#watch me audition for something in the future and say my experience is customer service

[alicelong]

15th January 2021

I keep thinking about Uni life – my previous student life, particularly my third and final year, how I enjoyed it so much, I was excited about what the future held (sell out at a bank for a while, but skim over that.) That’s a joke I say to myself, that I went the opposite to my studying, rather than into a creative or art-based route. Oversized shirts and ripped leggings were folded away in exchange for blouses and pencil skirts. Now I’m reverting back to my roots and I couldn’t be happier about it! I tried the other side, for a while I did think ‘yes this is for me,’ I really liked helping customers, fixing their problems and making them smile and a massive part of my job in management was helping and motivating my team. I think this is because I am a bit of a people person. All of my jobs from sixteen were customer service based, I enjoyed being around people, talking (endlessly at times) I enjoy observing people too. I remember getting coffees with my best friend, once we’d had a catch up we’d people watch, making up background stories as to why they were in the shopping centre, even putting on voices and accents. I am not the best at accents. I do try! If I’ve been watching a film or show with different accents I can lean into it more, Gavin and Stacey being a prime example as to when I can pull of an excellent Welsh accent. Theatre Love: I have still stayed creative in other ways during these sell out banking years. Cooking and baking. I love musical theatre, making my own money and having odd days off in the week I was able to see more shows at last minute discount prices too. I think the most was seven in one year, from most shows I have bought a souvenir mug, all of which I’ve cleaned, catalogued, wrapped and packed ready for the move. I love the theatre, I have seen more musicals than plays, the plan was to see more dramatic performances this/last year, however the pandemic had other plans. Its heart-breaking that the theatres have been closed for over six months now and the lack of funding and support performers and theatres have received. When I’m having a bit of a wobble day or just generally in a shitty mood I tend to put on a musical soundtrack, listening from start to finish imagining the show on stage in my mind. I get so swept up in the story telling through song, sometimes I laugh, others I cry. I always get goosebumps that’s a constant with all. One of the first shows I remember seeing was Joseph and the technicolour dream coat, I was in primary school and carried on singing ‘any dream will do’ on the drove home. When I really got the theatre but though was at 10 maybe 11 after seeing We Will Rock You. That’s when my little intrigued and analytical brain started switching on. I used our family PC (dial up internet times) to google the show, when it was made, who starred in the Broadway and West End runs and so on. I went to our local library with my Dad to check out the live recording CD, he helped me to make a copy and I’d play it on repeat in my room re-enacting my favourite parts of the show – I Want To Break Free and Somebody To Love were firm favourites. I developed a big love for Queen too and remember feeling so upset after discovering Freddie Mercury was no longer alive, as I would hear their songs on the radio and see their albums in my Dad’s CD collection it didn’t dawn on me how long ago they were made. Time and decades weren’t something I thought about much, I enjoyed the moment and the now. (That’s something I’m trying to do more of now! Less worrying of what I should or done earlier or what I need to do in the future!) I have even seen a show on my own. I had a ‘me day’ up London. I don’t mind doing things on my own, going to the cinema, art galleries, shopping. I became comfortable with my own company and enjoyed my time to think, explore and learn. I had a stall seat at The Savoy, it a matinee showing of Funny Girl with the amazing Sheridan Smith. I treated myself to prosecco during both acts and the matinee. I had a warm, fuzzy glow after leaving the theatre. A combination of the alcohol and endorphin rush I had from seeing such a brilliant performance. Oh I miss that feeling! (I’m currently completing dry January, a cold glass of prosecco would go down a trear right now!) I even considered a career in the performing arts, attending theatre school for a year and a half. I had a mixed relationship/feeling over this time. I enjoyed learning new things that I wouldn’t at school, meeting new people and the praise I would get from the dance teacher in particular. I was in the ‘younger group’ ages 7-12 whilst my sister was with the teenagers. I wanted to be with the older lot as they seemed to be doing more, they had more stage time on the shows too – I looked up to the older girls, who oozed with confidence and were going to auditions for advertisements and tv shows. It was at this time that I was becoming more aware of my body and weight, I started comparing myself to them, wanting to be thinner and have longer hair. I didn’t think I’d have the chance of getting any parts and didn’t sign up to be a part of the audition process yet. I felt like the bigger and old one in my pre-teenage group, so many of them were dainty and cute. God, I just would compare myself to either group rather than make the most of being in the moment. I started to get more and more self-conscious. I knew I’d have to wait another year being with the younger kids before I’d get to be in the older group.  I thought I could have a total transformation in that year, be a part of the ‘cool’ experience, pretty crowd. But in the end, I quit. I was getting more self-conscious each week, the excitement I had when I joined was being clouded by my own negative voice and opinions of myself. I have thought about revisiting this, knowing that there are adult performing arts groups, I’m not the best singer but also not the worst. Fitness and exercise are a big thing for me now, I feel like I could use that determination and drive to learn dance routines. Who knows.

[perfectirishgifts]

IRS At Supreme Court Over Captive Insurance

New Post has been published on https://perfectirishgifts.com/irs-at-supreme-court-over-captive-insurance-2/

IRS At Supreme Court Over Captive Insurance

Hand holds documents Captive insurance about insurance.

The Supreme Court rarely hears tax cases which makes the recent oral arguments in CIC Services v IRS exciting. That is about all that makes them exciting to ordinary mortals as what was going on at the Supreme Court was an argument about whether they could have an argument.

In 2017, CIC Services and Ryan LLC brought an action in the United States District Court for the Eastern District of Tennessee asking to set aside IRS Notice 2016-66 as modified by IRS Notice 2017-08. Both the District Court and the Sixth Circuit ruled that the action was barred by the Anti Injunction Act. The notices concern micro-captive transactions.

Micro-captive has a science fiction sound to it, Makes me think of Kandor – the Kryptonian city in a bottle that Superman kept in his Fortress of Solitude. That’s not it, though. It is about insurance, sort of. Simplistically, a captive is an insurance company that is owned by the insured or related parties. Micro means it takes in less than $2.3 million in premiums. (I’m simplifying. The threshold has been changing.).

So You Want To Own An Insurance Company

Warren Buffett famously likes to own insurance companies. He explained it in the 2019 Berkshire Hathaway Annual Report:

One reason we were attracted to the P/C business was the industry’s business model: P/C insurers receive premiums upfront and pay claims later. In extreme cases, such as claims arising from exposure to asbestos, or severe workplace accidents, payments can stretch over many decades.

This collect-now, pay-later model leaves P/C companies holding large sums – money we call “float” – that will eventually go to others. Meanwhile, insurers get to invest this float for their own benefit. Though individual policies and claims come and go, the amount of float an insurer holds usually remains fairly stable in relation to premium volume. Consequently, as our business grows, so does our float.

The Tax Leverage Of Insurance

So running an insurance company you can make or lose money from paying out more or less in claims than you collect in premiums – the underwriting income – and from your investments while you hold onto the money,

Back in the day, it was even better as insurance companies could deduct all those amounts that they expected to pay in the future. The Tax Reform of 1986 cut into that a bit, by forcing them to discount the expected payouts to present value. That was a much bigger deal back in the eighties when money earned interest. It was very complicated.

TRA 1986 carved out a break for smaller insurance companies. A small company, based on premiums written, can elect to only pay taxes on its investment income. The underwriting profit or loss is not considered in determining taxable income.

When you view all this in the aggregate considering both the insurance companies and their customers, there is some tax leverage at play. When people are insuring business risks they can deduct the premiums as ordinary and necessary business expenses immediately. The insurance companies ultimately will recognize income to the extent they don’t pay claims, but that will be over time unless they are one of the electing small companies.

If the customers decided to self-insure, they would not get a deduction for money they put aside to be prepared for whatever eventuality they were insuring against. At a very basic level, that is the tax incentive for a captive insurance company. There is a lot more to it than that. Your captive insurance company can go into the reinsurance market allowing you to lay off some of the risks in a more flexible way than you can with commercial insurance. So there can be business reasons independent of tax incentives for setting up a captive insurance company.

The Shenanigans

If you don’t see the potential for shenanigans in all this, you have not thought much about it.  If the customers get to deduct and the company does not have to pick up income there is one of those rifts in the space-time continuum when that big balance sheet in the sky does not balance. That’s the part of the universe where abusive tax shelters spawn.

The way CIC promotes almost implies that.

CIC Services is a captive manager and strategist. Since 2005, we’ve been helping small & mid-sized business owners turn their risk into wealth by owning their own insurance company. 

“Turn their risks into wealth” ?? If the wheels that spin straw into gold are not working, you have to do the best you can.

I spoke with a tax executive for a major life insurance company. Promoters had been trying to get the company’s sales force to recommend captive insurance deals. When he examined them he concluded that there was not actually much in the way of insurance going on. It looked more like alchemy.

