There is some exciting news for foreign investors due to recent geo-political developments and the emergence of several financial factors. This coalescence of events, has at its core, the major drop in the price of US real estate, combined with the exodus of capital from Russia and China. Among foreign investors this has suddenly and significantly produced a demand for real estate in California.
Our research shows that China alone, spent $22 billion on U.S. housing in the last 12 months, much more than they spent the year before. Chinese in particular have a great advantage driven by their strong domestic economy, a stable exchange rate, increased access to credit and desire for diversification and secure investments.
We can cite several reasons for this rise in demand for US Real Estate by foreign Investors, but the primary attraction is the global recognition of the fact that the United States is currently enjoying an economy that is growing relative to other developed nations. Couple that growth and stability with the fact that the US has a transparent legal system which creates an easy avenue for non-U.S. citizens to invest, and what we have is a perfect alignment of both timing and financial law… creating prime opportunity! The US also imposes no currency controls, making it easy to divest, which makes the prospect of Investment in US Real Estate even more attractive.
Here, we provide a few facts that will be useful for those considering investment in Real Estate in the US and Califonia in particular. We will take the sometimes difficult language of these topics and attempt to make them easy to understand.
This article will touch briefly on some of the following topics: Taxation of foreign entities and international investors. U.S. trade or businessTaxation of U.S. entities and individuals. Effectively connected income. Non-effectively connected income. Branch Profits Tax. Tax on excess interest. U.S. withholding tax on payments made to the foreign investor. Foreign corporations. Partnerships. Real Estate Investment Trusts. Treaty protection from taxation. Branch Profits Tax Interest income. Business profits. Income from real property. Capitol gains and third-country use of treaties/limitation on benefits.
We will also briefly highlight dispositions of U.S. real estate investments, including U.S. real property interests, the definition of a U.S. real property holding corporation “USRPHC”, U.S. tax consequences of investing in United States Real Property Interests ” USRPIs” through foreign corporations, Foreign Investment Real Property Tax Act “FIRPTA” withholding and withholding exceptions.
Non-U.S. citizens choose to invest in US real estate for many different reasons and they will have a diverse range of aims and goals. Many will want to insure that all processes are handled quickly, expeditiously and correctly as well as privately and in some cases with complete anonymity. Secondly, the issue of privacy in regards to your investment is extremely important. With the rise of the internet, private information is becoming more and more public. Although you may be required to reveal information for tax purposes, you are not required, and should not, disclose property ownership for all the world to see. One purpose for privacy is legitimate asset protection from questionable creditor claims or lawsuits. Generally, the less individuals, businesses or government agencies know about your private affairs, the better.
Reducing taxes on your U.S. investments is also a major consideration. When investing in U.S. real estate, one must consider whether property is income-producing and whether or not that income is ‘passive income’ or income produced by trade or business. Another concern, especially for older investors, is whether the investor is a U.S. resident for estate tax purposes.
The purpose of an LLC, Corporation or Limited Partnership is to form a shield of protection between you personally for any liability arising from the activities of the entity. LLCs offer greater structuring flexibility and better creditor protection than limited partnerships, and are generally preferred over corporations for holding smaller real estate properties. LLC’s aren’t subject to the record-keeping formalities that corporations are.
If an investor uses a corporation or an LLC to hold real property, the entity will have to register with the California Secretary of State. In doing so, articles of incorporation or the statement of information become visible to the world, including the identity of the corporate officers and directors or the LLC manager.
An great example is the formation of a two-tier structure to help protect you by creating a California LLC to own the real estate, and a Delaware LLC to act as the manager of the California LLC. The benefits to using this two-tier structure are simple and effective but must one must be precise in implementation of this strategy.
In the state of Delaware, the name of the LLC manager is not required to be disclosed, subsequently, the only proprietary information that will appear on California form is the name of the Delaware LLC as the manager. Great care is exercised so that the Delaware LLC is not deemed to be doing business in California and this perfectly legal technical loophole is one of many great tools for acquiring Real Estate with minimal Tax and other liability.
Regarding using a trust to hold real property, the actual name of the trustee and the name of the trust must appear on the recorded deed. Accordingly, If using a trust, the investor might not want to be the trustee, and the trust need not include the investor’s name. To insure privacy, a generic name can be used for the entity.
In the case of any real estate investment that happens to be encumbered by debt, the borrower’s name will appear on the recorded deed of trust, even if title is taken in the name of a trust or an LLC. But when the investor personally guarantees the loan by acting AS the borrower through the trust entity, THEN the borrower’s name may be kept private! At this point the Trust entity becomes the borrower and the owner of the property. This insures that the investor’s name does not appear on any recorded documents.
Because formalities, like holding annual meetings of shareholders and maintaining annual minutes, are not required in the case of limited partnerships and LLCs, they are often preferred over corporations. Failing to observe corporate formalities can lead to failure of the liability shield between the individual investor and the corporation. This failure in legal terms is called “piercing the corporate veil”.
Limited partnerships and LLCs may create a more effective asset protection stronghold than corporations, because interests and assets may be more difficult to reach by creditors to the investor.
To illustrate this, let’s assume an individual in a corporation owns, say, an apartment complex and this corporation receives a judgment against it by a creditor. The creditor can now force the debtor to turn over the stock of the corporation which can result in a devastating loss of corporate assets.
However, when the debtor owns the apartment building through either a Limited Partnership or an LLC the creditor’s recourse is limited to a simple charging order, which places a lien on distributions from the LLC or limited partnership, but keeps the creditor from seizing partnership assets and keeps the creditor out the affairs of the LLC or Partnership.
Income Taxation of Real Estate
For the purposes of Federal Income tax a foreigner is referred to as nonresident alien (NRA). An NRA can be defined as a foreign corporation or a person who either;
A) Physically is present in the United States for less than 183 days in any given year. B) Physically is present less than 31 days in the current year. C) Physically is present for less than 183 total days for a three-year period (using a weighing formula) and does not hold a green card.
