Religion and theology - 550 Words

Religion and theology (Essay Sample) Content: Name Professor Course Date The fundamental foundation of the church in a society cuts across both the younger and older generation. Moreover, the older generation ought to be ready to undertake ministry to the relatively younger generation devoid of any question concerning the direction the ministry. There is lack of understanding among the younger and older results to conflicts in conducting the operation of the gospel ministry of church (MacDonald, 96). Even though the older generation is concern with the question the direction of the younger individuals, it ought to yield the threshold that the younger generation feels require to reach its own generation. Both generations should appreciate the contribution of everyone within the ongoing ministry of the church that does not contradict the real experience of the favorable outcome. There exist no infusions of doctrinal exertion couple with the theological error which pass most positive manner. These positive manners are applicable devoid of grasping some of th e underlying fundamental weaknesses of the church in modeling the both generation in Church. The theological errors are found in a section of the renowned purpose Driven leaders. Wrong modeling in church results from opposition of objectives amongst the older and the younger generation in the church which originate from spiritual underdeveloped, selfish and ignorance. Thus, there is a need within the Discovery Group to concur with the pastor`s neutral and ideologies (MacDonald, 96). Pastor's ideas mainly rely on wisdom, patience and never sturdily braved by individuals within the church.The name changing procedure in church changes very poorly since it solely takes dual years of discussion, which concur to implement eighty percent of the plan with the majority votes of the pastor's votes. Nevertheless, they decline to abide by the own underlying rules because of their failure to attain own wants. Younger generation at the expense of the older generation is chosen to maintain within the membership which result to division in the church. Pastor ought to follow the outline rules of a simple majority instead of politics in order to get his objectives that might result to massive division within the Church. Utilization of innovative technology aids in the positive progress within Church thus few populaces in both generations oppose it (MacDonald, 76). The sound systems, some canned, power points, projection screens and background music are embrace in enhancing the public service. Technology in the church will aid older generation in singing and audibility hence resulting to positive impacts. Young group normally adopts the contemporary style of worship after the underlying mission field in demonstrations of numerous things. This clearly depict that prevailing younger generation ought...

