Jews Were Complacent During The Holocaust - 1670 Words

It is a common misconception that Jews were complacent during the Holocaust. For most people, the only knowledge, if any, about Jewish resistance during the Holocaust comes from a fictional movie, Inglourious Basterds. While certainly based on facts, Inglourious Basterds is not a good way of expelling a myth. In actuality, and despite popular belief, Jews were not complacent during the Holocaust. They performed both violent and non-violent resistance against the Nazis, such as spiritual resistance, forming partisan groups, and starting uprisings and riots in many ghettos and concentration camps. Spiritual resistance is defined as â€Å"attempts by individuals to maintain their humanity, personal integrity, and sense of civilization in the face of Nazi attempts to dehumanize and degrade them† by the United States Holocaust Museum (Spiritual). Spiritual resistance was highly regarded by many Jews, and most actually considered it to be the purest form of resistance because it was non-violent, and kept their spirits from being broken, even while facing horrible degradation. Examples of spiritual resistance include conducting religious services while in ghettos or concentration camps, keeping covert libraries of Jewish works, and establishing secret archives to report about daily life in the ghettos. The continuation of religious practices while in ghettos was most commonly conducted by Orthodox Jews because they heavily opposed violence, but religion continued in almost all ghettosShow MoreRelatedConstantines Sword Essay953 Words   |  4 Pagesdream that they were his legs under the bandages and when he would wake up he would think he was the one who couldnt walk. He learned early, what suffering was. Later on in life he would be reminded of his brothers legs. The crucifixes all had his brothers legs and the nails were Jesus polio. He was again reminded of his brothers legs the first time he saw pictures of the inmates of the concentration camps. That was also the first time he became aware of the slang term Jew. He remembered hearingRead MoreThe Train Car As A Symbol Of The Extermination1337 Words   |  6 Pagesthe case of the Holocaust, symbols are used to materially express the nearly unfathomably reality of its events. But, what do we do with often emotionally charged pe rceptions of history? Symbols can be used as evidence, and as a way to connect the past to the present commemorating the time period in which they encapsulate. But symbols are culturally created, as objects are assigned a meaning often during but more importantly after events have passed. In the case of the Holocaust, the train car Read MoreHitler s Political And Foreign Policy1263 Words   |  6 Pagesinformed by their mentors that college is important for getting a good job and providing for a family. Many German children joined Hitler Youth because, through propaganda, this organization seemed like a fun way to become powerful over the bad guys: the Jews. In Germany, the depression of the early 1930’s was an extreme event that caused democratic parties to lose support. The poor economy influenced people to turn to the radical Nazi party, which offered seemingly easy and quick solutions to all of theirRead MoreTreatment of Race in the Hobbit by J.R.R. Tolkien1151 Words   |  5 PagesThe Hobbit is a novel about a complacent hobbit named Bilbo Baggins accompanying a group of thirteen dwarves - as their burglar - on a journey to regain the dwarves’ treasure from the vast, beastly dragon, Smaug. Along the adventure, Bilbo starts becoming the brave adventurer he was meant to be. While the story is a fun, adventurous tale, the stereotypes and racism of/in the character races could be seen as a reflection of discrimination in the early 1900s and modern days. The way character groupsRead MoreWhy Common Germans Took Part Of The Holocaust2222 Words   |  9 PagesThis investigation evaluates why common Germans took part in the Holocaust. In order to assess why common Germans took part in the Holocaust the investigation focuses on the participation and complacency of the German people during the Holocaust, specifically the extermination of the Jewish people, and the reasoning behind it. Different explanations for the German actions developed by a ran ge of historians will be presented. The conventional reasons, like psychological and cultural, and the nonconventionalRead MoreThe World Of The Holocaust1940 Words   |  8 Pagesan event in history known as the Holocaust. The Holocaust was a genocide, in which the Nazi’s, with Adolf Hitler as their leader, killed about 6 million Jews. This occurrence took place in Germany and German occupied territories across Europe. January of 1933 was the start of the Nazi’s gaining power in Germany. The Nazi’s were known as the culprits who committed the mass killing of Jews across Europe. The Holocaust started because Adolf Hitler felt that Jews were ruining Germany. He stated in hisRead MoreNight Study Questions2598 Words   |  11 Pagesgradually reduced the Jews to little more than things which were a nuisance to them. Discuss at least three specific examples of events that occurred which dehumanized Eliezer, his father, or his fellow Jews. Dehumanization played a significant role throughout Elie Wiesels Night. In many historic references to the Holocaust the killing of the Jews were described as methodical and systematical(The Jewish Outreach Institute), though this is true, these heinous crimes were made even worse byRead MoreAdolph Eichmann And The Nazi Party2972 Words   |  12 PagesHitler, Heinrich Himmler, and Joseph Goebbels, Eichmann physically did not resemble the stereotypical tall, blonde, Aryan male, and due to his darker complexion, brown hair, and brown eyes Eichmann was teased as a child and derisively called the â€Å"little Jew.† As a young man in the 1920s Eichmann never held a steady job, working as a traveling salesman, a day laborer, and an office worker. In 1932 at the age of 26, at the suggestion of a friend, Ernst Kaltenbrunner, Eichmann became a member of the rapidlyRead MoreTriump in The Scarlett Letter by Nathiel Hawthorne2558 Words   |  10 Pagesupper class’ superficiality, but also to provide more insight into characters’ personalities. Nick’s cousin, Daisy Buchanan, is a perfect representation of what Fitzgerald believes is the mentality of the upper class. High class women such as Daisy were expected to be the trophy wives of rich husbands, and she was considered quite the catch. Though Daisy seems airy and oblivious on the surface, she is actually quite aware of her position in society. She chooses Tom over Gatsby because she is certain