If you can pay your own insurance company deductible dollars that the insurance company does not have to recognize as income, the more you pay them the better. That’s the essence of the potential shenanigans. We can see them illustrated in the Tax Court decision in the case of Benyamin Avrahami & Orna Avrahami by Judge Holmes.

Benyamin and Orna Avrahami own three shopping centers and three thriving jewelry stores. In 2006 they spent a little more than

$150,000 insuring them. In 2009 this insurance bill soared to more than $1.1 million and it flew even higher, to more than $1.3 million, in 2010. The Avrahamis were paying the overwhelming share of these big bills to a new insurance company called Feedback that was wholly owned by Mrs. Avrahami. Yet there were no claims made on any of the Feedback policies until the IRS began an audit of the Avrahamis’ and their various entities’ returns. With money flooding in and none going back out to pay claims, Feedback accumulated a surplus of more than $3.8 million by the end of 2010, $1.7 million of which ended up back in the Avrahamis’ bank account—as loans and loan repayments, say the Avrahamis; as distributions, says the Commissioner.

The Practical Effect Of The Notices

In the contested notices, the IRS declared that certain captive insurance transactions were “transactions of interest”. This is not quite as bad as being a “listed transaction”, but bad enough. What the designation does is trigger substantial reporting requirements that are backed by really nasty penalties. There is also collateral damage in that when something becomes identified this way people get nervous about it, which is bad for business. Ryan and CIC mentioned this in the original complaint filed in 2017.

As a result of the IRS audit program, the §831(b) market has, of course, been substantially constricted, negatively affecting captive managers, their employees, and many others who rely on the captive industry for employment, including residents of the State of Tennessee, which, at least for the moment, enjoys a robust captive insurance marketplace.

Reilly’s Fourteenth Law of Tax Planning – If something is a listed transaction, just don’t do it. I think I should revise that with a corollary rule – If somebody suggests a transaction of interest, tell them you are not interested.

I had a long talk with someone who is responsible for the tax practice of a firm that focuses on professional practices. He has fielded quite a few attempts to get his firm’s client’s interested in doing captive deals. When he first learned of the concept, the deals that were presented did not pass the smell test. There did not seem to be any business rationale for what they were doing. Once the notices came out he felt vindicated.

My outreach via #TaxTwitter did not yield much more in the way of anecdotal information. One respondent suggested that captive insurance tends to work well for auto dealers. It is important to remember that there are legitimate reasons for setting up a captive. That is why it is a “transaction of interest” rather than a listed transaction.

An example of the latter is in Notice 2017-10. That notice takes on syndicated conservation easements. Don’t get me started. That is an industry based on nonsense. Partnership For Conservation, the industry trade association, filed an amicus brief in the CIC case.

“IRS statements made around the time and subsequent to issuance of the Notice indicate the real purpose of the Notice was to put an end to the conservation easement donations so described. Comments from IRS Comm’r Charles Rettig include: “Putting an end to these abusive schemes is a high priority for the IRS.” and “[e]nding these abusive schemes remains a top priority for the IRS.“

Lance Wallach

Lance Wallach made a name for himself exposing 419(a) employee welfare benefit plans, a scheme that seems to share a lot with captive insurance in the type of market that it went after. He is very concerned with the possible bad effect that CIC winning this suit might have on tax compliance. He wrote:

In my experience of lecturing, writing, and acting as an expert witness in tax shelter cases, the IRS needs every tool available to it in order to combat the proliferation of the abusive tax shelters. I have watched IRS’s programs grow from the “SON OF BOSS” to 419 welfare benefit plans, 412i plans, section 79 plans, syndicated conservation easements, and section 231b small captive insurance arrangements. These “schemes” are a way for taxpayers to cheat the government out of large sums of money. They are also a way for promoters and others involved in the scams to earn large incomes. Many of these arrangements involve the sale of huge amounts of high commissioned life insurance policies by agents representing life insurance companies, which make huge amounts of money on the sale of these “shelter” policies.

As an expert witness against these life insurance companies, whose products fund many of the abusive tax shelters, I have never lost a case. Almost all the lawsuits have been settled privately. Profitable business owners and professionals are approached by insurance agents or accountants and sometimes attorneys, enticing them to get involved in tax shelters that are usually abusive. The end result for the taxpayer is usually, aggravation, payment of taxes, huge penalties, and interest to the IRS simply as the result of purchasing a product that they really never needed.

I have received thousands of phone calls about these “abusive” tax shelters.

It is my opinion, that the IRS needs every tool available to fight the growth of these abusive tax shelters. The insurance companies and promoters have vast resources to fight the IRS. While most of us dislike and/or are afraid of the IRS, their resources are, in fact, limited.

The Stakes In The Supreme Court

It might not be quite that dramatic. This is the sort of case that only legal nerds really like. The reason the IRS won at that district and circuit is because of the Anti-Injunction Act. Basically, you can’t sue to prevent the IRS from assessing a tax. The penalty for not complying with the notice is defined by Congress as a tax. You will find plenty of coverage on those nuances. The purpose of this post is to look at the broader picture.

Nonetheless, I turned to one of my legal experts who prefers to remain off the record about the stakes.

Peter the key is that CIC has a process for pre-enforcement challenge of whether a regulation is needed. Historically, taxes and penalties that the Code says are taxes (like the one involved in CIC) have permitted only post-enforcement challenge and the AIA (§ 7421(a)) is designed to preclude pre-enforcement challenges in most cases. There are some exceptions though, and I think that is were the Supreme Court will divide – as to whether there can be a pre-enforcement challenge (not whether the challenge has merit).

If CIC convinces the Court that it can mount its challenge (the challenge that a notice and comment regulation is required rather than a Notice), then the Court (probably lower court on remand) will determine whether that challenge has merit.

So the argument at the Supreme Court is about whether an argument can be held lower down.

The Ultimate Stakes

At the end of the day making something a listed transaction or a transaction of interest helps tax enforcement in two ways. All the extra filing identifies deals for the IRS to look at. The extra filing requirements discourage people from engaging in sketchy transactions and make mainstream advisers very wary of them. The ultimate stakes in this litigation are that it would be harder for the IRS to declare that something is a listed transaction or transaction of interest.

In Supreme Court Hears Arguments in Captive Insurer Case, Allison Bell discusses the problem IRS could ultimately face if it loses.

Supporters of the IRS position say that rejecting its ability to impose new reporting requirements through notices, without going through notice-and-comment periods, would gut the agency’s ability to respond quickly to scams and abusive tax shelters.

I am skeptical that that will actually affect tax compliance all that much. The IRS already knows about a lot of noncompliance that it never looks into. My favorite example is alimony. This is from a story I wrote in 2014 about a TIGTA (Inspector General) report.

According to the TIGTA report, there were 567,887 Forms 1040 for 2010 that had alimony deductions. The total claimed was $10 Billion. When they compared the corresponding returns that should have recorded the income, there were discrepancies on 266,190 returns including 122,870 returns that had no alimony income at all reported. 

The IRS examined 10,870 of those returns. They simply don’t have the resources. Getting serious about tax compliance requires more audits, which requires more people.

When it lists transactions, the IRS is to a significant extent bluffing. And shelter promoters are calling that bluff. Forcing the IRS to jump through more hoops to get the transactions listed will probably not be a real game-changer. Bringing IRS staffing back to where it was 20 years ago with an emphasis on sharp enforcement people is what would make a real difference.

Other Coverage

The North Carolina Captive Insurance Association has Long Awaited Oral Arguments In CIC Services v. IRS Before The Supreme Court Of The United States 12/1/2020. Before a rundown on how the arguments went, they give some interesting background on how the case came to be filed.

Beginning in 2017 NCCIA brought the case to the attention of the membership leading some association members to instigate the Captive Insurance Defense Group (“CIDC”) that privately raised monies to file an injunction/declaratory judgment action against the IRS for violation of the Administrative Procedures Act (“APA”). Sean King of CIC Services, LLC was a participant in the CIDC effort. The CIDC needed a plaintiff for that lawsuit. King bravely stepped up as plaintiff (even though his attorney feared possible IRS retaliation). NCCIA was the ONLY captive trade group to file an Amicus Curiae (friend of the court) brief (“AB”) in the initial District Court action. 

Captive Insurance Times expressed optimism for the industry’s prospects with IRS counsel faces tough questions from Supreme Court in CIC Services case.

Richard Rubin had Supreme Court Justices Question IRS Shield in Tax-Shelter Case in the Wall Street Journal.

Jack Townsend on Federal Tax Crimes has Discussion of Criminal Tax Issues in Oral Argument in CIC Services (12/5/20). He also covered the oral arguments more generally of Federal Tax Procedure with CIC Services Supreme Court Oral Argument (12/3/20).

