniture) (RM) 7,000 3,000 10,000 Building in Damansara Building in Bangsar Total The letting of both real properties is a business source.Therefore, both real properties can be grouped as one business source under paragraph 4(a) of the ITA. The statutory income of AJ Sdn Bhd from the business of letting of real property for the year of assessment 2010 is calculated as follows: (RM) Gross income from rental Less: Allowable expenses Adjusted income Less: Capital allowances (furniture) Statutory income from rental Example 14: Margaret owns several real properties which are let out since 2008 and the letting of the real properties is a non-business source under paragraph 4(d) of the ITA.The gross income and allowable expenses for ea ch real property for the year of assessment 2010 are as follows: 70,000 26,000 44,000 10,000 34,000 Issue: B Page 8 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 Gross income (RM) 12,000 9,000 24,000 1,500 46,500 Allowable expenses (RM) 3,000 11,000 8,000 1,800 23,800 INLAND REVENUE BOARD MALAYSIA Real property Terrace house Apartment Shop house Vacant land TotalStatutory income of Margaret from the letting of real property for the year of assessment 2010 is calculated as follows: (RM) Gross income from rental Less: Allowable expenses Statutory income from rental Example 15: Theodore Lim buys an office building and a business building in Taman Anggerik, Ampang in August 2009. The purchases of both buildings are financed by a bank loan. The office building is rented out commencing from 1. 1. 2010 whereas the business building is only rented out on 1. 2. 2011. Income from the letting of both buildings is assessed as a business source under paragraph 4(a) of the ITA.The gross income and interest expense on loan for each building for the years of assessment 2010 and 2011 are as follows: Gross income (RM) Year of assessment 2010 Office building Business building 120,000 Year of assessment 2011 120,000 165,000 Interest expense (RM) Year of assessment 2010 45,000 55,000 Year of assessment 2011 40,000 50,000 46,500 23,800 22,700 Real property Issue: B Page 9 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIAIn the year of assessment 2010, the business building has not commenced as a source because no income has been generated yet. As such, the business building and office building cannot be aggregated as one source. Interest expense in relation to the business building amounting to RM55,000 is not allowed a deduction against the gross income from the letting of office building. The statutory income from rent for the year of assessment 2010 is computed as follows: (RM) Gross income from rental [paragraph 4(a)] Less: Interest expense Statutory income from rental 120,000 45,000 75,000Note: If rental income from office building and business building is assessed as a non-business source under paragraph 4(d) of the ITA, the same tax treatment applies. In the year of assessment 2011, the business building can be grouped with the office building as one source as the business building constitutes a source once it has generated income. Although the business building is only rented out on 1. 2. 2011, the whole interest expense amounting to RM50,000 is allowed a deduction since the rental business source for the year of assessment 2011 exists from 1. . 2011. The statutory income from rent for the year of assessment 2011 is computed as follows: (RM) Gross income from rental (paragraph 4(a)) Less: Interest expense Statutory income from rental 285,000 90,000 195,000 Note: If rental income from office building and business building is a ssessed as a non-business source under paragraph 4(d) of the ITA, interest expenses in respect of the business building has to be adjusted according to the period the building is let out. Therefore interest expense in respect of the period from 1. 1. 011 to 31. 1. 2011 is not allowable. Example 16: Facts are the same as in example 13 with an additional information i. e AJ Sdn Bhd owns and lets out a residential house and one unit of apartment. The Issue: B Page 10 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA letting of the residential house and the apartment unit is a non-business source since maintenance services or support services are not provided. The company is not an investment holding company.The gross income, allowable expenses and capital allowances on the furniture in each building for the year of assessment 2010 are as follows: Real property – paragraph 4(a) source Gross income (RM) 6 0,000 10,000 70,000 Gross income (RM) 8,000 6,000 14,000 Allowable expenses (RM) 14,000 12,000 26,000 Allowable expenses (RM) 11,000 4,000 15,000 Capital allowances (furniture) (RM) 7,000 3,000 10,000 Capital allowances (RM) – Building in Damansara Building in Bangsar Total Real property – paragraph 4(d) source Residential house Apartment Total The letting of buildings in Damansara and Bangsar is a business source.Therefore, those buildings can be grouped as one business source under paragraph 4(a) of the ITA. Whereas the letting of residential house and apartment is a non-business source and can be grouped as one non-business source under paragraph 4(d) of the ITA. The total income of AJ Sdn Bhd for the year of assessment 2010 is computed as follows: (RM) (i) Statutory income from rental – paragraph 4(a) [70,000 – 26,000 – 10,000] (ii) Statutory income from rental – paragraph 4(d) [14,000 – 15,000] Aggregate income/Total income Issue : B Nil 34,000 Page 11 of 26 34,000INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA The adjusted loss from non-business source amounting to RM1,000 cannot be deducted against statutory income from business of letting and is not allowed to be carried forward to subsequent years of assessment. 