Argumentative Essay Legalization Of Marijuana - 1387 Words

Amanda Montoya April 14, 2014 Kathy severance Argumentative essay #2 Legalization of Marijuana Marijuana has been used in religious ceremonies or for medical purposes for thousands of years. I have always been against the use of Marijuana up until four years ago when my husband at the age of twenty seven underwent invasive surgery on his knee and has never been the same since. Colorado took a huge step several years ago legalizing marijuana for medical use and in recent years took the plunge to legalize it for recreational use. Marijuana is not always a bad thing nor is it always a good thing. A lot of people will compare it to any other mind altering substance and have very valid points. I would rather have a loved one or myself smoke marijuana or ingest it, instead of popping pain pills or other harmful substances put on the market by the pharmaceutical industry; Recreational use can be safe and accepting if it is regulated correctly and used responsibly. One of the biggest issues since legalization of marijuana in Colorado is the effect it has on our youth and future gen erations. In a report posted regarding the cause and effect on teenagers using marijuana Krista Lisdahl, director of the Brain Imaging and Neuropsychology lab at University of Wisconsin, Milwaukee, talks about the changes in the THC levels from the seventies to now. She also talks about how through modern technology it is possible to physically see the difference in the brain when a teenager isShow MoreRelatedArgumentative Essay : The Legalization Of Marijuana1293 Words   |  6 PagesArgumentative Essay: The Legalization of Marijuana in the United States Should we legalize marijuana? That is an excellent question. First, we must explore the history of Cannabis. Cannabis was introduced to the United States in the 1600’s, first encouraged by the federal government for domestic hemp production, cannabis soon became a required crop for farmers to grow. Hemp was recognized for its medical benefits and was the main fiber used in industrial textiles. Marijuana thrived until the earlyRead MoreMarijuana Legalization Argumentative Essay1060 Words   |  5 PagesSpanish brought marijuana to the New World. It was introduced in Jamestown in 1611, where it became a major commercial crop grown as an innocent source of fiber (specifically, hemp). By 1927, the production and possession of marijuana had been outlawed throughout the United States, causing a prohibition that is still in effect 80 years later. Since then, the world has seen the violent rise of drug cartels and the high price of fighting illegal marijuana use (Narconon). Marijuan a should be legalizedRead MoreThe Legalization of Marijuana: An Argumentative Essay1704 Words   |  7 Pagesï » ¿Legalization of Marijuana When it comes to the American war on drugs, marijuana is one of the biggest enemies. And in view of the fact that alcohol and tobacco, two life threatening substances, are officially permitted it is a pertinent question to ask why marijuana is not (Chopra et al 2002). The taxpayers of America can to a degree answer this question when they fill out their tax forms and when they hear the ruthless oratory used against marijuana by the government. The reality that marijuanaRead MoreArgumentative Essay On Legalization Of Marijuana901 Words   |  4 PagesThe legalization of Marijuana is a topic that has been discussed for many years. It has had many support as well as opposition. This topic has caused a lot of controversy over the years. In today’s society the amount of marijuana or cannabis that is being consumed is, for the most part, consumed by teens and adults. Although marijuana is an illegal drug, that does not stop people from getting a hold of it. The use of marijuana can be for many reasons such as, socializing, obtaining a high, escapingRead MoreArgumentative Essay On Legalization Of Marijuana951 Words   |  4 PagesIn 1971, President Richard Nixon declared war on drugs. Marijuana was one the drugs that Nixon tried to grasp a firm hold on. However in 2017, 29 states as well as DC, have laws legalizing marijuana in some form but some continue to fight their own war on drugs. The legalization of marijuana has health benefits that help those with certain diseases while also helping the economy grow and the crime-rate of the United States decrease. Marijuana was first used legally for medical reasons in the stateRead MoreArgumentative Essay On Legalization Of Marijuana1325 Words   |  6 Pages Marijuana is one of the most controversial subjects today. What is marijuana? It is a drug derived from the dried flowers, leaves, stems, and seeds of the cannabis plant, sativa or indica. The drug causes changes in the users mood and also affects how they think and perceive their environment. Today, marijuana has been misunderstood and interpreted wrongly for the simple fact that people are not well educated about the drug and its positive benefits. Marijuana is considered a gateway drug andRead MoreArgumentative Essay On Legalization Of Marijuana760 Words   |  4 PagesMarijuana has been used by mankind for thousands of years. It has been used medically, recreationally, and for various other purposes since it was first discovered. But in recent years, Marijuana has become a symbol of rebellion and laziness, thanks in part to the War on Drugs. Many argue for and against its legalization but there is one thing that they can agree on; the legalization of Marijuana for Medical and Re creational uses will have a tremendous impact on society and the cultures of the UnitedRead Morethree arguments Essay741 Words   |  3 Pagescritical argument analysis essay, focuses on three professional essays and how these authors construct their arguments using opinion and evidence. There are many different ways in which authors can construct their arguments. In the highly controversial topic of legalizing marijuana I found three very different styles of arguments in which the authors backed up their opinions with facts. In my reading of these arguments each writer had there own style. The first essay by Stephen B. Duke, CannabisRead MoreShould Marijuana Be Legalized For The Best Of Society?1742 Words   |  7 PagesMarijuana is one of the most controversial discussions to consider in various countries due to the numerous debates between citizens to legalize or criminalize the drug for the best of society. In countries such as Colombia, Netherlands, and various states in United States (Colorado, Washington, and Oregon), marijuana is legalized for recreational and medical purposes, which is obtainable to all citizens. However, in countries such as Canada, marijuana remains illegal for recreational use, whichRead MoreArgumentive Essay1121 Words   |  5 Pagesà ¯ » ¿ Argumentative Essay Legalization of Marijuana Ashley Bassett Eng. 1301 Instructor: Pam Hesser pg.1 The recreational use of Marijuana should be legalized. According to the New York Times The social costs of the marijuana laws are vast. There were 658,000 arrests for marijuana possession in 2012, according to F.B.I. Figures compared with 256,000 for cocaine, heroin and their derivatives. Even worse, the result is racist, falling disproportionately on young