The applicable Income tax rules associated to NRAs can be quite complex, but as a general rule, the income that IS subject to withholding is a 30 percent flat tax on “fixed or determinable” – “annual or periodical” (FDAP) income (originating in the US), that is not effectively connected to a U.S. trade or business that is subject to withholding. Important point there, which we will address momentarily.
Tax rates imposed on NRAs may be reduced by any applicable treaties and the Gross income is what gets taxed with almost not offsetting deductions. So here, we need to address exactly what FDAP income includes. FDAP is considered to include; interest, dividends, royalties, and rents.
Simply put, NRAs are subject to a 30 percent tax when receiving interest income from U.S. sources. Included within the definitions of FDAP are some miscellaneous categories of income such as; annuity payments, certain insurance premiums, gambling winnings, and alimony.
Capital gains from U.S. sources, however, are generally not taxable unless: A)The NRA is present in the United States for more than 183 days. B) The gains can be effectively connected to a U.S. trade or business. C) The gains are from the sale of certain timber, coal, or domestic iron ore assets.
NRA’s can and will be taxed on capital gains (originating in the US) at the rate of 30 percent when these exceptions apply.Because NRA’s are taxed on income in the same manner as a US taxpayers when that income can effectively be connected to a US trade or business, then it becomes necessary to define what constitutes; “U.S. trade or business” and to what “effectively connected” means. This is where we can limit the taxable liability.
There are several ways in which the US defines “US trade or Business” but there is no set and specific code definition. The term “US Trade or Business” can be seen as: selling products in the United States (either directly or through an agent), soliciting orders for merchandise from the US and those goods out of the US, providing personal services in the United States, manufacturing, maintaining a retail store, and maintaining corporate offices in the United States.Conversely, there are highly specific and complex definitions for “effectively connected” involving the “force of attraction” and “asset-use” rules, as well as “business-activities” tests.
Generally and for simplistic explanation, an NRA is “effectively connected” if he or she is engaged as a General or limited partner in a U.S. trade or business. Similarly, if the estate or trust is so engaged in trade or business then any beneficiary of said trust or estate is also engaged
For real estate, the nature of the rental income becomes the critical concern. The Real Estate becomes passive if it is generated by a triple-net lease or from lease of unimproved land. When held in this manner and considered passive the rental income is taxed on a gross basis, at a flat rate of 30 percent with applicable withholding and no deductions.
Investors should consider electing to treat their passive real property income, as income from a U.S. trade or business, because the nature of this type of holding and loss of deduction inherent therein is often tax prohibited. However, the election can only be made if the property is generating income.
If the NRA owns or invests in or owns unimproved land that will be developed in the future, he or she should consider leasing the land. This is a great way to generate income. Investment in income-generating allows the NRA the ability to claim deductions from the property and generate a loss carry-forward that will offset income in future years.
There are many tools we can use to assist our NRA clients in avoiding taxation on Real Estate income property, one of which is ‘portfolio interest’, which is payable only on a debt instrument and not subject to taxation or withholding. There are several ways to fit within the confines of these ‘portfolio interest’ rules. NRAs can participate in the practice of lending through equity participation loans or loans with equity kickers. An equity kicker is like a loan that allows the lender to participate in equity appreciation. Allowing the lender to convert debt into equity in the form of a conversion option is one way that this can be accomplished as these provisions usually increase interest rates on a contingent basis to mimic equity participation.
There are two levels of tax applicable to a foreign individual or a foreign corporation who owns a U.S. corporation.
The U.S. corporation will be subject subjected to a 30 percent withholding tax on its profits, when the income is not re-invested in the United States and there will be a tax on dividends paid to the foreign shareholders as well. When the U.S. business is owned by a foreign corporation, whether directly or through a disregarded entity, or through a pass-through entity. The branch profits tax replicates the double tax.
The U.S. has treaties covering the ‘branch profits tax’ with most of the European nations, reducing the tax to between 5 and 10 percent. The 30 percent tax is onerous, as it applies to a “dividend equivalent amount,” which is the corporation’s effectively connected earnings and profits for the year, less investments the corporation makes in its U.S. assets (money and adjusted bases of property connected with the conduct of a U.S. trade or business). The tax is imposed even if there is no distribution.
Foreign corporations are taxed on their effectively connected income and on any deemed dividends, which are any profits not reinvested in the United State under the branch profits tax.
The rules applicable to the tax on the disposition of real estate are found in a separate regime known as the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA).
Generally, FIRTPA taxes an NRAs holdings of U.S. real property interest (USRPI) as if he or she were engaged in a U.S. trade or business. As mentioned earlier, this means that the traditional income tax rules that apply to U.S. taxpayers will also apply to the NRA. Obligation to withhold 10 percent of the amount realized on any disposition falls on purchasers who acquire a USRPI from an NRA.
Ownership and interests of Real Estate Property include: fee ownership, co-ownership, leasehold, timeshare, a life estate, a remainder, a reversion or a right to participate in the appreciation of real property or in the profits from real property. For purposes of definition interest in real property would include any ownership of personal property used to exploit natural resources, land, buildings, mineral deposits, crops, fixtures, operations to construct improvements, the operation of a lodging facility, or providing a furnished office to a tenant (including movable walls or furnishings) as well as Improvements, leaseholds, or options to acquire any of the above.
There are several ways in which a partnership interest is treated as a USRPI: A domestic corporation will be treated as a U.S. real property holding corporation (USRPHC) if USRPIs are equal to or exceed 50 percent of the sum of the corporation’s assets. OR when 50 percent or more of the value of the gross partnership assets consists of USRPIs – Or when 50 percent or more of the value of partnership gross assets consist of USRPIs plus cash and cash equivalents. The disposition of partnership interest will be subject to FIRPTA. To the extent that such partnership continues to own USRPIs they will remain subject to this withholding.
The good news is that disposition of an interest in a USRPHC is subject to the FIRPTA tax and withholding but is not subject to state income tax. There is an obvious benefit when compared with the disposition of a USRPI owned directly. USRPI which are owned directly are subject to the lower federal capital gains rate as well as state income tax. If, however on the date of the disposition the corporation had no USRPIs and the totality of the gain was fully recognized (no installment sales or exchanges) on the sale of any USRPIs sold within the past five years Then this disposition cannot be subject to these rules.