As with any Supreme Court decision, I am grateful to the coverage on SCOTUSblog which allows me to keep my PACER bill from going through the roof.

More from Banking & Insurance in Perfectirishgifts

[love-stickywitchcollector]

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[rewindva]

CVAP Day 4

We had another guest speaker, Sir Tumnic Balabat who goes by The Nick Of Voice. He offered a lot of tips and insight on how to get into the craft and how he has been finding success with in in his journey so far. He mentioned how people should not be idle and wait for others to initiate but that it is better to try and get involved right away. He also recommended to try out various different genres in order to identify your strengths and weaknesses which are necessary steps in finding your niche. He brought up humility and not forgetting where you came from or where you started and also that CVAP can be used as a platform to help encourage others to pursue their dreams in terms of VO.

He gave tips on something he called by syllables but he wasn’t sure of the exact term but I thought he was referring to phonetic pronunciation. He says he has an accent and that by spelling out how things sound it is able to help him with his pronunciation. Take the acronym AGT, he would spell it as EY-GEE-TEE on his script. I didn’t notice an accent from him, he sounded very natural and neutral to me.

He gave tips on how to get clients which include helping friends or people with businesses or content creators and advertisers that do not have VO accompaniment with their projects. He even offers 1 free VO or service to clients initially, this has helped him forge positive relationships with his clients who often go back to him for more jobs. When submitting and joining auditions he encouraged people to be polite and humble. He did touch upon self-promotion and marketing which he attributes as a key to succeeding in this industry since there are so many competitors and your voice is your service or product. He talked about using all forms of social media that you use or plan to use if you want to expand your reach which even included FB stories. He brought up a quote as well ‘no business will ever need to run any promotions if there wasn’t any competition.’ My take on what he said is to be confident but not arrogant in all dealings. He brought up an interesting point in imitating people who are already skilled and established who you admire so you can practice doing what they do if you plan to do similar work and identify what they are doing as your preferred niche.

Sir Choy talked next and he covered the topic of building a home recording studio. Much like Sir Josh last time but in more detail he outlined the necessary things. He said a home studio is a lot less complex and demanding than a full blown professional recording studio and booth. He mentioned that headphones or headsets are sufficient for a home recording studio and that studio monitors are optional. To make it in the industry and have staying power he said you have to be relatable, significant and relevant. Something important he brought up is sticking to your core competencies and to have others help you where you are lacking or better yet to learn and apply it yourself.

Due to the pandemic he said that the people working from home will become like studio themselves carrying out all the work that studios normally do with larger teams. He emphasized the importance of documenting yourself especially for personal growth so you can see where you came from and how much you’ve changed or improved. He also covered websites we could register at once we start to send out auditions.

Sir Choy covered a few other topics about trends and general advice as well. He said a lot of work in translations are prevalent these days with no sign of slowing down. Regarding customer relationships he gave the advice to work within the budget of clients and not just your standard rate all the time as greed corrupts absolutely and is the cause for many problems globally. He also said to not lose your day job as investing in equipment is expensive and also this is a freelance job; you shouldn’t be doing it full time until you’re secure and 100% satisfied with the earnings from it.

This day was particularly interesting for me as it was the most I talked and interacted during the zoom call and in the group chat out of all the other days if at all. I’d like to thank my friend Kuai for encouraging me to participate and interact more, it helped me alleviate a lot of the shyness and inhibitions I was experiencing. I learned a lot about the others in particular Sir Richard who I share a professional background with. It helped me be more comfortable speaking too since I’m the kind of person who usually responds when spoken to but does not normally initiate.

The exercise we had to do is a live dubbing session. My group was pretty shorthanded since a lot of my groupmates couldn’t make it, it was just me, Sir Fred and Jessica. We were deciding between a Filipino comedy sketch or a Korean drama, we wound up going with the prior option. It was very difficult to make on the spot since we had to make a visual presentation out of it with visual aids; I really felt the time constraints but Ms. Nikie was training us for pressure situations where different clients and directors will require different things at different times. It was pretty fun though and I enjoyed watching the other groups’ performances. All in all it was a good day for me I think and I really enjoyed myself and started coming out of my shell a lot more too.

The assignments we were given are a group recording of the live dubbing and something I’m sure that is going to mess me up which is to read and react to a letter we had to write to our future selves. I’m sure it’s going to be an emotional experience for me as I already experienced crying quite a bit while I was writing it and reading it over. I’m not looking forward to that but whatever is necessary I guess.

[kuwaiti-kid]

Unmasking the Armorer: Emily Swallow Talks About The Mandalorian, Fans, and Set Life

Emily Swallow has appeared on both stage and screen, lending her talents to roles on The Mentalist, SEAL Team, Castlevania, and most notably as “Amara” on Supernatural and as “The Armorer” on The Mandalorian. 

Maggie Lovitt (ML): When I told a couple of friends that I was going to interview you, they got super excited because you’re from the DMV like we are. Are you proud to be from this area?

Emily Swallow (ES): I am! When [my husband and I] were driving down to Florida we drove by the sign for Walter Reed Army Medical Center, which is where I was born, and I pointed it out to my husband. I love Virginia. I loved going back there for school. I mostly grew up in Jacksonville, Florida. We moved down here when I was seven. I went back up there for the University of Virginia. 

ML: How did you get into acting? You initially went to college for something entirely different, right? 

ES: UVA was where I made the decision to pursue acting as a career. I did theater in middle school and high school, and I also did community theater. When I was at UVA I was a Middle Eastern Studies major and I thought I was going to go into the foreign service. I was also very heavily involved in the drama department and I’m so grateful that the drama department there is so open to non-majors, because it meant I could do both things. Then I had a really wonderful acting teacher who encouraged me to think about pursuing acting. He helped me work on auditions for grad schools and I auditioned for several. I got into NYU and I knew it was a good one, so I figured I should take advantage of that opportunity. I’m so glad that I did. 

ML: How did you get your SAG card?

ES: You know, I was asked this question in another interview recently and I’m not entirely certain what my first SAG job was. I was trying to look back on my member page to see when I became a member, but it didn’t tell me. I think it was a movie that I did called The Lucky Ones a few years after I was out of NYU. I mostly did theater and then I did a little bit of TV. I feel like the television work that I did at first was back when SAG and AFTRA were two different unions. I think some of the work I did was AFTRA work. 

ML: Did you grow up as a fan of Star Wars? 

ES: I was a fan, but I don’t think I had any idea of the depth and the breadth of that universe. I definitely remember the movies being part of my childhood. I remember Ewoks dolls and I absolutely played Princess Leia in reenactments with my friends. I had seen the other movies since then, but the whole world of the Mandalorians was pretty new to me because I hadn’t seen The Clone Wars or any of the animated series. Now [that] I have gotten to watch them, I think they’re just so fun. Star Wars was something that was such a big part of my childhood, but now being reintroduced to it and getting to learn so much more about it has been cool. 

Photo credit Diana Ragland

ML: Supernatural and Star Wars which both have massive fan bases. What has that experience been like?

ES: It’s such a gift. One of the things I miss when I’m doing film work is the connection to the audience. It’s part of theater that’s just so immediate. It’s so wonderful to get to feel that connection that so often you miss out on with TV. Doing these conventions and getting to meet these fans and find out what kind of impact the shows have had on them, what moment stood out, and what they like or don’t like about your character has been really cool. 

I feel that the Supernatural fan base is just beyond anything I had ever experienced before and now, getting to meet the Star Wars fan base, it is another level beyond that. Star Wars has forty years of fans and you get entire families that watch it together. I love that. I will say that there is this incredible feeling of joy that I’ve experienced from all of the Star Wars fans. They’re just giddy with happiness to get to cosplay characters and get to meet the different actors. Both communities really watch out for each other. I love the community that they have built. 

ML: A fan created a custom-made Armorer helmet for you, didn’t they?

ES: Yes! I didn’t get to keep mine because they’re holding onto that for future use. A fan who does his own stuff for cosplay and makes things for other people showed up at this convention and handed me the helmet. I was like “Wow, this is incredible!” and then he told me it was for me. I just lost it. I couldn’t believe it. I was just so excited. I brought it down to Florida with me to show my nephews. This is the only thing I’ve ever done that they’re actually interested in. 

ML: It seems like a great time to have an Armorer mask.

ES: The Armorer was just setting the trend before it was even necessary. 

ML: Both Pedro Pascal and Gina Carano have mentioned that they were sort of handpicked for their roles. What was the process for you? Did you have to audition? 

ES: I did audition. This was one of the characters that they didn’t have a specific actor in mind for. Actually, when they were first looking for people they were auditioning British women in their fifties and sixties. I am not either of those things. 