Learning Team Charter Analysis Essay Example For Students

Learning Team Charter Analysis Essay Learning Team Charter Analysis Business Communications COM/285 August 02, 2010 Learning Team Charter Analysis Team A There are several key elements involved with establishing and maintaining effective communications in a group environment. Understanding the dynamics of group communication is essential at the outset of any project or endeavor that requires input from multiple team members. A great deal of thought should also be put into the process and ground rules for dispute resolution. As with any solid plan, the effective application of fundamental communications strategies coupled with leveraging available technologies will go a long way toward ensuring project success. Group communication is the communication that takes place while an ensemble of people, working together towards a goal; focus on the informational, procedural, and interpersonal dimensions of achieving that goal. A group may communicate differently throughout the three individual stages; formation, coordination, and formalization, of their task. Effective group communication is the key to a group’s ability to optimally plan, organize, and conquer their goal or task. The dynamics of group communication differ considerably from that of the communication that takes place throughout individual communication. Group communication involves dialogue, verbal or written, that is coming from, and intended for, more than two people, while individual communication is the dialogue which takes place between two people. Communicating effectively involves understanding your audience. In a group, this can pose as more of a challenge than with individual communication as there are likely different levels of understandings, thoughts, and communication styles amongst a group. When communicating in a group there is more opportunity for persons’ thoughts to go unsaid or unheard, while most individual conversations are reciprocal. In a group, it may be more difficult for some individuals to share their feelings of thoughts out loud and in front of a large group. Therefore, more efforts must be made to encourage participation. A goal in communication with another individual is that the dialog be a reciprocal. To encourage reciprocal conversations individuals can remember three simple rules; stop, look and listen. When participation in a conversation with another individual it’s important, when the other person begins talking, to stop and actively listen to what they are saying. Nodding your head or an occasional â€Å"uh-huh† shows them you are listening and helps that person feel that they are being taken sincerely. The strategies that are used to promote effective group communication are similar to those used when communicating with one individual; however, additional efforts are made to encourage equal involvement amongst members. Trust, cooperation, and productivity are all enhanced when a group practices effective communication. The communication within a group is most effective when all members contribute. A few strategies to promote participation are round robin, small group discussion, and brainstorming. Round robin is a method during which each member of a group is asked their thoughts on one specific topic, or question. Each team member then writes their responses down and all ideas and suggestions are then discussed openly. Small group discussion is a tool large groups can use to discuss intricate topics. The large group breaks apart into smaller groups to discuss the same topic. Each smaller group records what is conversed, summarizes and report back for further discussion. (Leister, 1992) Avoiding group think and identifying and addressing issues within the group is vital to the group’s ability to further communicate. Some strategies to promote group communication are that each member of the group is given a chance to give their input and that all thoughts are received with respect and understanding. A group strategy to overcome conflicts and challenges is that the group actively and openly listens to one another’s concerns and puts forth the effort to address and resolve them. University of Phoenix Learning Teams change with each new class. Team members could build a stronger Conflict Management section by modeling previous team charters where dispute guidelines are well developed. A sample charter reviewed by the Team had a statement that provided a good example for how disputes should be handled, â€Å"Active discussion, open-minded consideration, and mutual respect should support resolution of any conflicts† (Sample, 2010). This statement could be inserted into the beginning of the Conflict Management section to set a positive tone for how disputes should be handled. University of Phoenix classes span a five week period. The class timeframe limits the amount of possible conflicts that may arise between learning team group members. The submitted Learning Team A Charter provides minimal information for dispute resolution. The Team identified one possible source of conflict within the group; agreeing on topic or main points. Other sources of conflict could include late submission parts from team members and differences in opinion. The sample charter reviewed by Learning Team A listed non-participatory team members and misunderstandings as possible sources of conflict. By incorporating the additional four conflict sources