Any USRPI sold by an NRA (individual or corporation) will be subject to 10 percent withholding of the amount realized. Withholding applies even if the property is sold at a loss.
The purchaser must report the withholding and pay over the tax, using Form 8288 within 20 days of the purchase. This is to be duly noted because if the purchaser fails to collect the withholding tax from the foreigner, the purchaser will be liable for not only the tax, but also any applicable penalties and interest. The withheld taxes are later credited against the total tax liability of the foreigner.
Instances wherein withholding is not required, are the following:
The seller provides a certificate of non-foreign status. Property acquired by the purchaser is not a USRPI. The transferred property is stock of a domestic corporation and the corporation provides a certificate that it is not a USRPHC.
The USRPI acquired will be used by the purchaser as a residence and the amount realized by the foreigner on the disposition is $300,000 or less. The disposition is not subject to tax, or the amount realized by the foreigner on the disposition is zero.
Estate and Gift Tax: In determining who is an NRA and who is excluded the test is completely different for estate tax purposes. The focus of inquiry will centers around the decedent’s residence. This test is very subjective and focuses primarily on intent.The test considers factors from across the board, such as how long the NRA has been in the United States, how often he or she travels as well as the size, and cost of home in the United States. The test will also look at the location of NRA’s family, their participation in community activities, participation in U.S. business and ownership of assets in the United States. Voting is also taken into consideration.
A foreigner can be a U.S. resident for income tax purposes but not be domiciled for estate tax purposes. An NRA, whether a nonresident alien or non-domiciliary, will be subject to a different transfer taxes (estate and gift taxes) than a U.S. taxpayer. Only the gross part of the NRA’s Estate that at the time of death is situated in the United States will be taxed with the estate tax. Although the rate of NRA’s estate tax will be the same as that imposed on U.S. citizens and resident aliens, the unified credit is only $13,000 (equivalent to about $60,000 of property value).
These may be ameliorated by any existing estate tax treaty. European countries, Australia, and Japan enjoys these treaties, The U.S. does not maintain as many estate tax treaties as income tax treaties.
The IRC defines the following property as situated in the United States: A) Shares of stock of a U.S. corporation. B) Revocable transfers or transfers within three years of death of U.S. property or transfers with a retained interest (described in IRC Sections 2035 to 2038). C) Debt issued by a U.S. person or a governmental entity within the United States (e.g., municipal bonds).
Real estate in the United States is considered U.S. property when it is physical personal property such as works of art, furniture, cars, and currency. Debt, however is ignored if it is recourse debt, but gross value is included, not just equity. U.S.-situs property is also a US property if it is a beneficial interest in a trust holding. Life insurance is NOT included as U.S.-situs property.
The estate tax returns must disclose all of the NRA’s worldwide assets, in order to determine the ratio that the U.S. assets bear to non-U.S. assets. The gross estate is reduced by various deductions relating to the U.S.-situs property. This ratio determines the percentage of allowable deductions that may be claimed against the gross estate.
As mentioned earlier, when real estate is subject to a recourse mortgage, the gross value of the real estate is included, offset by the mortgage debt. This distinction is very relevant for NRAs whose debts are subject to apportionment between U.S. and non-U.S. assets and therefore not fully deductible.
Accurate planning is crucial. Let us illustrate: An NRA can own US property through a foreign corporation and this property is not included in the NRA’s estate. This means that the US Real property owned by the NRA has now effectively been converted into a non-U.S. intangible asset.
And with Real Estate that was not initially acquired through a foreign corporation, you can still avoid future taxation to the estate by paying an income tax today on the transfer of the real estate to a foreign corporation (usually treated as a sale).
An NRA donor is not subject to U.S. gift taxes on any gifts of non-U.S. situs property gifted to any person, including U.S. citizens and residents. Gift taxes are imposed on the donor. Gifts from an NRA that are in excess of $100,000 must reported on Form 3520.46 by citizens and residents, however, Gifts of U.S.-situs assets are subject to gift taxes, with the exception of intangibles, which are not taxable.
If it is physically located in the United States tangible personal property and real property is sited within the United States. The lifetime unified credit is not available to NRA donors, but NRA donors are allowed the same annual gift tax exclusion as other taxpayers. NRA’s are also subject to the same rate-schedule for gift taxes.
The primary thrust of estate tax planning for NRAs is through the use of; the following: Foreign corporations to own U.S. assets, and the gift tax exemption for intangibles to remove assets from the United States. It is very important that the corporation have a business purpose and activity, lest it be deemed a sham designed to avoid U.S. estate taxes. If the NRA dies owning shares of stock in a foreign corporation, the shares are not included in the NRA’s estate, regardless of the situs of the corporation’s assets.
Let us break this down into one easy to read and understand paragraph:
In a nutshell, shares in U.S. corporations and interests in partnerships or LLCs are intangibles and the gift of an intangible, wherever situated, by an NRA is not subject to gift tax. Consequently, real estate owned by the NRA through a U.S. corporation, partnership, or LLC may be removed from the NRA’s U.S. estate by gifting entity interests to foreign relatives.
Ownership Structures: Here we discuss the ownership architectures under which NRA’s can acquire Real Estate. The NRA’s personal goals and priorities of course dictate the type of architecture that will be used. There are advantages and disadvantages to each of these alternatives. Direct investment for example, (real estate owned by the NRA) is simple and is subject to only one level of tax on the disposition. The sale is taxed at a 15 percent rate If the real estate is held for one year. There are many disadvantages to the direct investment approach, a few of which are: no privacy, no liability protection, the obligation to file U.S. income tax returns, and if the NRA dies while owning the property, his or her estate is subject to U.S. estate taxes.
When an NRA acquires the real estate through an LLC or an LP, this is considered an LLC or a limited partnership structure. This structure provides the NRA with protection of privacy and liability and allows for lifetime transfers that escape the gift tax. The obligation to file U.S. income tax returns and the possibility for U.S. estate tax on death remain, however.