7. 2 If a person has a business source of letting of real property under paragraph 4(a) of the ITA and a business source from other businesses in the same year of assessment, the business source of letting of real property has to be separated from the other business sources.Example 17: Syarikat MJ Sdn Bhd (SMSB) is carrying on a business of hardware wholesaler. SMSB owns a 4-storey building which is let out and provides maintenance services and support services comprehensively and actively. SMSB also owns a terrace house which is let out without providing maintenance services and support services. Income from letting of the 4storey building qualifies to be assessed as a business source (paragraph 4(a) of the ITA) whereas rental income from the terrace house is assessed as a non-business source (paragraph 4(d) of the ITA) for the year of assessment 2010.The gross income, allowable expenses and capital allowances on plant and machinery for each source of income of SMSB for the year of assessment 2010 are as follows: Source of income Adjusted income (RM) Adjusted loss (RM) Capital allowances (plant and machinery) (RM) Business of wholesale Letting of 4-storey building (paragraph 4(a) of the ITA) Letting of terrace house (paragraph 4(d) of the ITA) 100,000 – 10,000 15,000 5,000 – 3,000 – Issue: B Page 12 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIAThe total income of SMSB for the year of assessment 2010 is computed as follows: (RM) (RM) (i) Business of wholesale (paragraph 4(a) of the ITA) Adjusted income Less: Capital allowances (plant and machinery) Statutory income (ii) Letting of real property (paragraph 4(a) of the ITA) Adjusted loss Capital allowances (plant and machinery) Statutory income (iii) Letting of real property (paragraph 4(d) of the ITA) Adjusted loss Statutory income Aggregate income Less: Current year loss Total income (3,000) Nil 85,000 10,000 75,000 (10,000) 5,000 Nil 100,000 15,000 85,000Capital Allowances of RM5,000 in relation to the letting of real property under paragraph 4(a) of the ITA which cannot be absorbed in the year of assessment 2010 is carried forward to subsequent years of assessment. Adjusted loss from the letting of real property under paragraph 4(d) of the ITA amounting to RM3,000 cannot be deducted against the aggregate income and cannot be carried forward to subsequent years of assessment. 8. Expense relating to income of letting of real property 8. An expense wholly and exclusively incurred in the production of income under subsection 33(1) of the ITA and which does not fall under subsection 39(1) of the ITA is allowed as a deduction from income of business of letting of real property charged to tax under paragraph 4(a) of the ITA. Issue: B Page 13 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 8. 2Expense which is allowed a deduction from income of letting of real property charged to tax under paragraph 4(d) of the ITA is the direct expense that is wholly and exclusively incurred in the production of income under subsection 33(1) of the ITA. Examples of direct expenses which are deductible from gross income of letting of real property are as follows: (a) Assessment and quit rent Annual assessment paid to the local authority and quit rent paid to the land office. b) Interest on loan Interest paid on loan taken to finance the purchase of real property which is rented out. (c) Fire insurance premium Fire insurance premium paid in relation to fire insurance policy taken on the real property which is rented out. (d) Expense on rent collection Rent collection fee and legal expense incurred to enforce rent collection. (e) Expense on rent renewal Expense incurred to renew tenancy or to change tenant. (f) Expense on repair Expense on ordinary repair to maintain the real property in its existing state. 8. Initial expense Initial expense is not allowed a deduction from income of letting of real property assessed under paragraph 4(a) or paragraph 4(d) of the ITA since that expense is incurred to create a source of rental income and not incurred in the production of rental income. Examples of such expense are cost to obtain the first tenant such as advertising cost, legal cost to prepare rental agreement, stamp duty and commission for real property agent. Example 18: Sarah Property Sdn Bhd buys an office building on 1. 9. 2009 to be let out.The company incurs RM600 to advertise the letting of the building on 1. 1. 2010 and legal cost amounting to RM1,800 paid to Reganathan & Co on 12. 2. 2010 for preparing rental agreement. The building is let out commencing from Issue: B Page 14 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 1. 3. 