into future charters, the Team names the five most common learning team problems. An effective Learning Team Charter should list specific strategies of dispute resolution for each conflict source. The charter for Learning Team A gave brief, but specific strategies for disagreements on topics and main points; team members could suggest option for topics and vote to settle the disagreement. Wiping the sweat from my brow I called a halt to the crew EssayAll their energy can be aimed in certain direction to achieve the common goal. The most detrimental and common problems of face to face meetings is groupthink. Many groups have dominating members and personalities. People are also so focused on agree that members will go along with the idea just to keep peace. (Locker, K; Kienzler, D, 2008) When this happens, the groups work runs the risk of becoming inferior or less than desired. Groupthink can be created by another issue of this type of group communication, the length of meetings. To avoid two and three hour processes, the members will suppress their comments and allow others to run ideas in the wrong direction. Sidebar conversations also take away from this setting. (Heathfield, 2010) Without total participation, meetings become unproductive and frustrating. Members often find themselves talking about work schedules, personal lives, and a host of other topics unrelated to the reason of the meeting. Another technology that can facilitate group meetings and mass communication is through email. The biggest advantage of email is the convenience of getting an idea out to many people at once. All the members of one team can get the same information simultaneously despite their location or time zone. Each member is also allowed to begin work immediately on their specific portion. Emails are date and time stamped which also enables the messages delivery to be verified. Some networks allow the sender to know when the receiver reads the message as well. Emails can be referred to and referenced at any time. When a members needs clarification on a thought they have the option to revisit the message and omit whatever part does not concern them. The sender of an email can also attached files that may assist other members with the work; all members can share and view the same information. The major disadvantage of an email is its dependence on the internet. Without a connection an email cannot be access and therefore rendered useless. Emails are also extremely impersonal and cold. It is very difficult to send emotion through email and members may become offended and shut themselves off from the process. Another major disadvantage the email is the possibility of a virus. Many messages have virus unintentionally attached to them that can crash a mailbox or the computer all together. Telephones can also be used to facilitate group communication. Telephones are the quickest way for group members to meet and pass ideas. This technique is less personal then face to face but offers a more personal feel than the email. If the member does not understand the information being given they can ask for clarification immediately and without the fear of backlash from other members. The top disadvantage of the telephone is the time zone consideration. Many teams are not locally assembled and are not available at the same time. This removes the opportunity for a teleconference and face to face meetings, leaving only email or individual phone calls to communicate. Many phones can distort or even delete frequencies due to quality. (Bowman, 2002) This is becoming more and more common with the use of cellular phones as opposed to landlines. People are more distracted with driving, family issues, and even television shows during phone conversation that again thoughts are not given complete thought. It’s clear to see that there can be many challenges associated with group communications. These challenges can also be intensified in an online working environment. This does not mean, however that effective communication cannot take place. Through the use and understanding of group dynamics, conflict resolution, proper planning strategies and available technology, it can be fairly easy to establish an effective communications plan. When a group of people recognize the important role that communication plays in the process of achieving their goals, they are well served to plan accordingly. References Leister, M. (1992). North Dakota State University. â€Å"Leadership Development within Groups – Communicating Effectively. † Retrieved July 30, 2010 from, http://www. ag. ndsu. edu/pubs/yf/leaddev/he499w. htm Gioia, C. (2010). â€Å"How to Start a Conversation and Make Friends. † Retrieved July 31, 2010 from, http://www. helium. com/items/537319 Schwartz, A. E. (July 26 2005). Clear Communication. Retrieved from http://ezinearticles. com/? clear-communication Communication is an exchange of information. It is a process of understanding on both the part of the receiver and the sender. Locker, K, Kienzler, D. (2008). Business and administrative communication. New York, NY: The McGraw-Hill Companies. Heathfield, Susan. (2010). Meeting management: deal with competing conversations . TIPS for working with people at work, Retrieved from http//:humanresources. about. com Bowman, Joel. (2002, August 24). Managing information and relationships. Business Communication, Retrieved from http://homepages. wmich. edu/~bowman/phone. html

