Tips for Buying Outdoor Play Equipment

With advancement in technology, children nowadays are more accustomed to structured indoor activities. It is estimated that the average child spends not more than ten minutes in unstructured outdoor activities. Popularity of indoor activities is blamed for the poor quality of life of children. Realizing the positive impact of outdoor play on the health and mind of children, parents nowadays are encouraging their children to play outdoors. They are now installing outdoor play equipment to attract kids to the outdoor space of their residence.Choose appropriate outdoor play equipment
Different types of outdoor toys are available for kids. While selecting play equipment for your garden, buy only age appropriate toys. If you have a lawn or yard, you can install a swing, climbing frame or seesaw in the outdoor space. However, before placing the outdoor equipment, make sure that the area is hazard free for the kids. Besides swinging, climbing and sliding, children also love riding. They love exploring the space outside the house in the attractive ride-on-toys. To tempt your child to spend a few hours enjoying the sunshine and fresh air outdoors, place a lovely playhouse or play tent in your backyard. Enchanted by his/her own miniature house, your child will be willing to abandon indoor games in favor of more attractive outdoor activities. For kids who are a bundle of energy, trampolines or jumping mats is the appropriate play equipment for bouncing outdoors.Things to remember while shopping for outdoor toys
While shopping for outdoor toys, select toys made out of good quality material. They should be highly durable, and capable of withstanding rough handling. The metallic components of the garden play equipment should have a rust resistant coating. Only lead free non-toxic paints should be used for painting the equipment. Sometimes, to enhance the durability of fabrics present in outdoor equipment, they are covered with UV resistant coating. There should be no sharp edges in the toy. Plastic or PVC is widely used nowadays for constructing outdoor toys. The water and heat resistant properties of plastic or PVC has made it the popular choice for play equipment that are installed outdoors.Benefits of outdoor play equipment
Climbing and swinging are beneficial exercises for the muscles. Almost every muscle in the body is exercised while a child in playing with outdoor toys. Encouraging children to play with garden play equipment is the best strategy to improve their fitness level and reduce the risk of obesity and other childhood illnesses related to a sedentary lifestyle.

US International Tax Planning: Subpart F Branch Rule Causes Inclusions for CFC Shareholders

Subpart F rules limit deferral of foreign income by owners of foreign corporations. Earnings of a foreign corporation owned by U.S. taxpayer(s) are generally not subject to taxes in the USA until remitted. This general rule is subject to several anti-deferral regimes, including Subpart F. U.S. shareholders (generally U.S. persons owning 10% or more of the vote) of a controlled foreign corporation (CFC) must include in their income currently certain types of income earned by the CFC, under the provisions of Subpart F. These inclusions are accompanied by a deemed-paid credit for corporate shareholders that operates identically to the deemed-paid credit for dividends. A Subpart F inclusion, however, is not a qualified dividend eligible for the reduced 15% tax rate.This second of a series of articles on Subpart F deals with the branch rule that requires CFC shareholders to include income from sales branches of CFCs.Shareholders of CFCs that buy and sell goods must include in their income their shares of the CFC’s income if the goods are bought from or sold to a related party and both made and for use outside the CFC’s country. A high tax exception prevents this if the foreign income tax exceeds 31.5% on the income. This normally does not apply to shareholders of a CFC that makes and sells goods, even if it is not subject to foreign tax. Under the branch rule, though, part of the income of a CFC that makes and sells goods may be subject to Subpart F inclusion by the U.S. shareholders.Where the branch rule applies, the sales and manufacturing branches are treated as different, separate CFCs. The effect of this is to treat the sales branch as if it purchased goods from a related party and resold them. The sales branch is treated as incorporated in the home office CFC’s country of incorporation. Thus, sales of goods for use outside that country are treated as Subpart F income.The branch rule applies only if both of two tests are met: foreign tax reduction, and home-country tax deferral. The first test is met if the total foreign income taxes imposed on the CFC are reduced by at least 5 percentage points as a result of the use of branches. The second test is met if the effect of a branch is to defer income tax in the CFC’s country of incorporation until the earnings of the branch are remitted.The branch rule does not result in Subpart F income if the earnings of the branch are still subject to foreign income tax in excess of 31.5%. It also does not apply with respect to a branch in the USA.Example: Mech AG is a Swiss corporation owned by a Bob, U.S. citizen. Mech AG makes and sells machines. The machines are made by an Ireland branch, subject to 12.5% Irish income tax on the income of the branch only. The Ireland branch transfers the machines to an office of Mech AG in Switzerland. The transfer price results in a profit in Ireland. The Swiss office sells the machines to customers for use around the world. Under Swiss tax law, the Ireland profits are not taxed until remitted. The profits of the sales branch (treating the transfer from Ireland as if it were a purchase) are subject to 22% Swiss Federal and cantonal income tax. As a result of the Swiss tax law rules, the Ireland profits are taxed at 9.5 percentage points less than the other profits, and not taxed (deferred) until remitted. The branch rule tests are met. The sales branch profits are considered Subpart F income, and Bob must pay taxes in the USA on the sales income as if it were distributed.Note that Subpart F inclusions are not qualified dividends. Thus, for individuals who own CFCs, a Subpart F inclusion may be not only an acceleration of tax, but a permanent increase. Bob’s tax is up to 35% on the Subpart F income, rather than the 15% that would apply to a dividend from a Swiss corporation. For regular corporations who own 10% or more of a CFC, the Subpart F inclusion is only a temporary difference, since all a regular corporation’s income is taxed at the same rate.Summary: U.S. owners of foreign corporations may be required to include in their income their share of income of a CFC from making and selling goods if the CFC has separate manufacturing and sales branches.International tax planning can be complex, especially such provisions as Subpart F. Call Steve Fox to help make sure you are not paying more tax than necessary.