2010 without providing maintenance services or support services. The letting of the office building is a non-business source and the rental income is taxable under paragraph 4(d) of the ITA.The advertising cost amounting to RM600 and the legal cost of RM1,800 are not allowed a deduction from income of letting of office building for the year of assessment 2010 as the expenses are incurred to obtain the first tenant. Example 19: Facts are the same as in example 18 except the building is made available for letting on 1. 2. 2010 and Sarah Property Sdn Bhd provides maintenance services of lift, security services, cleaning services and maintenance of centralized air conditioner.The letting of the office bui lding is a business source and the rental income is taxable under paragraph 4(a) of the ITA. The advertising cost amounting to RM600 and the legal cost of RM1,800 are not allowed a deduction from income of letting of office building for the year of assessment 2010 as the expenses are incurred to obtain the first tenant. 8. 4 Expenses during a period the real property is not rented out 8. 4. 1 Expenses incurred in relation to a real property during a period it is not rented out are not allowable in calculating the adjusted income from the letting of the real property.However, if the period the real property is not rented out occurs after it has been let out and it is clear that it is ready to be let out, then expenses during that period are allowable subject to subsections 33(1) and 39(1) of the ITA. Example 20: Farhan lets out a double-storey terrace house on 1. 1. 2010 for RM1,000 a month. On 1. 9. 2010 the tenant moves out and the house is let out to another tenant on 1. 12. 2010 for the same amount of rental. Assessment for a year is RM500 while quit rent is RM50 a year.The letting of the house is a non-business source and the rental income is taxable under paragraph 4(d) of the ITA. The adjusted income from rent for the year of assessment 2010 is computed as follows: (RM) Rental income (gross) Period of 1. 1. 2010 – 31. 8. 2010 (8 x RM1,000) Period of 1. 12. 2010 – 31. 12. 2010 8,000 1,000 9,000 (RM) Issue: B Page 15 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Less: Assessment Quit rent Adjusted income from rent 00 50 550 8,450 As a concession, assessment and quit rent expenses are allowable in full even though the house is not rented out for the period of 1. 9. 2010 to 30. 11. 2010. 8. 4. 2 If the letting ceases temporarily due to the following circumstances: (a) (b) (c) (d) repair or renovation of the building; absence of tenants for a period of 2 years after termination of tenancy; legal injuction or other official sanction; or other circumstances beyond the control of the person who lets out the real property; xpenses for the period the real property is not let out are allowable provided that the real property is maintained in good condition and is ready to be let out. Example 21: Sinar Ria Sdn Bhd owns a 4-storey building which is let out to Deena Holding Bhd since 2008. The letting of the real property is treated as a business source. Sinar Ria Sdn Bhd closes its account on 31 December every year. On 31. 12. 2010, the letting of the building ends. The company makes an effort to obtain a new tenant but only manages to let out the building to another company on 1. 4. 013 (absence of tenants for a period of 27 months). Expenses during the absence of tenants deductible. Therefore the expenses for 31. 12. 2012 are allowable. However the 1. 1. 2013 to 31. 3. 2013 are not allowed a exceeds the specified period of 2 years. for a period of 2 years are the period of 1. 1. 2011 to expenses for the period of deduction since that period Issue: B Page 16 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Example 22: Syarafina owns 2 houses which are let out since 2009.The rental income is assessed as a non-business source under paragraph 4(d) of the ITA. The gross income and allowable expenses for each real property for the years of assessment 2010 and 2011 are as follows: Gross income (RM) Assessment , quit rent and interest expense (RM) Year of assessment 2010 3,550 2,500 Year of assessment 2011 3,550 2,500 Real property Year of assessment 2010 House I House II 1 Year of assessment 2011 12,000 -1 12,000 9,600 House II was not rented out as the local authorities had given an instruction to vacate the house from 1. 1. 2011 to 31. 12. 011 so that the hill slopes could be monitored after a landslide had occurred at a nearby area. The house was rented out again on 1. 1. 2012. The statutory income from rent for the year of assessment 2010 is computed as follows: (RM) Rental income (paragraph 4(d)) Less: Allowable expenses Statutory income from rental 21,600 6,050 15,550 The statutory income from rent for the year of assessment 2011 is computed as follows: (RM) Rental income (paragraph 4(d)) Less: Allowable expenses Statutory income from rental Issue: B 12,000 6,050 5,950 Page 17 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. /2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 8. 5 Expenses before real property is let out Expenses in respect of a period before the real property is let out is not deductible and have to be adjusted proportionately. Example 23: Michael lets out a shop house commencing from 1. 5. 