Portfolio of the Cultural Perception in the Fine Art

Drawing is a crucial element of visual arts since it constitutes a noteworthy element of fine art. Evidently, a drawing highlights crucial information about the object under study.Advertising We will write a custom essay sample on Portfolio of the Cultural Perception in the Fine Art specifically for you for only $16.05 $11/page Learn More It also shuns the use of words in recounting occurrences in real life. Modern drawings make use of ‘dry’ or ‘wet’ media; furthermore, drawings do not significantly differ from painting. During the drawing process, it is important to look at the connection between the vertical and horizontal lines of the image. The identification of the angle is tenable using a compass. It is remarkable to note that the measuring process lacks significance. Additionally, the pose of grasping the pencil is crucial during illustration. An example is evident when the vertical line is placed against the second line to form an angle. This determines the accuracy of the angle under formation. During the course of coming up with angles, it is important to shun the preconceived knowledge concerning the object. Instead, the artists should create new ideas to bring out the subject in a real situation. Proper consideration of the layout as evident in accurate joints makes the drawing appear real. Evidently, figures such as portraits attain proportionality. When drawing figures to exemplify three-dimensional aspects, it is important to darken the regions that are further from the light. This reflects the tone of the drawing. The direction of light influences the side of image with the shadow. Interestingly, the strength of the light influences the shade of the shadow. Additionally, lighting in the drawing also affects the feeling created by the figure. Two lighting aspects influence the ‘mood’ of a drawing. This incorporate the direction of lighting, and the magnitude of the light. During high intensity, light may blur some element of texture thus creating a perception.Advertising Looking for essay on art? Let's see if we can help you! Get your first paper with 15% OFF Learn More Composition is a significant aspect when producing quality artwork. Plans are initiated while organizing each of the image’s elements in a proper way thus communicating the mood/feeling to the observer. The positioning of the image together with the lighting will influence the feeling, which comes to the artist’s mind. In essence, the artist’s ideas ought to exemplify the viewer’s perceptions. The distance of the main figure relative to other figures in the drawing is an imperative element in art. This aspect influences the size and the ‘negative space’ in the drawing. This is an important feature in presentation of the drawing since it highlights important themes in the background. The arrangement in the background and emphasis on obje cts highlights the message, which the artist aims to communicate. Indeed, motion becomes articulate with the intention of passing appropriate information. Conclusively, drawings highlight the cultural setting of the artist. For example, aspects of religion may arise as the theme, which the artist intends to highlight. The drawing may represent a deity, group worshippers, and worship places. Music/dance may become manifest after studying an artistic drawing. It is worth denoting that music and worship are subject to separate or comprehensive consideration. Concurrently, drawings on nature may show the geographical background of the artist. This may be an important hint, which may highlight his home setting. Additionally, it may offer a suggestion on the gender roles in the society. Interestingly, economic activities may show how the subjects make their income and the core pillars of the economy. Concisely, the artist may choose the cultural perception she wants to create in the viewe r. Summarily, fine art is incomplete without drawing. Therefore, perfection of the art is important to enhance reality in drawings.Advertising We will write a custom essay sample on Portfolio of the Cultural Perception in the Fine Art specifically for you for only $16.05 $11/page Learn More This essay on Portfolio of the Cultural Perception in the Fine Art was written and submitted by user Jamie Stephenson to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

How to prepare a report or write an article youve been assigned to do.

How to prepare a report or write an article youve been assigned to do. Research.The first thing you should do when you've been assigned to prepare a report or write an article is research the topic in much the same way as you've researched topics for essays or reports.On my first day as a reporter at the Winnipeg Free Press I was assigned to interview the Winnipeg singer Ed Evanko. I had never heard of him so I checked the newspaper's archives for articles. I took such copious notes that I had the first eight paragraphs completed before I met him that afternoon. If Ed Evanko so much as coughed I'd have my story.However, the research served another purpose. I now knew what sort of questions I should ask him.You might wonder how on earth can anyone write a news story by devoting the first eight paragraphs to archived material? I decided it wasn't going to be a news article, it was going to be a personality piece; after all I had reading a dozen personality pieces about him in the Free Press.Large sculpture of a scallop on the beach at Aldeb...The article was prominently displayed the next day on the first page of the local news section, complete with a photo of Mr. Evanko. Although the writing was flat, wooden, nd completely lacking in rhythmn and tempo it proved serviceable. The article began as follows:Fifteen years ago an 11-year-old boy made his stage debut in the part of a one-armed wooden soldier at Faraday School in West Kildonan.Edward Evanko, tenor and actor, recently returned to Winnipeg to play a leading role in The Fantasticks.Since that first appearance, Mr. Evanko, a Winnipegger, has studied under Stefan Pollman, a friend of the late Johannes Brahms, worked under the direction of the British composer, Benjamin Britten, and played before the Queen Mother.His prospects...