Ownership of real estate through a domestic corporation, will afford privacy and liability protection, obviate the foreigner’s need to file individual U.S. income tax returns and allow lifetime gift tax-free transfers. *this refers to a C corporation, since a foreign shareholder precludes an S corporation.
Ownership of stock will not trigger a return filing obligation, unlike engaging in a U.S. trade or business which requires a U.S. tax return
Ownership of real estate through a domestic corporation has three disadvantages: Federal and state corporate income tax at the corporate level will add a second layer of tax. Dividends from the domestic corporation to its foreign shareholder will be subject to 30 percent withholding. Shares of the domestic corporation will be included in the U.S. estate of the foreign shareholder.
Furthermore, the foreign shareholder will be subject to FIRPTA, because the corporation will be treated as a USRPHC (upon the disposition of the stock in the corporation). The purchaser of the shares is then required the file a U.S. income tax return with 10 percent tax withholding. Actual ownership of the real estate may be held by the U.S. corporation directly, or by a disregarded entity owned by the corporation or through a U.S. partnership. An LLC that chooses to be taxed as a corporation can also be the corporation.
There are several advantages to foreign corporation ownership:
Liability protection– There is no U.S. income tax or filing requirement for the foreign shareholder. Shares in the foreign corporation are non-U.S. assets not included in the U.S. estate.
Dividends are not subject to U.S. withholding. There is no tax or filing requirement on the disposition of the stock. There is no gift tax on the transfer of those shares of stock.
Disadvantages of using the foreign corporation: A) just like with the domestic corporation, there will be corporate level taxes, because the foreign corporation will be deemed engaged in a U.S. trade or business. B) Possibly the largest disadvantage of ownership of U.S. real estate through a foreign corporation would be that the foreign corporation will be subject to the branch profits tax.
One of the most advantageous structure for ownership of U.S. real estate by NRAs is a hybrid foreign and U.S. corporation. It runs like this: The NRA owns a foreign corporation that in turn owns a U.S. LLC taxed as a corporation. The benefits to this type of structure is paramount to a good tax shield and offers: privacy and liability protection, escaping U.S. individual income tax filing requirements and it also avoids U.S. estate taxes. On top of that it allows for gift tax-free lifetime transfers, and avoids the branch profits tax.
The beauty and benefit of this is that the timing and the amount of this dividend is within the NRA’s control even though distributions from the U.S. subsidiary to the foreign parent are subject to the 30 percent FDAP withholding.
There are many things to consider and several structures available to limit tax liability, preserve and protect anonymity and increase profits of US Real Estate investments by foreign investors. We must keep in mind that each investment presents its own challenges and no structure is perfect. Advantages and disadvantages abound which will require a tailored analysis in light of the individual or group objectives.
It’s really about implementing a structure which will successfully carry the NRA through to his or her END GAME, with the utmost protection from liability and the maximum return on investment.
Different Types and Uses of Advanced Construction Equipment
The construction industry is experiencing more demand than ever before, given that urbanization is taking place at a faster pace the world over. The role that construction equipment plays therefore is of paramount importance. The more a company understands how to derive the maximum efficiency from each piece of equipment it has, the better its project execution becomes. Here’s a look at the many purposes served by different kinds of advanced construction equipment:
- Earthmoving & Mining: Construction equipment that is capable of lifting huge quantities of earth in one scoop falls in this category. While bulldozers and articulated trucks are part of this kind, they are quite versatile and are widely used in highway construction projects. Some of the other specialized equipment is:
- Surface Mining equipment, which includes electric shovels for mineral extraction, drills, mass excavators and giant draglines, which are extensively used in civil engineering.
- Underground mining equipment, while similar, needs to function under different space parameters. Advanced pieces of such machinery include scalers, scissor lifts, and continuous miners.
Valkor’s Gold Making Guide – Making Maximum Gold
Some World of Warcraft players are surprised to learn exactly how much gold other players can make strictly through mining. Mining gold in World of Warcraft (WoW) has always been thought of as the “slow” method to acquiring large amounts of gold. But if you had the ability to look into other players’ accounts who strictly use the mining technique to acquire gold, you would probably be very surprised to see how much gold some of them have been able to acquire.
One of the “secrets” to mining large amounts of gold is to get a hold of a good gold making guide. There are a lot of these guides available, given that WoW is probably the most popular online computer game ever made. One of the leading Gold guides is called “Valkors Gold Making Guide”. This particular guide has been around for a few years now and was written by a player with several years of playing experience under his belt. It has become a best seller in the “gold making” category of WoW guidebooks for the simple reason that it works.
Thousands of copies of this book have been sold and are being used daily by World of Warcraft enthusiasts to make and sell gold for maximum profit. The guide covers a lot of ground in its 145 pages, but one of the main themes throughout the book is not just the making of gold, but also selling in the auction house. Too many players make the mistake of going to the auction house unprepared. Valkor’s Gold Making Guide spends a lot of time teaching your how to go to the auction house fully prepared so that your can maximize the spread between your buying price and selling price. “But low, sell high” is as true in the online computer gaming world as it is in the real world because the difference between the 2 prices is your profit.
WoW players who are best prepared for the fast-paced action in the auction house usually profit the most. Experienced Auction House WoW players typically will always do better in the game than players who may have expertise in other parts of the game but lack Auction House skills.
Mines of Moria Leveling Guide
Mines of Moria is the latest expansion for the well-known MMORPG The Lord of the Rings Online. Announced on March 14, 2008 was finally released on November 18, 2008.
The storyline is set in Moria, the complex underground land of the dwarves, in north-western Middle-earth and it was extended by six more books. Two brand new classes were introduced (warden and rune-keeper) as well as a new weapon enhancement system. The character level cap was also increased by ten levels.