It was incredibly lowkey. I knew that it was something to do with Star Wars, but I knew so little about it. I didn’t know if it was a big deal or not. The audition itself was just me in the room with the casting associate and a video camera. I just had the scenes that they had given me and very little information because it was so secretive. 

ML: Did they tell you that she was masked? 

ES: They did. Which influenced my audition a little bit. But since I wasn’t actually wearing a mask in the audition, it didn’t really change the way I did it too much. I think I paid more attention to how I moved my body and communicated more that way. 

ML: Is that where the British accent came from?

ES: It was the casting associate that suggested that I do it with a little bit of British accent, because they had been seeing Brits for it. We just did it a few times and that was that. Then I got the call from my agent. I was still so unsure about what the show was. I didn’t know how many episodes I was going to be in. It was very shrouded in mystery. 

ML: Were you provided with any information about the Armorer’s backstory? 

ES: I wasn’t given anything specific about where she came from or what her origins were. It was mostly about how she functioned within this clan of Mandalorians. The function that she served as their spiritual leader, the one who keeps the history, and obviously the one who makes their armor. 

Jon Favreau mostly talked about images and the feeling of a lot of old [Akira] Kurosawa films. How the Mandalorians were like a samurai order of warriors. [He discussed] the formality and the regal feeling that some of those characters have. It felt like the Armorer needed to move very simply. He described her as a very zen-like person. She’s someone who has a lot of authority but doesn’t need to put it on display, which I really liked about her. 

ML: Did you come up with a backstory to work with? 

ES: This is not confirmed by anyone else in the production, but in my mind I felt that she knew Din Djarin when he was younger. So she knew a little bit about his origin and the path that he had been on. How he’s become this lone ranger. How he’s really lost touch with where he comes from. I feel like when he comes back to see her in that first episode, it’s like he’s coming back to his roots and starting to step into who he really is. 

ML: Do you think we might eventually get the Armorer’s backstory?

ES: It’s entirely possible. But there’s so many parts of the story to tell. 

ML: With so many of the roles on The Mandalorian requiring actors to wear full armor, what was that like? Did you all bump into each other a lot? 

ES: Oh my gosh, yes! It was ridiculous for those of us that were in the Mandalorian helmets. You don’t have a lot of peripheral vision. We realized very quickly that any extraneous movement was distracting because when you can’t look at someone’s face to see what they’re expressing, you find yourself looking that much more closely at their mannerisms. So anything extraneous took away from the story we were trying to tell. Just walking across a room, you can’t look down to see where you’re walking. That had to be stepping forward on faith that you weren’t going to fall on your face. But then in between takes, when we were trying to get situated and get into place, we were bonking heads and tripping over things. I would drop all of my tools for my welding and my forging. 

I keep saying that I hope they’re going to release a blooper reel because I think it would be pretty entertaining. 

ML: Watching the Disney Gallery: The Mandalorian program, it really showcased what a fun and creative set environment the series has. 

ES: I think that Jon [Favreau] and Dave [Filoni] really set the tone. Everything was very well communicated; the feel of the story and the overall arc of the story. Jon really encouraged the directors to lean into their own styles. There was such a feeling of trust. I feel that it relaxed and inspired everyone to work really hard to do their best. 

Everyone working on the show has so much love for the Star Wars world. All of us felt like this was our childhood dream come true. I was amazed every day at the level of artistry in my forging tools, all the little details in the sets and costumes. In my experience, it was a really joyful place to be. My work was limited to my forging studio and I’m sure it was a lot more physically exhausting to do some of the stuff in the desert settings. But everyone just gave it their all. Everyone was willing to pour their hearts into it and that just absolutely came across. 

ML: You have done voice acting on Castlevania, did that help you prepare for the Armorer when all of the dialogue is done with a mask on? 

ES: I think so. I think that it did come in handy. The voice is one of the first ways that I am able to connect with a character. My background before acting was in music, which might have had something to do with it too. My preparation for a voice acting character isn’t dissimilar from my preparation for other roles. I’m still trying to connect to the characters. Having that physicality, even if you’re only going to hear my voice still informs my voice. But it’s really fun to be in a voice-over booth, you have so much freedom to move how you want. You can do anything you want to do to connect to the character.

ML: Did you have to do any of the combat for the scene where the Armorer takes on the Stormtroopers? 

ES: I did a very little bit of it. I wanted to do it so badly, but the level of skill that the woman who did do combat was not a level that I could achieve in the time we had to film it. But I did train in a martial art style called Kali, which is what a lot of the fight was based in. I did some of the ends and outs and some of the transitions. The coolest parts of it were someone who is much more skilled than I am. I have to give credit where credit is due. That also was a moment that, even though I knew what happened in the scene, when I watched [the episode] it was just so incredible to see. 

ML: What were your favorite scenes to shoot? 

ES: I loved shooting the scenes prior to that one, where I get to reveal that The Child is in the line of the Jedi warriors. There was something so cool about getting to say “Jedi” and introducing that to the story, since it hadn’t been mentioned before that. It gave me the shivers. I like that scene for all of the action in it. Din finds out that he’s in charge of this child-being. I love getting to give him the jetpack. So many cool things happen in that scene. 

ML: That puppet. What was it like seeing the Child in action? 

ES: I didn’t realize just what an impact the Child was going to have. I didn’t get to read all of the scripts. I had the scripts for the episodes I was in and I also got to read six or seven. I didn’t have the entire story. I didn’t realize what a huge role he had. I was getting to experience a lot of the story at the same time as everyone else was watching it for the first time. I knew so little when we were shooting the series. It was really fun to get to be an audience member. 

ML: If you could choose your own sigil, like the Mudhorn sigil the Armorer crafted for the Mandalorian, what would you choose?

ES: Oh man! I think it would probably be my dog Norma. She would look pretty good. She’s half French Bulldog, half Boston Terrier. She’s got these incredible ears. I think her silhouette would look pretty good as a Beskar seal. 

Photo credit Disney/Lucasfilm

  ML: How heavy was the armor? 

ES: The armor wasn’t so bad. It was leather and a kind of canvas material. The leather was pretty supple, so it moved fairly easily. I wouldn’t say that I would love to wear it every day of my life, but it was very easy to move around in. The one thing that was challenging was the gloves that they made me. They looked great, but they were too big for me. It was very challenging to handle my welding tools. What turned into these beautiful forging sequences, were anything but that when we were filming them. I had trouble picking things up and I kept dropping things. I couldn’t tell if I was holding things right. That’s one of the times where you’re glad that you’re doing it on screen. They can just edit it to look great. You can’t do that in theater in front of the audience. 

ML: As a second teamer myself, I would love to know if the stand-ins ever had to wear pieces of the armor during camera rehearsal or just stunt doubles.

ES: We didn’t really have a lot of rehearsals outside of shooting. Most of the time we were dressed and ready to go. Especially for Pedro [Pascal] there were a number of stunt doubles and body doubles that were dressed up in the full Mandalorian armor. Most of us were just hanging out in our armor all the time, which was a great bonding experience. 

ML: Now, I thought I’d ask some fun questions. What is the earliest call time you’ve ever had?

ES: I don’t think I’ve ever been called before 4 AM. I was on the CBS show SEAL Team for a lot of this last season and most of my scenes were first up. Most of my mornings there started at 5:18. 

ML: What was your longest day on set? 

ES: I’ve had some sixteen and seventeen-hour days. I had some really long days on the set of Supernatural. Not the season eleven finale, but the episode before that. I was involved with fighting these angels and demons. My character got really beat up so I had a lot of prosthetics and make-up put on for blood, scarring, and burns. I had to get there early to get all of that put on, then there were long days of shooting, and it took awhile to get out of it [after wrap]. 

ML: I love Vancouver. It's one of my favorite cities.

ES: It’s a great city. I had never been there before I started working there. It’s my favorite place to go to work. I just love that it’s so easy to get out into the mountains or to the beach. It’s just beautiful up there. 

ML: I always joke that I got into acting because I love set catering. Which set had the best catering?

ES: Oh no! I think Supernatural. That might be because it’s the most recent in my memory, but the guys who cater for them have been there for years. First of all, they’re so kind. They’ll make you whatever you want. I’m somebody who likes to have a big creative salad and they always had great salad fixings. 

ML: What is your greatest weakness at crafty?

ES: Doritos! It’s so simple. 

ML: I bet the wardrobe loves that. 

ES: You can’t really hide when you’ve been eating Doritos. 

ML: There’s a great debate on sets about which is the best sparkling water. La Croix, Bubbly, or another brand? 

ES: I’m a fan of La Croix’s pamplemousse. It’s the grapefruit flavor, but it’s so much more fun to say “pamplemousse”. 