Type 2 Diabetes – Concerns About Breast Cancer

Type 2 diabetes is associated with a high risk of breast cancer, and the genetic mutations of BRCA1 and BRCA2 are also associated with a high breast cancer risk. Researchers in the Hereditary Breast Cancer Clinical Study Group at the Juravinski Cancer Centre in Ontario, Canada, studied whether the BRCA1 and BRCA2 mutations could be associated with Type 2 diabetes. The results of their work will be published in the journal Cancer in May 2011. BRCA1 and BRCA2 belong to a group of genes that suppress tumors.Six thousand and fifty-two women with either the BRCA1 or BRCA2 mutations were included in the study. Half had already been given a diagnosis of breast cancer. Histories of diabetes were also obtained. Those who had breast cancer had no trace of diabetes before their cancer was diagnosed and neither did the women without cancer. In the 15 year period after their cancer was diagnosed, it was found these ladies had twice the risk of also receiving a diagnosis of Type 2 diabetes. For women with a body mass index of over 25, meaning that they were overweight or obese, the risk was more than five times as great.Could breast cancer be a possible cause of Type 2 diabetes? More research on these diseases will tell.BRCA1 and BRCA2 are genetic mutations found primarily among the Ashkenazy Jewish population. People with a family history of breast cancer can also be carriers of these mutations…if your mother, sister or daughter were diagnosed with breast cancer before the age of 50, suspect the mutations,
having three or more aunts or a grandmother with breast cancer, at any age, should also raise your suspicions,
a close relative with breast and ovarian cancer or cancer of both breasts,
two or more relatives with ovarian cancer or breast cancer in a male relativecan all be indications of the presence of the BRCA1 or BRCA2 mutation.Women with either mutation are at risk for both breast and ovarian cancer, and both men and women with either mutation are at risk for breast cancer. Tests are available for detection of these mutations, and if they are found preventive measures can be taken.Breast exams should be self-performed every month and should be carried out as part of a regular checkup:the American Cancer Society recommends an annual mammogram for women over 40,
transvaginal ultrasound can also detect tumors early,
women who are at high risk can consider prophylactic surgical removal of their breasts and ovaries
normalizing weight is also a preventive measure,
the drugs tamoxifen and raloxifene are also used as preventive measures.If you are concerned that you might be at high risk because of your ethnic background or family history, see your doctor for genetic testing. Your privacy is legally protected. If you are aware you are carrying BRCA1 or BCRA2 mutations, discuss with your doctor the preventive measures that might be appropriate in your case.All women should have regular breast exams and mammograms. Whether this will help to prevent Type 2 diabetes remains to be seen, but certainly prevention and early detection of cancer can be life saving.

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