The fastest way to go through the ten new levels is to follow this step-by-step Mines of Moria leveling guide:
Eregion (Level 50-53)
Start by doing the quests at Gwingris, in northern Eregion. The next steps will take you to Echad Eregion, South of Gwingris then to Echad Dunann, to the East. After completing the quests at these locations, go to Echad Mirobel South-Western area of Eregion, then the storyline will take you to the Walls of Moria to defeat the guardian of the entrance to the mines, The Watcher.
The Great Delving (Level 53-54)
After finishing Volume II, Book I you may adventure inside the kingdom of the dwarves, to Durin’s Threshold and then, East, to Dolven-view.
Durin’s Way (Level 54-55)
Next, the Mines of Moria leveling guide will take you the Chamber of the Crossroads in Durin’s Way, the northern wing of the Mines of Moria.
The Silvertine Lodes (Level 55-56)
The Silvertine Lodes is an intermediate mine between The Great Delving and The Waterworks. The quests here are about all concentrated in the Deep Descent.
The Waterworks (Level 56)
The second part of your level 56 should take part inside The Waterworks, one of the deepest area of the Mines of Moria. The easiest way to get here is to jump in the pit at the Deep Descent in Silvertine Lodes. You can find most of the quests at the Rotting Cellar, in Waterworks.
Durin’s Way (Level 56-57)
The following quests will head you to Jazargund and outside to Zirakzigil, back to Durin’s Way the northern wing of the Mines of Moria.
Zelem-melek (Level 57-58)
The most important place of the mines is the Twenty-first Hall, in north-eastern Zelem-melek. There is an Auction Hall and Crafting Hall, you can also find all the trainers here as well as an important number of quests.
Redhorn Lodes (Level 58-59)
The Redhorn Lodes area is situated South-East from Zelem-melek. The Orc-watch is the most important node of quests here.
Flaming Deeps (Level 59-59)
One of the high level zones of the Mines of Moria, Flaming Deeps, is located South of Zelem-melek. Go to Anazarmekhem at the northern entrance to this zone and start questing there.
The Foundations of Stone (Level 59-59)
This is one of the areas inside the mines with an increased degree of difficulty. Although there are solo quests at the Shadowed Refuge, but it is best to do them with a friend.
Lothlorien (Level 59-60)
The area where your leveling should end is Lothlorien. All the quests here are at Mekhem-bizru.
This Mines of Moria leveling guide shows the best order to go throught the zones of Eregion, Moria and Lothlorien. Most of the quests can be done by solo players but you will have your share of group content quests.
Magical Panorama Route and Oliver’s Restaurant and Lodge
Imagine… dramatic mountain scenery with isolated buttresses, sheer cliff faces and unusual geological features; imagine spectacular gorges, fairytale waterfalls and thick lush forests. I introduce to you ‘The Panorama Route’ in the Magical Mpumalanga Province of South Africa. Mpumalanga meaning ‘The place where the sun rises’.
The Panorama Route offers the traveller a number of spectacularly scenic viewpoints to experience this wonderland and includes views of the Blyde River Canyon (the 3rd largest canyon in the world) and its Three Rondavels, God’s Window, Pinnacle Rock, Bourke’s Luck Potholes and a number of beautiful waterfalls such as Mac Mac, Lone Creek and Lisbon Falls. The region also has an historical influence and a visit to the historic gold mining town of Pilgrims Rest is a must. Take a stroll down its quaint little main road viewing the restored historic buildings and miners huts, visit the museum to view the old mining relics, stop in at the tourist office and join a guided tour to experience the life in the gold mining hey days and try your hand at gold panning.
Most of the Panorama Route is situated on the Highveld. The views from God’s Window and Pinnacle Rock look out over the Lowveld way below. These 2 areas experience comparatively different climates. The Lowveld is subtropical, due to its proximity to the warm Indian Ocean and latitude. The Highveld is comparatively much cooler, due to its altitude of 2300m to 1700m above sea level. The Drakensberg Escarpment receives the most precipitation, with all other areas being moderately well-watered by mostly summer thunderstorms. The Highveld often experiences severe frost, whilst the Lowveld is mostly frost-free. Winter rainfall is rare, except for some drizzle on the escarpment.
My suggestion to you when travelling to South Africa is to combine a 2-night stay in or near The Panorama Route, with your African safari experience in the world-renowned Kruger National Park or in the private reserves just west of Kruger. Three of my absolute favourite luxury game lodges are Londolozi Private Game Reserve, Savanna Private Game Reserve and Lion Sands Private Game Reserve. These are all situated in the Sabi Sands Game Reserve well known for its excellent game viewing and in particular, its brilliant leopard sightings.
Now to bring you back to your experience on the Panorama Route, my suggestion here would be to stay at the award winning Oliver’s Restaurant and Lodge. This lodge has built a great name for itself. It is owner run and offers a friendly home away from home experience. Situated on a peaceful and tranquil country golf estate within easy reach of the Panorama Route, Kruger National Park and Nelspruit, the closest international airport.
Oliver’s Restaurant and Lodge rooms are luxurious, spacious and beautifully appointed. Attention to detail is superb. Personal service is top class. Cuisine is to die for. These combined attributes make it an absolute pleasure to stay here.
Spend the day lazing at the pool or being lavishly pampered in their wellness spa. A game of golf is right on your doorstep at the White River Golf Club. Outdoor activities in the region are plentiful and include quad biking, gorge swinging, white water rafting, hot air ballooning, helicopter scenic flights, hiking and horse riding. Obviously with Kruger National Park being only 25km away, you could also enjoy the day game viewing in your own vehicle. Pack a picnic lunch and spend the day roaming around the park spotting our fascinating African wildlife.
So one sees the abundance of options available to you in this area. It is well worth spending a couple of nights here to become acquainted with it and its friendly people. Just another magnificent part of our Rainbow Nation!
High Potential in Kimberley Mine Dumps
History of the Kimberley Diamond Fields
South Africa’s first diamond was found in 1866 in the Northern Province, along the Orange River banks. Following the discovery of the diamond, there was a extensive diamond rush, with thousands of hopeful prospectors flooding the area in search of alluvial diamonds along the river’s banks as well as by the banks of the nearby Vaal River.