ML: What is something you always need to have with you in your trailer? 

ES: I always live in fear of having nothing to do on set, which is sort of ridiculous because there’s always something to keep you occupied. But I like to bring a book with me. 

I always bring my journal because if I have to wait a long time after hair and make-up, it helps me keep focused on the character and the work I’m doing that day. I love having good music in my trailer. One of the things I dislike about film is how much time you spend in your trailer. It’s a tiny space without much to do. I like to have some music in there. 

We wrap up the interview by discussing the uncertainties of this new world we’re living in. Her husband, Chad Kimball, is part of the cast of Come From Away on Broadway, where there’s a question about when they’ll return. 

“We can worry and fret, or we can assume that things will work out for the best. We might not know what the future looks like, but sometimes when things fall apart they might come back better than they were before.” 

The post Unmasking the Armorer: Emily Swallow Talks About The Mandalorian, Fans, and Set Life appeared first on Your Money Geek.

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[charlesjening]

An Interview with a Paperless Practitioner Doing Things Her Way

Welcome back to the second in our series of interviews with Gusto partners who just so happen to be doing some pretty cool things out there in the exciting world of accounting. In case you missed the last one, we introduced you to Bruce Phillips of Aprio Cloud, all while extolling the virtues of payroll and benefits solutions provided by our friends at Gusto. Go give it a read.

Before we jump in, we encourage you to pay Gusto a visit to find out how they’re bringing payroll and benefits into the 21st century. Forget flying cars, what the future needed was a modern solution to getting your people paid, onboarded, and insured. I mean, flying cars would have been nice but hey, this is pretty good too.

This time around, you’re meeting the incomparable Nayo Carter-Gray of Maryland-based 1st Step Accounting. Not to play favorites but we’re particularly fond of her paperless approach and how she’s using technology to embrace the deskless lifestyle.

Going Concern: Let’s get some introductions out of the way. Tell us about your firm.

Nayo Carter-Gray: 1st Step Accounting is a virtual accounting and tax preparation firm that is environmentally conscious and focused on leveraging technology for efficiency and convenience.

Nayo Carter-Gray

The culture I’m building for my practice is one of flexibility and freedom. I truly believe no one should be tied to a desk because of the advancement of technology, and so I try to ensure that my customers can work with us regardless of location and can access all information with at bare minimum a smartphone.

GC: As laptop hobos ourselves, we fully get behind the deskless lifestyle. What all do you do over there?

Carter-Gray: We currently offer accounting and bookkeeping services, tax preparation and planning, education and seminars (online and in-person), QuickBooks online setup and training, IRS and state tax audit and collection services, as well as consulting for small business growth and development.

GC: Nice. So a solid well-rounded suite basically. Bit of a personal question maybe but why did you start your firm?

Carter-Gray: I started my firm initially as a tax preparation firm, and I focused on multilevel marketing business owners because I was a MLM business owner. I found that my team members and other colleagues were being fed bad information when it came to reporting the business income and expenses on their taxes. After the first tax season, I discovered a need for bookkeeping and education for the small business community since the larger firms don’t want to waste their time and resources on these customers because they don’t earn them enough billable hours.

GC: It’s funny, we’ve heard that from other firm owners about starting with tax prep and then branching out when they see a need to provide more services to their clients. It’s almost as if tax prep is a gateway drug. So, if the little old lady you’re helping cross the street asks you about your work, how would you describe your job?

Carter-Gray: I make accounting a little less taxing for small business owners all across the U.S.

GC: Excellent play on words. While you’re making things less taxing for your clients, what tools can you not live without?

Carter-Gray: So many to choose from! My project management system Trello keeps me on track, my forms builder Cognito Forms helps me organize data collection from clients, and my online scheduler/CRM vCita does just about everything: it helps me keep my schedule in order, allows my clients to conveniently book appointments that work for them, and helps me to keep communication and notes in one centralized location.

As an honorable mention, I can’t live without my SideTrak second monitor for my laptop which conveniently attaches to the back of the laptop and slides out to make working from home as easy as working from my office.

GC: And Gusto, natch! How did you first hear about them?

Carter-Gray: Another accountant mentioned them (not sure who), and shortly after I heard about Gusto, I attended QuickBooks Connect where I got to see all the features for myself at a breakfast they hosted. I switched my largest customer at the time a month later because I was so impressed.

GC: Excellent first impressions aside, any surprises about partnering with Gusto?

Carter-Gray: No real surprises because Gusto did a fabulous job of presenting its product. I will say the payroll autopilot feature definitely lived up to the hype. I have several clients on salary and this makes payroll a breeze!

GC: Positive feedback is always nice. How about you? What do you think is the best perk of partnering with Gusto?

Carter-Gray: I do love how Gusto listens to its community and makes improvements based on our feedback. And it’s awesome that Gusto offers a discount or revenue share when we refer the product to our communities.

GC: Alright, enough about all the benefits of partnering with Gusto. What are some challenges your firm has faced in 2019? And don’t be afraid to tell us the really tough stuff.

Carter-Gray: This year my firm struggled with finding a project management system to stay in constant communication with my clients. After taking some hard but necessary feedback from a few clients that left the firm this year, I decided to make it a priority to find/create a system that would allow us to stay on track of deadlines and give our customers the insight they needed to know what was going on with their project.

Another challenge is because I’m the only person working in the firm year-round, my personal goals have hindered the growth of the firm this year. I’m currently sitting for the CPA exam, which is very time-consuming and it has taken away from major marketing efforts to bring in tons of new clients like I have in the past.

GC: Wow, that’s got to be incredibly difficult. We’re sure you’ll do great. Back to your clients, are you seeing any future trends on their side our readers might be interested in hearing about?

Carter-Gray: My clients will continue to grow in their respective industries. Because I work with businesses that are newly formed or have only been in business for one to two years, I get to watch their growth from part-time hustle to full-time enterprise. So I’m expecting a few of my part-timers to go full time in their businesses in 2020 because of their steady growth.

GC: That’s gotta be fun for you to see your clients thrive. On that note, can you tell us about an interesting client situation that you’ve advised on? Or something exciting your clients are working on?

Carter-Gray: The most interesting situation that I have advised on may not be very interesting at all to most. For me, I’m very interested in watching my clients grow. So the situation I have had the most pleasure of advising on was watching a current client who is a hair stylist create and sell a physical hair-styling product. To be a part of the team that helped her go from concept to reality was an amazing experience.

The client’s reality is that the older she gets, the harder it will be for her body to sustain the hours she puts in at the salon standing and styling people’s hair. So creating her product is going to allow her to create an exit plan before she actually needs it, and this is so inspiring and interesting to me.

GC: I bet! I’m happy to report that we’re done with the interrogation portion of this interview, now on to the easy stuff! What’s your usual breakfast?

Carter-Gray: Usually it’s two eggs over easy, but during the winter months when it’s cold or I’m traveling, it’s apple cinnamon oatmeal.

GC: Everyone has a routine for winding down at the end of a stressful day. What’s yours?

Carter-Gray: I love me some good TV and a delicious Coca-Cola slurpee. I can drink them every day no matter the temperature.

GC: Man! I haven’t had one of those in FOREVER. Alright, tell us a fact about you that would surprise people to hear.

Carter-Gray: I was a parent by the age of 14.

GC: Yep, definitely surprised! What a wonderful example you’re setting of how hard work and a forward-thinking attitude can take you far in life and make an impact in the world.

So that’s all we’ve got with Nayo Carter-Gray. Feel free to check her out on YouTube for more. And if her glowing review of Gusto made you eager to learn more about how partnering with Gusto can help you and your clients seven ways to Sunday, be sure to check out their partner program for more details.

The post An Interview with a Paperless Practitioner Doing Things Her Way appeared first on Going Concern.

republished from Going Concern

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UX tips for SEO experts and business owners Search Engine Watch

The times when ranking high in search results as the final goal have passed.

As search algorithms are improving and there’s no place for keyword stuffing anymore, SEO experts should adopt for trends coming and replacing each other too fast.

Today SEO involves loads of practices including link building, technical optimization, proper keyword research, and more. Although the process of boosting websites’ rankings is challenging enough, it isn’t the only task SEO specialists should cope with. To help businesses engage their target audience and make them convert is the problem falling to SEO practitioners as well.

Here comes the need for UX optimization, which is impossible not knowing what matters most of all for the target audience coming to the specific website. In this article, I’ll tell you about the most important steps to focus on for your customers and how to improve the user experience.

The debate rages: How much does UX count?

UX = CTR in some way. The debate about CTR among SEOs is evergreen, really. Everyone tries to defend his or her point of view despite Google’s statements on this issue. And recently, a new wave of discussion sparked up after the tweet of Moz SEO, Britney Muller. She tweeted about a new Google document that implies CTR matters for ranking.