The Lost Maya Village of Cern

The Lost Maya Village of Cern Cerà ©n, or Joya de Cerà ©n, is the name of a village in El Salvador that was destroyed by a volcanic eruption. Known as the North American Pompeii, because of its level of preservation, Ceren offers a fascinating glimpse into what life was like 1400 years ago. The Discovery ofCern Shortly after dinner started, one early evening in August about 595 AD, the Loma Caldera volcano of north-central El Salvador erupted, sending a fiery mass of ash and debris up to five meters thick for a distance of three kilometers. The inhabitants of the Classic period village now called Cerà ©n, a mere 600 meters from the volcanos center, scattered, leaving dinner on the table, and their homes and fields to the obliterating blanket. For 1400 years, Cerà ©n lay forgotten- until 1978, when a bulldozer inadvertently opened up a window into the perfectly preserved remains of this once thriving community. Although it is presently unclear how big the town was before it was destroyed, archaeological excavations conducted by the University of Colorado under the auspices of the El Salvadoran Ministry of Culture have revealed an astonishing amount of detail of the working lives of the people who lived at Cerà ©n. Components of the village excavated so far include four households, one sweat bath, a civic building, a sanctuary, and agriculture fields. Negative impressions of agricultural crops, saved by the same flash-heat that preserved images at Pompeii and Herculaneum, included 8-16 row corn (Nal-Tel, to be exact), beans, squash, manioc, cotton, agave. Orchards of avocado, guava, cacao grew outside the doorways. Artifacts and Daily Life Artifacts recovered from the site are just what archaeologists love to see; the everyday  utilitarian wares that people used to cook in, to store food in, to drink chocolate from. The evidence for ceremonial and civic functions of the sweat bath, sanctuary, and feast hall is fascinating to read and think about. But really, the most spectacular thing about the site is the everyday normality of the people who lived there. For example, walk with me into one of the residential households at Cerà ©n. Household 1, for instance, is a cluster of four buildings, a midden, and a garden. One of the buildings is a residence; two rooms made of wattle and daub construction with a thatched roof and adobe columns as roof supports at the corners. An interior room has a raised bench; two storage jars, one containing cotton fibers and seeds; a spindle whorl is close by, suggestive of a thread-spinning kit. Structures at Cern One of the structures is a ramada- a low adobe platform with a roof but no walls- one is a storehouse, still filled with large storage jars, metates, incensarios, hammerstones and other tools of life. One of the structures is a kitchen; complete with shelves, and stocked with beans and other foods and domestic items; chile peppers hang from the rafters. While the people of Cerà ©n are long gone and site long abandoned, the excellent inter-disciplinary research and scientific reporting by the excavators, coupled with computer-generated visuals on the website, make the archaeological site of Cerà ©n an indelible image of life as it was lived 1400 years ago, before the volcano erupted. Sources Sheets, Payson (editor). 2002. Before the Volcano Erupted. Before the Volcano Erupted: The Ancient Cerà ©n Village in Central America. University of Texas Press, Austin. Sheets P, Dixon C, Guerra M, and Blanford A. 2011. Manioc cultivation at Ceren, El Salvador: Occasional kitchen garden plant or staple crop? Ancient Mesoamerica 22(01):1-11.

Evaluating an International Human Resource Strategy (Sarun) Essay

Evaluating an International Human Resource Strategy (Sarun) - Essay Example The report mentions PESTLE analysis, necessary to understand how and why they shape their HRM strategy in India. The report also looks into evaluating the main HRM models that are relevant to the recognized economic drivers for Starbucks. It studies how the interim strategy is benefiting the employees and helping them achieve their career goals. The HRM report also covers an analysis of different approaches of HRM globally and that are actually used at Starbucks and how they can be modified in India. The links identified between the business strategy and the interim strategy are crucial to the differences between international and local policies. The report of Starbucks and corporate also covers the successful impact of HRM policy on overall organizational performance. A section is specifically assigned towards recognizing the employee involvement and participation in how this creates a healthier work environment. The report also looks into the reward system as how Starbucks Corporat ion encourages their workforce to achieve better results. And finally based on the discussion from the literature and the practical examples of HRM in the Starbucks Corporation suggestions are given that will help improve the HRM strategy for their joint venture in India. Starbucks Corporation was established in 1971 Seattle, Washington. It grew to 55 stores in 1989 and today it has over 19,767 stores all over the world (Starbucks Company Profile, 2013). It started its overseas operations in 1996, starting from Tokyo (Bussing-Burks, 2009). The main products sold at the outlets include; ready-made coffee, whole coffee beans, beverages, pastries and other coffee related retail items. Starbucks Corporation belongs to the disposable income industry of food and beverages. Since 1990s the industry has seen tremendous growth, this also brings a lot of competition for Starbucks.

The Piano Lesson by August Wilson Research Paper

The Piano Lesson by August Wilson - Research Paper Example The point of the disagreement is the piano. Boy Willie has travelled to Pittsburgh to get his portion of the piano, which is presently in the ownership of Berniece, his sister.   Boy Willie is a ruffian, and thinks that the profit from the piano gives him his finest opportunity to surpass the social and economic persecution that has troubled the men in his family (Boan 73). Yet, his vision of a better life is prevented by the refusal of Berniece to put on sale what is, she believes, a very important symbol the family’s history. All over the play, therefore, the piano becomes a criterion through which conflicting perceptions of the past could be assessed. The outcome is that Wilson has re-interpreted the difficulties of bearing the weight of history, which is at the core of his other stories, into an issue of how to use history in the most effective way. As Wilson said (Krasner 327): â€Å"The real issue is the piano, the legacy. How are you going to use it?†Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚     Wilson dreamed of writing a ten-play series that would highlight the history of African Americans in his country. He tool on the responsibility of an ancestral ‘griot’ whose obligation was to protect and perpetuate his culture’s history and heritage: â€Å"†¦ the role of the griot is significant since it is with him we mark the beginning of African literary tradition as we know it† (Miller 97). So as to accomplish this he engaged in his ten-play series which would introduce the experience of the African Americans to his fellow citizens and to the rest of the world.