Within a few years, several large diamonds were found, among them one located on a farm called Jagersfontein, which later became a famous diamond mine. After a number of discoveries, the area became known as Beaconsfield, which is today a suburb of Kimberley. One year after the discovery of the Jagersfontein diamond, the Kimberley and De Beers pipes were discovered nearby Bultfontein, and similar discoveries were made at farms such as Benaauwheidsfontein, Dorstfontein and Vooruitzicht. A fifth was found 20 years later, known as the Wesselton pipe.
While the pipes were initially worked by individuals, as the depth of the digging increased a more effective solution became necessary. In 1888 the De Beers Consolidated Mines came into being, under ownership of Cecil John Rhodes, a combination of the Kimberley and De Beers Mines.
In 1897, the rights to dig the Kimberley Mines were bought by a new company – Kimberley Mining Limited (KML). They mined until 1914, using a method known as opencast pit mining. This continued until World War I, in 1914. After the war ended in 1918, the mine was simply maintained for the next 8 years. At that point De Beers Consolidated took charge, but other than a few samplings of the mine’s contents, once in the 1950s and again in the 1980s, the mine has lain dormant. In 2002, the New Diamond Corporation (NDC) took control, but without funding the dumps and the mine became available. Today the Meepo Investment Consortium, part of the New African mining operations, has the rights to both the Caravan Park Dumps and the Kamfersdam Dumps of the Kimberley mines.
Town of Kimberley
Kimberley itself was established in 1871 following the diamond discoveries, and the town’s growth was largely as a result of the various mines built in the surrounding area. The town is named after kimberlite rocks – geologic volcanic rock formations that occur in vertical pipes, and which contain diamonds. Over time, the formations erode and the diamonds are carried downstream by rivers and streams to collect in alluvial diamond deposits. Not all kimberlites contain diamonds, and of those found not all are of sufficient quality or quantity to attract interest. However the alluvial diamonds found are usually of higher quality than those found inside the kimberlite pipes – because by the time the alluvial diamonds are discovered in their riverbed locations, low quality stones have been destroyed by the river’s current and only high quality stones remain.
One of the world’s premier areas for diamond mining, the Kimberley area is known today globally by members of the industry. It is nearly 500 km from Johannesburg and nearly 1,000 km from Cape Town.
Abandoned Mine Dumps
Today, in the area surrounding Kimberley there are a number of abandoned mine dumps that may have economic potential. Three of those dumps are: The Caravan Park dumps, the Kamfersdam dumps and the Eddie Williams Oval dumps. The Kimberley Municipality owns the mining rights to these areas, which they hope to turn one day into low-cost housing. Diamond Recovery can be carried out at the plant which is secured, and has both water and electricity. There is a perfect area for disposing of tailings. Kimberley’s infrastructure means it can be easily reached by airplane, railway or other means of public transport, a great boon to mining the area.
Reliability of Reports
While surveying has been done of late, it is not easy to judge the reliability of the resultant report. Primarily, both tailings and waste material have been dumped together, making the grades somewhat unreliable and although samples were taken from certain areas, the grades in other areas not tested could be vastly different. Today’s successful diamond recoveries from the Kimberley tailing dumps could be indicative of poor techniques used initially in the diamond recovery plants of the previous century. Another possible explanation is that previously the material was ground too coarsely and the smaller stones were not released or that the poorer graded material was dumped along with the tailings. As an experienced investor in New Africa Mining, I would say that this material’s diamonds, through the processes of weathering, have been released and are turning up in great quantities, also increasing the number of diamonds being recovered.
Caravan Park dumps
West of the Kimberly Mine Museum, these dumps hold material originally mined from the Kimberley mine – one of the biggest mines that existed as the 19th century drew to a close – from 1871 until 1914. The diggers mined to an ultimate depth of 1,097 meters. The caravan park sits on top of material that is between 1 and 2 meters thick, and as it contains some 595,000 tons of tailings, graded 9 cpht, there are approximately 53,550 carats worth of total diamonds located in the grounds here, with the largest diamond recovered from this dump so far weighing in at nearly 23 carats. In 2005, the dumps were mined for a total of 187 days and 1,122 hours. A total of 74,800 tons were mined and 4,874.28 carats were recovered at an average grade of 6.7 cpht. Estimates are that some 42% of the original dump material exists, which means that there is extraordinary potential for mining and a great return on the investment it will require to bring these mines to a fully active working state.
Some six kilometers north of Kimberley, the Kamfersdam dumps hold material from the Kamfersdam mine, first discovered in 1880 and mined until 1914, when World War I broke out. By that time it had been mined to 104 meters deep. The Kamfersdam tailings dumps are all situated next to the abandoned Kamfersdam Mine north of Kimberley. The historically head grade of Kamfersdam was 28 carats per 100 tons (cpht). The two tailings of this dump total 5.2 meters or 5.4 million tons of tailings, which means there are an inferred.63 million total carats at 12 cpht. If 1 million tons are mined here per year, there should be another 4 – 6 years in which to make use of this resource. Despite the 12 cpht inferred, it is actually quite difficult to ascertain the grade of the material located in this dump, though it can be used for now. It will be important to discover the actual grade, as well as the average value per diamond carat – especially if it is to be compared with the diamonds found in the Caravan Park dumps so that a true estimate of its economic value can be ascertained. Over the next 4-6 years,mining these dumps should be an extremely lucrative venture, well worth the investment and a reliable source of income and investment return.
Eddie Williams Oval dumps
Some 3 kilometers north of Kimberley, these are a number of dumps that have very few resources left inside and are not worth discussing much further, so this paper will refrain from providing any more details at this stage.
A Short Primer To Get A Canadian Commercial Mortgage In The US
Owning a commercial property in the United States is the dream of almost every Canadian citizen living in the USA. Many of them have no idea of how to obtain a commercial finance or mortgage. Certainly, purchasing a commercial property in the US presents its own challenges, if you are not a US citizen, rather a Canadian. As per a survey by the National Association of Realtors (NAR), more than half of the property transactions are done in cash in the US.