Different SEO specialists expressed their opinions and tried to confirm or deny this fact, as several weeks before that Google also said CTR for ranking is made up.

For example, Barry Schwartz said that this new doc is “Confusing. Google did write “when you click a link in Google Search, Google considers your click when ranking that search result in future queries.” They should clarify that it is used for personalized search.”

Also read: Google RankBrain: Clearing up the myths and misconceptions

Regardless of all these debates, CTR and UX itself is a great practice. Even if it doesn’t improve your rankings, it’ll make your site more understandable, comfortable, and informative for visitors.

Why should SEO pros bother with user experience?

It may seem that being number one on Google search results is key to an engaging audience and driving conversions. It’s not quite so. Every improvement of search algorithms Google brought in recent years is focused on providing user-friendly results. Of course, domain authority and quality links are still important, but if the website ranked top has poor user experience, it may lose its positions soon.

How does it happen? Well, let’s assume your website is technically optimized, has a perfect content-to-keywords balance, and has links even from .edu domains. All these factors are most likely to result in high rankings.

But if the site is not fulfilling users’ expectations, it may take a dip as quickly as it’s rocketed. Once people that clicked through your website aren’t satisfied with the result, they’ll leave it quickly. The next time Google updates search results, it’ll see that your page’s bounce rate is too high.

The numbers will point to the fact your site isn’t relevant to the query, and it shouldn’t rank that high.

Bounce rate isn’t the only factor search engines consider when analyzing user experience. There are also such signals as pages per session, dwell-time, and organic CTR. As you see, the tasks of an experienced SEO specialist are much broader than it used to be several years ago. But the results cost the effort.

Best practices for UX improvement

The good news is that you already know these practices. The only difference is that using them now, you should concentrate not on the search engines’ requirements but on meeting the needs of your visitors.

Let me take you through the user’s journey point by point and emphasize on crucial aspects influencing his or her decisions. Here we go.

Search query

Where does the search journey start? Right, everything starts from the query. Once users have questions, they go to search engines and ask them. That’s why knowing what your potential customers are likely to look for is half-way to success.

The knowledge of queries your target audience conducts helps you come up not only with content ideas but also with key phrases your page should rank for. There are several questions you should answer to make your keyword research user-focused:

1. Do you consider user intent?

The thing is that every user conducting a search query has a certain intent. In other words, there’s always the reason why a person searches for something. If I search for “iPhone price”, there’s a 90 percent probability that I want to buy the smartphone. In this case, Google will provide me with various online stores. Searching for “Apple or Samsung”, it’s most likely I want to read the articles where authors compare devices produced by these two companies. And again, the search engine will get it.

Therefore, it’s essential to denote the intent of the content you provide. If you own an online shop, you should mark transactional intent on your page. Add “buy”, “price”, “purchase”, “on sale”, and other related keywords. If you run a blog, use the phrases with “how to”, “what is”, “best tips”, and more. Denoting intent not only helps search engines rank your website for the relevant queries but also provides users with a better understanding of what they’ll see on your page.

Moreover, users quite often don’t mark their intent in their search queries. One can type “women jeans”, and the machine won’t be 100 percent sure whether a person wants to get some fashion tips or purchase jeans. In this case, the search results will contain both informational and transactional websites. To help your prospects understand if they should click through your site, you’d better denote what type of service you provide.

2. What queries do your prospects conduct?

Even if you think you understand what kind of information concerning your product your target audience may be interested in, don’t jump to conclusions. Working in a niche is pretty different from being a consumer. The words you use to describe what you do may be absolutely unknown for people searching for your product at first.

As we concluded it’s important to know what kind of search queries your potential customer’s conduct. I’ll show you the quickest ways to identify these queries.

Serpstat Search Suggestions: Providing the opportunity to research keywords, analyze competitors’ websites, and conduct SEO audit, this tool also provides you with search suggestions related to the researched keyword. These are the queries usually popping up when you start typing your keyword in the search field. Instead of collecting all these variations of queries by yourself, you can go with this tool.

Answer The Public: This tool specializes in content ideas and keyword research. Enter your main keyword in the search field, and you’ll see the list of questions users ask on the subject.

People also ask: I mean the box in SERP appearing among the search results engines provides to your query. If you pay attention to it, you may find lots of relevant suggestions for you to use in the future. Tap on the arrow near the questions, and you’ll see even more variations.

Snippets

The next step users undertake after entering the search query is choosing which website from all the search results provides the most comprehensive information. And how do they make a decision? Right, they judge by what they see in the snippet.

The website may contain high-quality and relevant content, but failing to denote it in the snippet, decreases its chances to get high traffic dramatically. In fact, there are two pieces of metadata influencing how your snippet may look.

1. Title tag & meta description

Of course, creating a catchy and intriguing title and description is essential in case you want to attract the audience’s attention. But you should be careful. In the way, a boring title will bring you little profit, the too promising one will also do you no good.

You may say: “There are loads of posts on the subject, I should make my page stand out.” I agree. Partly. You should stand out. But with unique and quality content, not with false promises in your snippets.

Once you promised something that you don’t provide on your page, it’ll increase your bounce rate and hurt user experience.

So, when creating a title tag and meta description, make sure you:

Provide the main idea of your content in the title

Emphasize on your competitive advantage in your description

Denote user intent

Don’t spam with keyword stuffing

Don’t make false promises

2. Page speed

After your audience clicked through your website, there’s one more thing they’ll face before seeing the page itself. Page speed is the factor considered not only by search robots but also by users.

If a person (especially a mobile user) should wait for more than several seconds for your server to answer, the chances he or she will return to search results are quite significant. Here’s an infographic by HubSpot.

There are services, such as PageSpeed Insights, Serpstat, and Moz, which analyze web pages’ loading speed and generate suggestions to make them faster.

Never forget that 48.2 percent of web page views worldwide account for mobile device users. So, if you don’t want to damage the user experience, it’s worth checking whether your website is mobile-friendly or not. Click on “mobile” to see the analysis of your mobile version. You may be surprised to see that these two versions differ a lot.

Design & content structure

When people have already chosen your website, clicked through it, and waited for it to get loaded, they see your page. What’s the first thing catching the visitor’s eye? The way it looks. Your content may be incredibly authoritative and trustworthy, but once users see it’s impossible to draw the essential data quickly, they might decide the content is too complicated.

I’ve circled out a few tips for you to follow when elaborating your content structure and design:

The more minimalistic your website looks, the better. It’s pretty easy to overdo when it comes to design. Concentrate not on unusual fonts but on readability of your content.

Provide a clear structure for your texts. Your visitors should see compelling questions or topics you cover in the headings. It’ll denote they’ll get the answers in the paragraphs below.

If your article is long enough, add internal tags to your content in the beginning. It’ll help users navigate if they want to find something specific.

Navigation

Mind that lots of visitors don’t come to your website from your home page. Make sure your website is easy to navigate for users to visit different pages of your website. Remember that the more time people spend on your site, the better the user experience it causes.

First of all, your menu button (or hamburger button) should always be handy. It would be the most convenient to create a fixed header for your web pages. Due to such a header, visitors won’t have to scroll the page after they’ve read your content.

Moreover, when unrolled, the menu shouldn’t overlap the page content. Talking of overlapping, try to avoid pop-ups. All the advertisements overtaking the article every minute cause extremely poor user experience.

Don’t forget to provide clearly labeled categories on the menu. Everything should be organized logically. To make your website even more convenient in the usage, add a search box. If visitors aren’t sure which category contains the necessary information, this box will help a lot.

Never stop testing

Here were the basic tips which may help you improve UX for your website. Following them is the start, not the finish line. UX tendencies are changing almost as often as search algorithms do.

Always look for ways of improving your strategies. Track users’ reactions to your new posts. ask yourself, “Did the conversions improve when you applied a new design?” Analyze all the changes whether they’re good or not and discover how you can develop user experience.

Inna Yatsyna is a Brand and Community Development Specialist at Serpstat. She can be found on Twitter .

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What Is Blockchain? A Primer for Finance Professionals

It’s often not easy to envision or understand a new technology when we first hear about it—especially when the technology is not something that you can see, hold or touch.

Everyone can see what a smartphone is, and most finance professionals understand the impact that related technologies, like mobile and social, have had on the way we conduct business.

Emerging technologies are a different matter.

My colleagues have already written primers on new technologies such as machine learning, artificial intelligence and robotics process automation. Today, I’d like to take a closer look at blockchain—another new concept that finance teams are only beginning to grasp.

When writing about complex ideas, my editor likes to say, “Explain it to me as if I’ve never worked in in a technology company.” So, let’s start with a simplified example.