Nutrition and Body Essay Example for Free

Nutrition and Body Essay All macromolecules are essential to the body. One has to have the right amount of all of the macromolecules in order to be healthy. It is believed that high protein diets with carbohydrate restriction causes weight loss. However as a result of high protein diet, one damages his/her kidney which is responsible for filtering proteins from blood. In the article, Janine says, â€Å"If you eat too much proteins and not enough carbs you can ruin your kidneys forever.† I agree with Janine, one has to have enough carbohydrates. Carbohydrates are important in the body as they provide energy for short term storage. However if one does not have enough carbohydrates in his/her diet, it affects the brain. Glucose from carbs is the fuel that brain uses to produce energy that moves and motivates one therefore one has to have glucose in the body. Mitchell has this misunderstanding about carbs and fat. Mitchell thinks that if one cuts down on carbs, he/she is actually training the body to burn fat instead. Fats and carbohydrates are two different things. If one is gaining weight, that’s because of calories. The amount of calories one takes causes obesity. Obesity is linked with poor body image. A positive body image is maintained by eating foods that contain fewer calories in it. A person’s weight is affected by genetic inheritance, nutrition and physical activity. Perceived body size is affected by media, puberty, and peer groups. All these factors affect body weight and perceived body size. Metabolism refers to all chemical processes that go on continuously inside the body. The amount of kilojoules your body burns at any given time is affected by your metabolism. Thyroid gland located below the larynx produces thyroid hormone which controls metabolism, growth, body temperature, muscle strength and appetite. Homeostasis is the process used by the body to maintain a stable internal environment. Hormonal regulation of metabolism such as when blood sugar levels rise in the body, insulin is secreted by the pancreas to covert glucose into glycogen, and when sugar levels in blood fall, glucagon is secreted by the pancreas to convert glycogen into glucose. If people have high blood sugar, they get diabetes. If people have low blood sugars, they get headaches, hunger, pale skin etc. Maintaining a normal blood sugar level is very important in the body. In the article, Mitchell says, â€Å"I get pretty hungry and I was getting headaches.† I think it’s because of having low blood sugar level. Mitchell has high  insulin and less glucagon hormone in the body. The advice I would give to Mitchell is to stop dieting and eat healthy foods that contain fewer calories. Mitchell needs to have physical exercises, healthy foods and self-concept.

Whether Business and the Economy Across the Globe :: Economics Trade Imports Marketing Essays

Business and the Economy Across the Globe Task - 1 Discuss whether firms like Rechem should be allowed to "import" chemical waste from overseas to be disposed of here in the U.K. ANALYSIS Rechem have thirty years of experience in solving environmental problems caused by a wide range of hazardous and toxic materials. Their range of services included the following:  · Waste Management  · Logistics  · Incineration  · Project Management  · Recycling  · Environmental Monitoring DISCUSSION Not all Countries in the World have the ability or the technology to safely dispose of chemical waste such as polychlorinated biphenyl’s (PCBs). It may be argued that it is more desirable and safer to move the waste to another country for disposal. The alternative of storing the waste for long periods of time may result in serious problems and consequently cause pollution effecting living organisms beyond the host countries borders. There has been instances where one country’s pollution problems in turn pollute neibouring countries such as Mercury used in manufacturing process eventually leaking into river systems (This happened between Canada and the United States). Another example is acid rain caused by burning fossil fuels without capturing or burning off the chemicals that cause acid rain, for example, UK’s industrial plants affecting the forests of Germany and Scandinavia. Chemical pollution has no boundaries, dumping chemical in the North Sea by the northern European countries not only destroys the food chain in that area, but, with tidal and ocean currents, this pollution can affect organisms and eventually human beings on the other side of the globe. Pros:- of firms like Rechem importing & disposing chemical waste: 1. Helps the environment because it discourages landfills. 2. It breaks chemicals down at high temperatures not a low normal temperatures which can be dangerous. 3. It can break down PCB’s which are extremely dangerous. 4. Brings money into the British economy. 5. Supplies jobs for workers. 6. Licences for this type of disposal is limited and helps the environmental factor of other countries that do not have this process and have to resort to landfills or burning the waste at dangerously low temperatures like, America and Germany. 7. In the eighties many articles on "green" companies and industries featured Rechem 8. Rechem were praised by the Minister for the Environment at the time as "true friends of the earth" 9. Rechem were acknowledged as a world leader in the safe incineration of dangerous