However, commercial mortgage lenders are willing to extend credit to Canadian citizens on attractive terms. Sometimes these lenders even provide credit to them without a credit history in the US. Getting a commercial mortgage depends on the residential status of the Canadian citizen. Canadian borrowers can be categorized into the below categories based on their residential status.
- Non-permanent residents with a valid Work Visa (G1-G4, E1, E2, H1B, L1, H3, H2B, and H2A)
- Permanent Residents with a Green Card (form 1-551)
- Foreign nationals whose residence is not in the US
Paying for mortgage
If you are a Canadian citizen who wants to purchase a commercial property in the US, then be prepared to pay more for your commercial mortgage as US mortgages are compounded monthly as opposed to commercial mortgages in Canada which are computed semi-annually. In addition to this, there may also be tax deductible in the United States for its Permanent Residents. Whereas, there is no such tax deductible available for Canadian citizens interested in purchasing a commercial property in the United States by getting commercial mortgage finance.
How to apply for Canadian citizen mortgage?
Canadians can apply for a commercial loan in the US remotely via Email or phone, if they do not mind a few long distance charges. Most of the lenders and brokers strongly recommend that Canadian citizens should have a US business bank account via a ITIN (individual tax identification number) in order to facilitate the funding of finance and transfer of the down payments for the closing.
Some of the reputed lenders offer secured mortgages of up to 75% of loan-to-value (LTV) at very competitive interest rates. Canadian citizens can avail such finances in all 50 states of US. In order to attain maximum client satisfaction, such transactions are closed in 30-45 days. The closing of Canadian citizen mortgage should be done in person in the United States, preferably at the offices of the commercial loan lenders.
Documents required for processing of the mortgages?
- Legible copy of valid Canadian passport
- Copy of Canadian Credit History Report
- Fully executed legible purchase and sale contract which is signed by all the parties Verification of funds or deposit
- 3 months bank statements showing that they have enough funds for a purchase
- Personal Financial Statement stating Assets & Liabilities
- Professional Reference Letter from CPA & Personal Banker
- Bio or Resume on the Sponsor outlining previous ownership and experience managing such sizable investment
- property if more than a $1M.+ investment
- Real Estate Schedule of Existing Real Estate Owned In The U.S or Canada
- Copy of U.S Individual Tax Identification Number
- Copy of Earnest Money Deposit or Escrow Letter
- Canadian Primary Residence
The final thought
Many commercial loan brokers and mortgage lending companies in the US offer commercial loans to Canadian citizens after verifying their financial track record, residency status and work history.
How Cisco Meraki Can Save Both An Enterprise’s Time and Money
The whole idea behind Cisco Meraki was generated due to a peculiar problem faced by Tim Irimies, IT Manager of Saracen Mineral Holdings. The gold mining company has five mining sites spread across Western Australia that house over 200 employees and 750 contractors. Tim wanted to manage the networking needs of those sites and he had just two IT officials based in an office in Perth. The challenge was new, but it became evident that this was the need of the near future.
With the help of Cisco Meraki, Saracen was able to fulfill all his requirements with ease. Foremostly, it was easy to install; even a non-technical person could do it. It empowered the two IT officials Saracen had to monitor and troubleshoot the installation process without leaving the office in Perth. With Meraki devices in place, Saracen could now have transparency at what was happening at network devices, client devices and connections in real-time. This was not limited to a single property, but all the 5 mining sites. With the power to access remotely through Meraki Dashboard, Saracen had everything he needed.
If you analyze this particular case, with the help of Cisco Meraki, Saracen no longer needed to invest in numerous technical professionals to troubleshoot issues at all his locations. He was easily able to ensure a regular flow of information through all the sites without moving an inch. In addition, he was able to keep a track on all his network devices. He not only saved his money but also time.
In the current scenario, where time is of great essence, Cisco Meraki emerges to be a perfect solution for wireless management, networking, and switching. The best part is that it is also extremely secure, which makes it an instant favorite among the enterprises.
Some of the superior features of Cisco Meraki that cannot be overlooked are as follows:
- Considerably lower the network management investment
- Can be installed by any non-technical person
- Comes with pre-configured adapter and AP settings
- Offers an extremely reliable and unwavering network connection
- Easily scalable to accommodate the rapid growth of wireless
- Provides great savings on operational costs of a) Dedicated training of the staff, b) Deployment of trained officials at different locations and c) Software upgrade on separate devices periodically
- Easy access anytime and anywhere
- A unified view of the whole network irrespective if the diverse geographical locations of the end devices
Concluding everything, it is safe to say that Cisco Meraki is an excellent solution that can efficiently help an enterprise save their money as well as time investments.
How to Compare Mortgage Refinance Rates – Use a Mortgage Refinance Loan Comparison Site
You always want to compare mortgage refinance rates before choosing a particular a lender as this is truly the only method to ensure that you are being offered the best mortgage rate on the market. People refinance their mortgage for several reasons but whatever your financial goals are I can say undoubtedly that this is the best time in history to refinance your mortgage. With interest rates currently at all time lows, along with the attractive incentives from the Obama administration, it has never been so financially advantageous for homeowners to consider a mortgage refinance.
The best way to compare mortgage refinance rates is to utilize a mortgage refinance loan comparison site. These sites will let you evaluate what mortgage refinance lenders are able to offer you the best mortgage rates. They will usually have an application that you fill out online and after it is completed you are able to get instant feedback on whether or not a mortgage refinance is right for you. The best mortgage lenders will provide you a cost/benefit analysis free of charge to help you further identify whether refinancing your home is a wise financial decision.
A mortgage refinance loan comparison site basically will take the prospecting and researching part of the process of finding the best mortgage rates. It is important that you go to a comparison site that is affiliated with several mortgage lenders and not just a few. These multiple lender comparison sites make the various lenders compete over your refinance loan and therefore act as your personal broker in a sense. They are able to use leverage through a large affiliation of mortgage lenders to guarantee the consumer the best rate on the market.