A Simplified Blockchain Example

Imagine that you have a child in university, and every month, you send them a living allowance. There are a number of ways you can do this, but the most common is transferring money from your bank account into your child’s. There are two records of this transaction: a debit recorded in your bank account, and a credit in your child’s account.

In most circumstances, neither of you can see the other’s bank records. Banks keep separate ledgers on their customers’ behalf, and they spend a lot of time and money ensuring that these ledgers are accurate, and private.

But what if you didn’t want the ledgers to be private? What if you wanted both you and your child to have access to a single ledger, with all transactions visible to you both?

In the past, this would require setting up a joint bank account. Blockchain offers a different approach.

Learn more about the latest in modern finance. Get the handbook.

Now imagine that, every time you send the monthly living allowance, you laid down a “block” with the transaction information carved into it (date, time, amount, and so on). Both you and your child can see the block, confirming that the money was sent and received. Your spendthrift kid couldn’t come back to you a week later claiming that “the bank screwed up” and the transfer never came through.

Every month, you lay down more blocks, which form a “chain.” Together, they create a record of all transactions with your future college graduate. When you get old and infirm, you can point to the chain, show your kid how much money you paid for college, and demand that they invest a similar amount in a high-quality nursing home.

This is, more or less, how blockchain works. Each block is a record of a monetary transaction. The chain is a shared accounting ledger that is visible to all parties across multiple networks, or “nodes.” Every new transaction is verified by all nodes and, if valid, added to all copies of the ledger—in other words, a new “block” is added to the “chain.”

The chain is cryptographically secured, so nobody can change a record once it has been inscribed. And even if you were to find a way around the cryptography, the records are visible to all members—making it nearly impossible to change a block without someone noticing. The most you can do is lay down new blocks.

The Implications for Finance Leaders

Modern financial structures evolved from Venetian traders in the 15thcentury, and later, Dutch bourses in the 17th century. Double-entry bookkeeping has been with us since those very early days, and has helped build the institutions upon which our modern financial world rests.

The concept for exchanges and transactions of all kinds—including money, commodities, stocks, loans, and products—have required each participant to track every transaction using its own ledger. Most of the time, this works very well. But occasionally, ledgers get out of sync—leading to audits, mistrust, and increased scrutiny.

The difference with blockchain is that all parties use the same ledger, which is visible to all participants. Ledgers can never be out of sync when there is only one of them.

Why Blockchain Matters

This new approach to monetary record keeping offers multiple benefits, including:

Increased transactional trust. Since every participant can see every block in the chain, it’s easier to ensure that all transactions are above board. It’s hard to deal under the table when everyone is watching.

Reduced fraud. Similarly, it becomes difficult—if not impossible—to hide, misrepresent or delete monetary or other transactions (for example, the movement of commodities).

Reduced risks and associated moral hazards. With more trust and reduced fraud, enterprise risk is likewise reduced. Moral hazards are harder to hide as contracts and deals are evaluated.

Lowered transaction costs and faster processing times. Fewer systems and organizational infrastructure simplify and speed up the entire transaction process, for less money.

Beyond Bitcoin

While bitcoin and blockchain are often discussed in tandem, they are not the same thing. Bitcoin is an application utilizing blockchain; blockchain does not require bitcoin. Nevertheless, bitcoin has proven, on a global basis, how blockchain works and has driven rapid interest in the technology—especially in the financial services industry among banks and credit card processors.

But the disruption opportunities of blockchain will not be limited to financial services. Consider other industries that move products through distribution, or even utilities that measure and track the use of electricity, water, and sewage. Short term housing rentals, car sharing and food production from farm to fork could experience disruptions driven by blockchain.

Examples of rapidly evolving blockchain applications include online voting, medical record keeping, provenance of art and historical artifacts, non-profit banking service for regions and populations not served by traditional banking, and process automation for generic, time-consuming back-office activities.

Other potential applications of blockchain include intercompany transactions for financials, distributed procurement through a network for vendors, and loyalty management programs for consumers.

More Efficiency, Transparency and Trust

Think about the problems and situations you encounter today that require multiple ledgers and systems. Some of those systems add cost, complexity, and control with little or no additional value. With blockchain, you might soon have the potential to securely and safely extend these systems outside the enterprise, reducing friction when transacting with trading partners, or even with customers.

Both finance and technology organizations are only just beginning to look closely at blockchain and imagine future applications. Even during these early stages, there is the potential to deliver more efficiency, transparency, and trust—with less risk, cost, and complexity.

  https://blogs.oracle.com/what-is-blockchain-a-primer-for-finance-professionals-v2

from WordPress https://reviewandbonuss.wordpress.com/2017/08/18/what-is-blockchain-a-primer-for-finance-professionals/

[perfectirishgifts]

IRS At Supreme Court Over Captive Insurance

New Post has been published on https://perfectirishgifts.com/irs-at-supreme-court-over-captive-insurance/

IRS At Supreme Court Over Captive Insurance

Hand holds documents Captive insurance about insurance.

The Supreme Court rarely hears tax cases which makes the recent oral arguments in CIC Services v IRS exciting. That is about all that makes them exciting to ordinary mortals as what was going on at the Supreme Court was an argument about whether they could have an argument.

In 2017, CIC Services and Ryan LLC brought an action in the United States District Court for the Eastern District of Tennessee asking to set aside IRS Notice 2016-66 as modified by IRS Notice 2017-08. Both the District Court and the Sixth Circuit ruled that the action was barred by the Anti Injunction Act. The notices concern micro-captive transactions.

Micro-captive has a science fiction sound to it, Makes me think of Kandor – the Kryptonian city in a bottle that Superman kept in his Fortress of Solitude. That’s not it, though. It is about insurance, sort of. Simplistically, a captive is an insurance company that is owned by the insured or related parties. Micro means it takes in less than $2.3 million in premiums. (I’m simplifying. The threshold has been changing.).

So You Want To Own An Insurance Company

Warren Buffett famously likes to own insurance companies. He explained it in the 2019 Berkshire Hathaway Annual Report:

One reason we were attracted to the P/C business was the industry’s business model: P/C insurers receive premiums upfront and pay claims later. In extreme cases, such as claims arising from exposure to asbestos, or severe workplace accidents, payments can stretch over many decades.

This collect-now, pay-later model leaves P/C companies holding large sums – money we call “float” – that will eventually go to others. Meanwhile, insurers get to invest this float for their own benefit. Though individual policies and claims come and go, the amount of float an insurer holds usually remains fairly stable in relation to premium volume. Consequently, as our business grows, so does our float.

The Tax Leverage Of Insurance

So running an insurance company you can make or lose money from paying out more or less in claims than you collect in premiums – the underwriting income – and from your investments while you hold onto the money,

Back in the day, it was even better as insurance companies could deduct all those amounts that they expected to pay in the future. The Tax Reform of 1986 cut into that a bit, by forcing them to discount the expected payouts to present value. That was a much bigger deal back in the eighties when money earned interest. It was very complicated.

TRA 1986 carved out a break for smaller insurance companies. A small company, based on premiums written, can elect to only pay taxes on its investment income. The underwriting profit or loss is not considered in determining taxable income.

When you view all this in the aggregate considering both the insurance companies and their customers, there is some tax leverage at play. When people are insuring business risks they can deduct the premiums as ordinary and necessary business expenses immediately. The insurance companies ultimately will recognize income to the extent they don’t pay claims, but that will be over time unless they are one of the electing small companies.

If the customers decided to self-insure, they would not get a deduction for money they put aside to be prepared for whatever eventuality they were insuring against. At a very basic level, that is the tax incentive for a captive insurance company. There is a lot more to it than that. Your captive insurance company can go into the reinsurance market allowing you to lay off some of the risks in a more flexible way than you can with commercial insurance. So there can be business reasons independent of tax incentives for setting up a captive insurance company.

The Shenanigans

If you don’t see the potential for shenanigans in all this, you have not thought much about it.  If the customers get to deduct and the company does not have to pick up income there is one of those rifts in the space-time continuum when that big balance sheet in the sky does not balance. That’s the part of the universe where abusive tax shelters spawn.

The way CIC promotes almost implies that.

CIC Services is a captive manager and strategist. Since 2005, we’ve been helping small & mid-sized business owners turn their risk into wealth by owning their own insurance company. 

“Turn their risks into wealth” ?? If the wheels that spin straw into gold are not working, you have to do the best you can.

I spoke with a tax executive for a major life insurance company. Promoters had been trying to get the company’s sales force to recommend captive insurance deals. When he examined them he concluded that there was not actually much in the way of insurance going on. It looked more like alchemy.

If you can pay your own insurance company deductible dollars that the insurance company does not have to recognize as income, the more you pay them the better. That’s the essence of the potential shenanigans. We can see them illustrated in the Tax Court decision in the case of Benyamin Avrahami & Orna Avrahami by Judge Holmes.