Unhealthy America

American is supposed to be the strongest nation in the world however we have managed to grasp the largest and most unhealthy nation trophy along with it. Americans care more about how quickly they can grab a meal rather than what that meals consists of and how bad the food is for the body. Americans are becoming increasingly unhealthy with every meal they consume. My aunt went on a trip to Greece recently where she says the food was exquisite and utterly delicious. While she was crashing a Greek wedding she got to experience some of the traditional food. She said the meats were fall off the bone tender with more explosive tastes than her taste buds could handle. She said the salad was a rainbow of green lettuce with mixed with reds of all colors for tomatoes. She produced a tiny bottle that once was full of homemade Greek salad dressing that the mother of the bride had made especially for her daughter’s perfect day. She recalled how immaculate the food was saying specifically she had never seen such amazing foods in America and wished she could bring the cooks back with her. She later told me that when she got back to the states, she realized just how bad she ate before she went on her trip and she sees more clearly now just how unhealthy Americans really are. Her story prompted me to step back and look closer at how we as a nation choses what we are eating. I took my son to the grocery store to get food for the next couple weeks. I made all of his food myself instead of buying processed baby food because I know it is much healthier for him and it makes me think about what I eat. While we were in the fruits and vegetables isle, I noticed we were one of three people shopping in this area while the rest of the market place was packed with people. With the previous conversation stuck in my head, I decided to look around at what others were purchasing around me. I spotted a woman with a shopping cart mounding over with food. The looks of her cart reminded me of a contest I watched on TV where the mom got 5 minutes to get as much stuff as she could and by the end of her 5 minutes her cart was overflowing with stuff. As I watch her carefully choose what she was placing in her cart I realized we were in the frozen foods section. She was staring at a glass door intensely. Behind that glass door sat probably 20 different variations of ice cream. While this stranger and her overweight daughter discussed the options together, I watched her pick up two different one gallon containers of ice cream. One container had chocolate swirls throughout the off white vanilla ice cream and the other had the same chocolate swirls accompanied by pink strawberry swirls. I could hear her daughter asking for one kind and her mother saying she wanted the other kind. So instead of having to choose between the two different gallons of ice cream, she placed both containers in her already overflowing cart. I could sense both of their insulin levels increasing as they began to walk away with their prized frozen treats. While I was standing in the isle with this mother-daughter duo, I was able to get a good look at what they had stuffed in to their cart. I saw several blue boxes of Mac-N-Cheese paired with packages of processed animal intestines otherwise known as hotdogs. I could count six boxes of Hamburger Helper and each one a different variation but all boxes had the detail in bold of being doubly cheesy. I would think that a box of processed food that only needs to have water added to it is not the healthiest meal a mother could make for her child. I also spotted a couple 12 packs of various types of soda. I saw short green soda containers of individual bottles of Mountain Dew placed neatly on the side wall of her cart. Thinking to myself I remembered something I read saying that Mountain Dew has the most sodium per bottle than any other soda drink in the business. I came to the conclusion that my aunt was right. We as a nation are not only eating unhealthy but teaching our children to do the same as well. After leaving the grocery store with our fruit and veggies in hand, I decide to stop at fast food restaurant to grab a salad for lunch. While in line the person ahead of me places his order. The young lady taking his order is a very short woman with a very wide stance. As he gives his order I recount the experience that I had just had, watching this stranger and her daughter purchase mass quantities of food that were processed and extremely unhealthy. The gentleman tells the cashier he would like a Quarter Pounder with cheese. He asks for an extra slice of cheese, extra pickles and no lettuce or tomato. While the young lady quickly punches thing in to her computer screen to detail the order to his specific wants, he also adds that he would like to supersize his meal and requests a fresh batch of French fries. In my head, still reeling from my conversation with my aunt, I thought about how much grease this man is going to eat in just his lunch sitting. The woman waddled over to the fryers that were full of what looked like grease that had not been changed in a week, pulled out a new bag of frozen French fries, filled the container full of them and slid them in to the hot, boiling grease to cook. With his order being made, I couldn’t help but to think of all of the calories in his meal that he was getting ready to devour. He stepped aside waiting on his food and I placed my order for a grilled salmon salad with no dressing. I quickly realized our two orders couldn’t be more on the opposite sides of the nutrition chart as his meal was nothing but fat and grease and mine containing lettuce, fish, cheese and tomatoes. Another stranger opting to eat absolutely nothing good for them. As I sit down to enjoy my salad I look around and see the meals of others in the restaurant. I take out a package of already cut up bite size pieces of peaches for my son to each since he is only 7 months old. Trying to be inconspicuous, I look at the table next to me. A mother and her two young children are sitting, enjoying their lunches. The mother had a cheeseburger with so much ketchup running out of the sides you would think there was more ketchup that meat. Her youngest son had a 10 piece chicken nugget meal. The nuggets were obviously fried but the meat inside was a strange color of grey leading me to believe it was imitation meat. The little boy devoured each nugget only after carefully dipping each one of the nuggets in to a tub of barbeque sauce, making sure to lather each inch of the nugget to his desired amount. The oldest boy had the same fried, strangely grey food but was dipping his nuggets in to ketchup. In my head I couldn’t help but to sum up their lunch as to being fried fat and fried imitation meat, all lathered in a sodium filled dipping sauce. I quickly finished my meal and headed for the door. I had set my mind that I would not be like that mother, teaching her sons that eating unhealthy was acceptable. As I started putting away my groceries, I also started riding my cupboards and refrigerator from anything processed. It was clear to me that the word unhealthy was quickly becoming our nation’s primary adjective. As I reflect on my conversation with my aunt and the experiences I had with the unknowing strangers I watched purposely chose fatty, processed, fried and ultimately the most unhealthy foods possible, I realized obesity is not just a term used to define a plus size individual but a growing epidemic that is quickly spreading across our great nation. Unhealthy Americans are more prominent in society today and the growing trend does not look to be slowing down any time soon.

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