2010 for RM2,500 a month. He pays annual assessment amounting to RM1,200, annual quit rent amounting to RM120 and fire insurance premium of RM600 for year 2010. The letting of the shop house is a non -business source and the rental income is taxable under paragraph 4(d) of the ITA.The adjusted income from rent for the year of assessment 2010 is computed as follows: (RM) Rental income (gross) Period of 1. 5. 2010 – 31. 12. 2010 (8 x RM2,500) Less: Expenses for period of 1. 5. 2010 – 31. 12. 2010 Assessment (8/12 x RM1,200) Quit rent (8/12 x RM120) Fire insurance premium (8/12 x RM600) Adjusted income from rent 8. 6 Restriction on interest expense If a person takes a loan for business purposes and to finance the purchase of real property that is let out, interest expense allowable against the business source has to be restricted under subsection 33(2) of the ITA.Interest expense on loan to finance the purchase of real property that is let out is deductible from rental income. Example 24: Azalea Property Sdn Bhd, a property development company closes its account on 31 December every year. On 9. 6. 2009 the company takes a loan of RM2 million from a bank for business p urposes and to finance the purchase of a bungalow costing RM450,000. The company claims an interest expense of RM120,000 in the profit and loss account for the year assessment 800 80 400 1,280 18,720 20,000 Issue: B Page 18 of 26INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 2010. The bungalow is let out commencing from 1. 1. 2010 and income from letting of the bungalow is taxable under paragraph 4(d) of the ITA. Interest restriction is computed as follow: RM450,000 ——————- x RM 120,000 RM2,000,000 = RM27,000 The amount of RM27,000 is added back in arriving at the adjusted income from business of the company. However the company can claim interest expense of RM27,000 against income from the letting of the bungalow.Note: Since the cost of the bungalow does not exceed RM500,000, interest restriction under subsection 33(2) of the ITA is calculated based on the end-of-year balance in the balance sheets. 9. Rental income received in advance 9. 1 9. 2 Rental received in advance is treated as gross income for the basis period in which it is received. Where rental income received in advance is assessed in the basis period in which it is received, any expense incurred in relation to that rental income after that basis period is allowable in the basis period in which the income is assessed.Therefore amendment has to be done to the assessment for the year of assessment concerned. Example 25: Kelvin Ong lets out a double-storey terrace house for the period of 1. 1. 2010 to 31. 12. 2012. Rental for the three years amounting to RM36,000 is received in the year 2010. Expenses incurred on that house are as follows: Year ended Income/expenses 31. 12. 2010 (RM) Rental income Expenses 36,000 4,000 31. 12. 2011 (RM) 5,000 31. 12. 2012 (RM) 3,000 Issue: B Page 19 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND R EVENUE BOARD MALAYSIAThe adjusted income from rent for the year of assessment 2010 is computed as follows: Year of Assessment 2010 (RM) Rental income Less: Expenses Adjusted income Less: Expenses for a period ending 31. 12. 2011 Amended adjusted income Less: Expenses for a period ending 31. 12. 2012 Amended adjusted income 36,000 4,000 32,000 5,000 27,000 3,000 24,000 Expenses incurred in 2011 and 2012 are allowable against the rental income which is assessed in the year of assessment 2010. Therefore the assessment for the year of assessment 2010 has to be amended when the expenses are incurred in 2011 and 2012. . 3 In the case where there is more than one real property and rental income from one or several real properties is received in advance, expenses related to that source is deductible from other rental income in the basis period in which the expenses are incurred. This treatment is only applicable to rental income from real properties which are assessed as one source. Example 26: Fortune Sdn Bhd lets out 2 buildings commencing from 1. 1. 2010. The company receives rental for 3 years amounting to RM300,000 in 2010 in relation to the first building.The second building is let out for RM10,000 a month. The letting of both buildings is treated as a rental source under paragraph 4(d) of the ITA. Income received and the allowable expenses for the building are as follows: Issue: B Page 20 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Year ended First building Income (RM) Expenses (RM) 20,000 15,000 18,000 Second building Income (RM) 120,000 120,000 120,000 Expenses (RM) 30,000 30,000 30,000 31. 12. 2010 31. 12. 011 31. 12. 2012 300,000 – The adjusted income from rental for the years of assessment 2010 to 2012 is computed as follows: Year of assessment 2010 (RM) Rental income Less: Expenses Adjusted Income 420,000 50,000 370,000 2011 (RM) 120,000 45,000 75,000 2012 (RM) 120,0 00 48,000 72,000 Example 27: Facts are the same as in example 26 but the letting of the first building is treated as a business source under paragraph 4(a) of the ITA whereas the letting of the second building is treated as non-business source under paragraph 4(d) of the ITA.The adjusted income from rental for the years of assessment 2010 to 2012 is computed as follows: Issue: B Page 21 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA Rental source under paragraph 4(a) of the ITA Year of assessment 2010 (RM) Rental income Less: Expenses Adjusted income Less: Expenses for a period ending 31. 