Benyamin and Orna Avrahami own three shopping centers and three thriving jewelry stores. In 2006 they spent a little more than

$150,000 insuring them. In 2009 this insurance bill soared to more than $1.1 million and it flew even higher, to more than $1.3 million, in 2010. The Avrahamis were paying the overwhelming share of these big bills to a new insurance company called Feedback that was wholly owned by Mrs. Avrahami. Yet there were no claims made on any of the Feedback policies until the IRS began an audit of the Avrahamis’ and their various entities’ returns. With money flooding in and none going back out to pay claims, Feedback accumulated a surplus of more than $3.8 million by the end of 2010, $1.7 million of which ended up back in the Avrahamis’ bank account—as loans and loan repayments, say the Avrahamis; as distributions, says the Commissioner.

The Practical Effect Of The Notices

In the contested notices, the IRS declared that certain captive insurance transactions were “transactions of interest”. This is not quite as bad as being a “listed transaction”, but bad enough. What the designation does is trigger substantial reporting requirements that are backed by really nasty penalties. There is also collateral damage in that when something becomes identified this way people get nervous about it, which is bad for business. Ryan and CIC mentioned this in the original complaint filed in 2017.

As a result of the IRS audit program, the §831(b) market has, of course, been substantially constricted, negatively affecting captive managers, their employees, and many others who rely on the captive industry for employment, including residents of the State of Tennessee, which, at least for the moment, enjoys a robust captive insurance marketplace.

Reilly’s Fourteenth Law of Tax Planning – If something is a listed transaction, just don’t do it. I think I should revise that with a corollary rule – If somebody suggests a transaction of interest, tell them you are not interested.

I had a long talk with someone who is responsible for the tax practice of a firm that focuses on professional practices. He has fielded quite a few attempts to get his firm’s client’s interested in doing captive deals. When he first learned of the concept, the deals that were presented did not pass the smell test. There did not seem to be any business rationale for what they were doing. Once the notices came out he felt vindicated.

My outreach via #TaxTwitter did not yield much more in the way of anecdotal information. One respondent suggested that captive insurance tends to work well for auto dealers. It is important to remember that there are legitimate reasons for setting up a captive. That is why it is a “transaction of interest” rather than a listed transaction.

An example of the latter is in Notice 2017-10. That notice takes on syndicated conservation easements. Don’t get me started. That is an industry based on nonsense. Partnership For Conservation, the industry trade association, filed an amicus brief in the CIC case.

“IRS statements made around the time and subsequent to issuance of the Notice indicate the real purpose of the Notice was to put an end to the conservation easement donations so described. Comments from IRS Comm’r Charles Rettig include: “Putting an end to these abusive schemes is a high priority for the IRS.” and “[e]nding these abusive schemes remains a top priority for the IRS.“

Lance Wallach

Lance Wallach made a name for himself exposing 419(a) employee welfare benefit plans, a scheme that seems to share a lot with captive insurance in the type of market that it went after. He is very concerned with the possible bad effect that CIC winning this suit might have on tax compliance. He wrote:

In my experience of lecturing, writing, and acting as an expert witness in tax shelter cases, the IRS needs every tool available to it in order to combat the proliferation of the abusive tax shelters. I have watched IRS’s programs grow from the “SON OF BOSS” to 419 welfare benefit plans, 412i plans, section 79 plans, syndicated conservation easements, and section 231b small captive insurance arrangements. These “schemes” are a way for taxpayers to cheat the government out of large sums of money. They are also a way for promoters and others involved in the scams to earn large incomes. Many of these arrangements involve the sale of huge amounts of high commissioned life insurance policies by agents representing life insurance companies, which make huge amounts of money on the sale of these “shelter” policies.

As an expert witness against these life insurance companies, whose products fund many of the abusive tax shelters, I have never lost a case. Almost all the lawsuits have been settled privately. Profitable business owners and professionals are approached by insurance agents or accountants and sometimes attorneys, enticing them to get involved in tax shelters that are usually abusive. The end result for the taxpayer is usually, aggravation, payment of taxes, huge penalties, and interest to the IRS simply as the result of purchasing a product that they really never needed.

I have received thousands of phone calls about these “abusive” tax shelters.

It is my opinion, that the IRS needs every tool available to fight the growth of these abusive tax shelters. The insurance companies and promoters have vast resources to fight the IRS. While most of us dislike and/or are afraid of the IRS, their resources are, in fact, limited.

The Stakes In The Supreme Court

It might not be quite that dramatic. This is the sort of case that only legal nerds really like. The reason the IRS won at that district and circuit is because of the Anti-Injunction Act. Basically, you can’t sue to prevent the IRS from assessing a tax. The penalty for not complying with the notice is defined by Congress as a tax. You will find plenty of coverage on those nuances. The purpose of this post is to look at the broader picture.

Nonetheless, I turned to one of my legal experts who prefers to remain off the record about the stakes.

Peter the key is that CIC has a process for pre-enforcement challenge of whether a regulation is needed. Historically, taxes and penalties that the Code says are taxes (like the one involved in CIC) have permitted only post-enforcement challenge and the AIA (§ 7421(a)) is designed to preclude pre-enforcement challenges in most cases. There are some exceptions though, and I think that is were the Supreme Court will divide – as to whether there can be a pre-enforcement challenge (not whether the challenge has merit).

If CIC convinces the Court that it can mount its challenge (the challenge that a notice and comment regulation is required rather than a Notice), then the Court (probably lower court on remand) will determine whether that challenge has merit.

So the argument at the Supreme Court is about whether an argument can be held lower down.

The Ultimate Stakes

At the end of the day making something a listed transaction or a transaction of interest helps tax enforcement in two ways. All the extra filing identifies deals for the IRS to look at. The extra filing requirements discourage people from engaging in sketchy transactions and make mainstream advisers very wary of them. The ultimate stakes in this litigation are that it would be harder for the IRS to declare that something is a listed transaction or transaction of interest.

In Supreme Court Hears Arguments in Captive Insurer Case, Allison Bell discusses the problem IRS could ultimately face if it loses.

Supporters of the IRS position say that rejecting its ability to impose new reporting requirements through notices, without going through notice-and-comment periods, would gut the agency’s ability to respond quickly to scams and abusive tax shelters.

I am skeptical that that will actually affect tax compliance all that much. The IRS already knows about a lot of noncompliance that it never looks into. My favorite example is alimony. This is from a story I wrote in 2014 about a TIGTA (Inspector General) report.

According to the TIGTA report, there were 567,887 Forms 1040 for 2010 that had alimony deductions. The total claimed was $10 Billion. When they compared the corresponding returns that should have recorded the income, there were discrepancies on 266,190 returns including 122,870 returns that had no alimony income at all reported. 

The IRS examined 10,870 of those returns. They simply don’t have the resources. Getting serious about tax compliance requires more audits, which requires more people.

When it lists transactions, the IRS is to a significant extent bluffing. And shelter promoters are calling that bluff. Forcing the IRS to jump through more hoops to get the transactions listed will probably not be a real game-changer. Bringing IRS staffing back to where it was 20 years ago with an emphasis on sharp enforcement people is what would make a real difference.

Other Coverage

The North Carolina Captive Insurance Association has Long Awaited Oral Arguments In CIC Services v. IRS Before The Supreme Court Of The United States 12/1/2020. Before a rundown on how the arguments went, they give some interesting background on how the case came to be filed.

Beginning in 2017 NCCIA brought the case to the attention of the membership leading some association members to instigate the Captive Insurance Defense Group (“CIDC”) that privately raised monies to file an injunction/declaratory judgment action against the IRS for violation of the Administrative Procedures Act (“APA”). Sean King of CIC Services, LLC was a participant in the CIDC effort. The CIDC needed a plaintiff for that lawsuit. King bravely stepped up as plaintiff (even though his attorney feared possible IRS retaliation). NCCIA was the ONLY captive trade group to file an Amicus Curiae (friend of the court) brief (“AB”) in the initial District Court action. 

Captive Insurance Times expressed optimism for the industry’s prospects with IRS counsel faces tough questions from Supreme Court in CIC Services case.

Richard Rubin had Supreme Court Justices Question IRS Shield in Tax-Shelter Case in the Wall Street Journal.

Jack Townsend on Federal Tax Crimes has Discussion of Criminal Tax Issues in Oral Argument in CIC Services (12/5/20). He also covered the oral arguments more generally of Federal Tax Procedure with CIC Services Supreme Court Oral Argument (12/3/20).

As with any Supreme Court decision, I am grateful to the coverage on SCOTUSblog which allows me to keep my PACER bill from going through the roof.

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