When businesses compete you win. I’m sure you’ve heard this saying before but this statement is true in almost every business sector. More competition results in a better rate for the consumer. Multiple lender websites, while relatively new, have proven to consistently offer consumers the best mortgage rate on the market. Most of these sites are free to the consumer and you would be foolish not to utilize this service if you are considering refinancing your mortgage.
After you compare mortgage refinance rates through a multiple lender comparison site you will be matched up with 3-4 lenders who were able to provide the most competitive rates. I would suggest doing a little research before talking to a mortgage professional so you are able to ask them tough questions and see who you feel most comfortable dealing with.
Using a mortgage loan comparison site is the most efficient way to compare mortgage refinance rates and find a quality lender. Most of these sites are completely free to the consumer and I strongly encourage homeowners to at least consider refinancing your mortgage. There really has never been a better time in history to refinance your home and taking action now with historic low interest rates will most likely turn out to be a financially savvy decision.
Why Consider Having Your Broken Gadgets Be Fixed Rather Than Be Replaced?
If you have accidentally damaged your phone, it does not necessarily mean that you need to buy a new one. Screen cracked? Battery is not charging anymore? Camera and speaker stopped working? All of these issues can actually be fixed.
Experts highly advised having your broken gadgets be fixed instead of replacing them. Of course, this option is more affordable. But there are other reasons.
Why Opt For Gadget Repair Services
You will become knowledgeable – Repair will not give you control over your stuff; rather, it will connect you with it as you begin learning what makes it tick. Also, you won’t be overcharged for just a simple repair again.
E-waste can be prevented – Did you know that about 75% of broken gadgets end up in incinerators, landfills or e-waste dump sites worldwide? Gadgets being recycled are often shredded, and then sold as raw materials.
Mining and manufacturing efforts can be conserved – Mining is actually hard on earth. It can result to huge wastewater leaks. Manufacturing, on the other hand, has real human costs. If you opt to fix your old stuff, you are not actually contributing to the mining and manufacturing of new things or items.
Why Phones Get Broken
Dropping – About 29% of smartphone claims are associated with dropping phone down the stairs. Others even dropped their gadgets in parking lots, hot air balloons, sidewalks, and hardwood floors. It is for this very reason that it is very important for users to invest in cases that can withstand almost anything you can throw at it.
Liquid – These will include spilling a drink and dropping them in a toilet.
Scratching – Screen scratches are not just caused by the keys in your pocket. It is also caused by the particles of dirt and dust rubbing against the glass as you move. They can also be a result of loose items inside your handbag. Be reminded that you can have an unlimited supply of potential screen tarnishing alternatives.
Unlocking your phone – This can result to 2 things immediately. It will void your warranty as well as boost the chances of unintended damage to the software exponentially. It may even cause many of your apps to stop working. Bear in mind that if you commit any mistakes during the conversion process, you will certainly be staring at an error screen on a costly doorstop. Repairing must only be done by knowledgeable and skilled repair experts.
Children – 1 out of 4 parents reported that their phone have been damaged by their kids. With their mind boggling and creative ways, the little ones can actually destroy a lot of things. Be reminded that in the hands of a skilled child, your gadget can go from cutting edge to paperweight in an instant.
Regardless of what the reason may be for having a broken phone, it is highly recommended that you must have the experts fixed it. Look into reliable phone repair services in your area.
Manual Credit Card Imprinters Becoming Obsolete
Since the introduction of credit cards in the 1960’s, the cards have carried the card number, expiration date and cardholder name in embossed or raised letters on the plastic card surface. Mechanical devices were developed and used to imprint credit card charge slips from those raised alphanumerics. Those slips were then, for many years, deposited into the merchant’s bank account like checks to prove the transaction took place. More recently, the cards were affixed with a magnetic stripe and were swiped through electronic devices that read and transmit the card information to processing centers for verification and sale authorization.
Electronic processing has now become so standardized that last year Visa announced they were going to phase out the embossing of card information on the card surface and future cards will be “flat”, the card information printed but only accessible magnetically with the stripe on the back. Other card associations – MasterCard and the rest-will follow suit shortly.
Few merchants still manually take imprints of cards anymore, with the exception of merchants accepting card payments for delivery of goods or services ordered by telephone – such as a pizza restaurant, for example. They do so to verify that the physical card has been presented to the merchant during the transaction, in order to prevent fraudulent charge backs.
In my own wallet I have an ePassporte Visa Electron card and the numbers are flat. No imprint can be taken.
And no imprint any longer needs to be taken. The new standard is to always swipe the card through a terminal, whether that terminal be in the store, next to or part of the cash register or point of sale system, or via use of a wireless terminal a driver carries with themselves to the customer for payment at time of delivery.
If your business takes orders by telephone or mail and you are manually keying credit card numbers into your terminal, you are costing yourself a lot of money in additional card processing fees. Manually keyed-in transactions are processed as “non-qualified” transactions at a rate more than double your basic rate, due to risk of fraud by the card not being physically present.
The fact is, card imprints are no longer a safeguard against fraud, because any criminal can create phony credit cards and use an Addressograph machine to emboss stolen credit card numbers onto them. Encoding a magnetic stripe on the back, however, is almost impossible to counterfeit. The stripe contains not only the card number but other coding which, when swiped through a terminal, verifies to the bank that the actual card is present and being swiped, not manually keyed in.
What can a merchant do?
Short of purchasing some sort of portable photocopier to copy the customer’s card and perhaps I.D., the only thing to do is to catch up with 21st century technology and equip your drivers or delivery personnel with wireless credit card terminals. The terminals may be purchased or leased from your credit card processor and they pay for themselves quickly, because now all transactions they process will be under a lower rate, as card-present transactions.
These terminals include a printer so you can get a signed receipt from the customer after the transaction is put through and authorized, and you print a second receipt copy for the customer. Just as if the customer had been physically in your store.
I have equipped many mobile merchants with these devices: food delivery, locksmiths, massage therapists, computer technicians, handymen, plumbers and other repair personnel – the list is growing every day as more businesses go mobile and deliver their goods and services to customers. The terminals are also great for fairs, shows, conventions and other locales with no landline telephone access available.
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