12. 2011 Amended adjusted income Less: Expenses for a period ending 31. 12. 2012 Amended adjusted income 300,000 20,000 280,000 15,000 265,000 18,000 247,000Expenses incurred in the years of assessment 2011 and 2012 are allowed a deduction from rental income which is assessed in the year of assessment 2010. Therefore th e assessment for the year of assessment 2010 has to be amended when the expenses are incurred in 2011 and 2012. Rental source under paragraph 4(d) of the ITA Year of assessment 2010 (RM) Rental income Less: Expenses Adjusted income 120,000 30,000 90,000 2011 (RM) 120,000 30,000 90,000 2012 (RM) 120,000 30,000 90,000 10. Capital allowances 10. If the letting of real property is treated as a business source, capital allowances can be claimed on capital expenditure incurred on plant and machinery. The provisions in Schedule 3 of the ITA relating to capital allowances shall apply to the business of letting of real property. Issue: B Page 22 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 10. 2 If the letting of real property is treated as a business source and the letting of real property ceases temporarily due to the circumstances mentioned in paragraph 8. . 2 of this Ruling, capital allowances can still be claimed in respect of the period the real property is not let out provided the real property is maintained in good condition and is made available for letting. Example 28: Saravanan Sdn Bhd let out a shop lots building since 2008. The letting is treated as business source. On 1. 4. 2010 the building is repaired and cannot be occupied until 31. 5. 2010. The building is only let out again on 1. 6. 2010. Capital allowances claimed for the year of assessment 2010 is RM30,000. Even though the letting of shop lot building ceases from 1. . 2010 to 31. 5. 2010, the whole amount of capital allowances of RM30,000 can be claimed in the year of assessment 2010 since the letting ceases temporarily due to the repair of the building. Example 29: Harris Property Sdn Bhd owns a 5-storey building which is let out to Fetty Holding Bhd since 2007. The letting of the real property is treated as business source. Harris Property Sdn Bhd closes its account on 31 December every year. On 1. 3. 2010, the tena ncy of the building ceases and Fetty Holding Bhd does not renew the tenancy. The building is left vacant until 31. 2. 2011 despite the efforts of the company to find a new tenant (including advertising the letting in several newspapers). Harris Property Sdn Bhd only manages to let out the building to another company on 1. 1. 2012 (absence of tenants for a period of 22 months). Capital allowances have been claimed since 2007. Even though the letting of building ceases from 1. 3. 2010 to 31. 12. 2011, capital allowances can be claimed in the years of assessment 2010 and 2011 since the letting ceases temporarily due to the absence of tenants for a period of less than 2 years.Example 30: Facts are the same as in example 29 except that the building is not let out until 31. 3. 2012. Harris Property Sdn Bhd only manages to let out the building to another company on 1. 4. 2012 (absence of tenants for a period of 25 months). Harris Property Sdn Bhd is eligible to claim capital allowances for the years of assessment 2010 and 2011. Harris Property Sdn Bhd is also eligible to claim capital allowance for the year of assessment 2012 if the letting of the building is treated as a business source for that year of assessment.Issue: B Page 23 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 10. 3 If there is a change in tax treatment of the letting of a real property from a business source under paragraph 4(a) of the ITA to a non-business source under paragraph 4(d) of the ITA in the basis period for a year of assessment, the person who lets out the real property has two sources of income from the same real property in that basis period, i. a business source under paragraph 4(a) of the ITA and a non-business source under paragraph 4(d) of the ITA. If as a result of the change: 10. 3. 1 a company becomes an investment holding company (IHC), the rental income (business source) would be assessed as incom e under paragraph 4(d) of the ITA. Therefore, the company is not entitled to claim for capital allowances on plant and machinery since they are not used for the purpose of a business at the end of the basis period for that year of assessment. 0. 3. 2 a company does not become an IHC, the company still derives rental income under paragraph 4(a) and 4(d) of the ITA in respect of the real property. Even though the company is not an IHC, the company would not be entitled to claim for capital allowances on plant and machinery since they are not used for the purpose of a business at the end of the basis period for that year of assessment. Note: The determination of whether a company is an IHC or not is explained in the Public Ruling No. /2011 (Investment Holding Company). 10. 4 If a company has a business source and a rental source (not necessary to determine whether an IHC or not since its main activity is not the holding of investments) and there is a change in tax treatment of the lett ing of a real property from a business source under paragraph 4(a) of the ITA to a nonbusiness source under paragraph 4(d) of the ITA in the basis period for a year of assessment, the company still derives rental income under paragraph 4(a) and 4(d) of the ITA.The company would not be entitled to claim for capital allowances on plant and machinery since they are not used for the purpose of a business at the end of the basis period for that year of assessment. Note: In the case where capital allowances cannot be claimed, the residual expenditure of the plant and machinery will be reduced by notional allowances for that year of assessment and subsequent years of assessment. Example 31: Menara Sdn Bhd owns an office building consisting of 20 units and lets out all the units fully furnished since 2006.The letting is treated as a business source since maintenance services and support services are comprehensively and actively provided by Menara Sdn Bhd. Capital allowance have been claimed on the furnitures in the office building. Issue: B Page 24 of 26 INCOME FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA However from June 2010, Menara Sdn Bhd did not provide maintenance services and support services.Menara Sdn Bhd closes its account on 31 December every year. Menara Sdn Bhd is not entitled to claim capital allowances on the furnitures in the office building for the year of assessment 2010 since the furnitures are not used for the purpose of a business at the end of the basis period for that year of assessment. Notional allowances will be deducted to arrive at the residual expenditure of the furnitures for the year of assessment 2010 and subsequent years of assessment. 0. 5 If more than one real property is let out and there is a change in tax treatment of any of the real properties from a business source under paragraph 4(a) of the ITA to a non-business source under paragraph 4(d) of the ITA in the basis period for a year of assessment, capital allowances can be claimed on plant and machinery for the real property which remains as a business source under paragraph 4(a) of the ITA.If there is a change in tax treatment of the letting of a real property from a non-business source under paragraph 4(d) of the ITA to a business source under paragraph 4(a) of the ITA in the basis period for a year of assessment, the person who lets out the real property has two sources of income from the same real property in that basis period, i. e a non-business source under paragraph 4(d) of the ITA and a business source under paragraph 4(a) of the ITA.Capital allowances can be claimed on plant and machinery in the real property since they are used for the purpose of a business at the end of the basis period for that year of assessment. For the purpose of computing capital allowances, the qualifying expenditure for the plant and machinery is the market value on the first day they are used in the b usiness. Example 32: Teguh Sdn Bhd closes its account on 31 December every year and its main activity is the holding of investments. The company owns and lets out a fullyfurnished 10-storey office building.The letting is treated as a rental source under paragraph 4(d) of the ITA. From 1. 3. 2010 the company provides maintenance services and support services comprehensively and actively. The company is not an IHC in the year of assessment 2010 since the income from holding of investment is less than 80% of its gross income. Teguh Sdn Bhd is entitled to claim capital allowances on the furnitures in the office building for the year of assessment 2010 since they are used for the purpose of a business at the end of the basis period for that year of assessment.For the purpose of computing capital allowances for the year of assessment 2010, the qualifying expenditure for the furnitures is the market value on 1. 3. 2010. No initial allowance will be given. Issue: B Page 25 of 26 10. 6 INCOM E FROM LETTING OF REAL PROPERTY Public Ruling No. 4/2011 Date of Issue: 10 March 2011 INLAND REVENUE BOARD MALAYSIA 11. Industrial building allowance 11. 1 If a person owns a building lets out the building and the building is in used as an industrial building, industrial building allowance can be claimed by the owner of the building even though the letting is a non-business source.If the letting of real property is given a special treatment as explained in paragraph 4. 4 of this Ruling, the owner of the building is eligible to claim industrial building allowances on the qualifying building expenditure incurred. 11. 2 12. Replacement cost of furnishings If the letting of a furnished real property is treated as non-business source, cost of replacing furnishings such as furniture and air conditioner can be claimed as a deduction from gross income from that letting. 13.Letting of part of building used in the business If a building, whether owned or rented, is used for business purposes and part of the building is let out, the rent arising from the letting is treated as part of income from the existing business source. 14. Effective date This Ruling is effective for the year of assessment 2011 and subsequent years of assessment. This Ruling supersedes Public Ruling No. 1/2004 issued on 30 June 2004. Director General of Inland Revenue, Inland Revenue Board Malaysia. Issue: B Page 26 of 26