Construction Contracting in Arizona - Free Essay Example

Sample details Pages: 10 Words: 2936 Downloads: 6 Date added: 2017/06/26 Category Building Essay Type Research paper Level High school Did you like this example? Construction Contracting on Tribal Lands in Arizona: Both the State Tax and a Tribal Tax May ApplyPage 1 of 7 SALES TAXATION OF CONSTRUCTION CONTRACTING ON TRIBAL LANDS IN ARIZONA: BOTH THE STATE TAX AND A TRIBAL TAX MAY APPLY Randal T. Evans* Arizona is home to 22 federally-recognized Indian tribes. Tribal lands comprise over a quarter of Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s land base. Don’t waste time! Our writers will create an original "Construction Contracting in Arizona" essay for you Create order As a result, a significant amount of construction activity in Arizona takes place on tribal lands, including recent and ongoing large-scale development projects. Contractors performing services on tribal lands in Arizona are faced with the somewhat daunting task of determining what taxes apply to each particular project. In Arizona, this inquiry involves two separate questions: (1) does the Arizona transaction privilege tax apply, and (2) does a tribal tax apply? Both of these questions require an analysis of state or tribal tax law and federal Indian law, but the two questions must be analyzed independently. In many situations, a contractor performing services on tribal lands may be subject to both a state and a tribal tax, as Indian tribes and states are recognized as having concurrent taxing authority over non-Indian transactions on Indian lands, except in limited circumstances. Further, this inquiry must be done on a project-by-project basis, as the law in this arena is par ticularly fact-based, still evolving, and filled with nuances, subtleties, and complexities. This article briefly addresses each of these questions, focusing on some of the more significant federal and state court cases and the Arizona Department of Revenueà ¢Ã¢â€š ¬Ã¢â€ž ¢s ruling dealing with transactions involving tribal lands. This article is intended as an introduction only. Contractors performing services on tribal lands will need to undertake a careful analysis of what tax laws apply for each particular project, working closely with their legal counsel and/or a state and local tax professional with experience in this particular area of law. Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s Transaction Privilege (Sales) Tax on Construction Contracting Differs Significantly From Other States In place of a traditional sales tax, Arizona imposes a Transaction Privilege Tax (TPT) on specified business activities, including retail sales, personal property rentals, and construction contracting, among others. The Arizona transaction privilege tax is commonly referred to as a sales tax; however, the tax is imposed on the business engaged in a taxable activity, and is not a true sales tax. Although the transaction privilege tax is usually passed on to the consumer, the legal burden (incidence) of the tax is on the seller. Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax treatment of construction contracting is significantly different than that of other states. In most other states, sales of building materials are taxable, and there is no sales tax on a contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢s receipts from construction services. Arizona is just the opposite. In Arizona, sales of building materials to contractors generally are exempt from the retail sales tax, and a à ¢Ã¢â€š ¬Ã…“prime contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢sà ¢Ã¢â€š ¬Ã‚  gross receipts from construction contracting are subject to the transaction privilege tax. See A.R.S. 42-5061(A)(27), 42-5075. As of March 1, 2014, the combined state and co unty tax rates for construction contracting range from 5.85% to 7.6%. See  https://azdor.gov/transaction-privilege-tax/tax-rate-table. There are many nuances to how the Arizona sales tax applies to different construction contracting variations, such as speculative build, design-build, owner-build, construction manager, and other types of contracting arrangements. These nuances in the state tax structure are often amplified when the construction takes place on tribal lands. In Some Situations, Arizona Sales Tax May Apply to Construction Services on Tribal Lands Historically, the U.S. Supreme Court held that states had no jurisdiction within the territory of an Indian tribe. Indian tribes are still recognized as sovereign entities under federal law (see the very recent U.S. Supreme Court holding in Michigan v. Bay Mills Indian Cmty, __ U.S. __ (2014), affirming that Indian tribes are à ¢Ã¢â€š ¬Ã…“à ¢Ã¢â€š ¬Ã¢â€ž ¢domestic dependent nationsà ¢Ã¢â€š ¬Ã¢â€ž ¢ that exercis e à ¢Ã¢â€š ¬Ã‹Å"inherent sovereign authorityà ¢Ã¢â€š ¬Ã¢â€ž ¢Ãƒ ¢Ã¢â€š ¬Ã‚  and upholding a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s sovereign immunity from suit). Notwithstanding, federal courts à ¢Ã¢â€š ¬Ã…“long agoà ¢Ã¢â€š ¬Ã‚  departed from the view that à ¢Ã¢â€š ¬Ã…“à ¢Ã¢â€š ¬Ã‹Å"the laws of [a State] can have no forceà ¢Ã¢â€š ¬Ã¢â€ž ¢ within reservation boundaries.à ¢Ã¢â€š ¬Ã‚  White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 141 (1980). Even so, states do not have unlimited regulatory authority over activities that take place on tribal lands. See Nevada v. Hicks, 533 U.S. 353 at 362 (2001). In the context of state taxation, the general rule now is that states may impose a tax on transactions that occur on tribal lands, unless the federal government has expressly prohibited state taxation (that is, unless federal law preempts the state tax), or the state tax would unduly interfere with significant federal and tribal interests. See Cotton Petroleum Corp. v. New Mexico, 4 90 U.S. 163, 188-189 (1989). There are several situations, discussed below, where federal law may prohibit the state from imposing a tax on construction services performed on tribal lands. Arizona Sales Tax Does NOT Apply to On-Reservation Services Performed by the Tribe or a Tribal Member Under federal preemption principles, state sales taxes may not be imposed on the business activities of an Indian tribe, a tribe-owned entity, or an enrolled member of the tribe, if the activities take place on that tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. See, e.g., White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 144 (1980) (à ¢Ã¢â€š ¬Ã…“[w]hen on-reservation conduct involving only Indians is at issue, state law is generally inapplicable, for the stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s regulatory interest is likely to be minimal and the federal interest in encouraging tribal self-government is at its strongestà ¢Ã¢â€š ¬Ã‚ ). The Arizona Department of Revenue, in Transaction Privilege Tax Ruling (TPR) 95-11, details its position regarding the taxability of construction work performed on an Indian reservation. TPR 95-11 recognizes that Arizona sales tax does not apply to the gross proceeds derived from contracting activities performed on a reservation by the Indian tribe, a tribal entity, or an enrolled member of that tribe. TPR 95-11 I.A, C. Arizona Sales Tax Does NOT Apply to the On-Reservation Services of a Non-Member Contractor Performing Services Under Contract with the Tribe, a Tribal Entity, or a Tribal Member The Arizona sales tax also does not apply to construction services performed under a contract with an Indian tribe, a tribal entity, or an enrolled tribal member, if the construction activities take place within that tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. Where a non-tribal member makes a sale or performs a service on tribal lands, federal courts generally apply a à ¢Ã¢â€š ¬Ã…“balancing testà ¢Ã¢â€š ¬Ã‚  to determine whether state sales tax applies , weighing on one hand federal and tribal interests, and on the other, the stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s interests. See, e.g., White Mountain Apache Tribe v. Bracker, 448 U.S. 136 (1980). This analysis is referred to as the à ¢Ã¢â€š ¬Ã…“Bracker balancing test,à ¢Ã¢â€š ¬Ã‚  named after the Supreme Court case that established the test. In Bracker, the Supreme Court applied this test and determined that Arizona could not impose motor carrier and use fuel taxes on a non-Indian logging and hauling company hired by a tribe for on-reservation logging operations. In that case, the state was prohibited from imposing its taxes because the interests of the federal government and the tribe, as reflected in federal regulations, outweighed Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s general interest in tax revenue. Bracker, 448 U.S. at 144-53. Two years after the White Mountain Apache case, the Supreme Court applied the Bracker test in holding that New Mexico could not impose its gross receipts tax on a contra ctorà ¢Ã¢â€š ¬Ã¢â€ž ¢s proceeds from the construction of a school built on the Navajo Indian reservation by a local school board which had been formed by a chapter of the Navajo Nation. Ramah Navajo School Board, Inc. v. Bureau of Revenue, 458 U.S. 832 (1982). As for Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s sales tax, TPR 95-11 recognizes that the Arizona tax does not apply to proceeds from a construction project performed on an Indian reservation by a non-affiliated Indian or non-Indian prime contractor, if one of the following conditions apply: 1. The activity is performed for the tribe or a tribal entity for which the reservation was established; or 2. The activity is performed for an individual Indian who is a member of the tribe for which the reservation was established. TPR 95-11 I.C. Under Ramah and TPR 95-11, in order to be exempt from the Arizona tax, the contract must be with the Indian tribe, a tribal entity, or an enrolled member of the tribe. As illustrated by the two cases discussed below (Blaze and Greenberg), if the contract is with a federal or state agency, the project generally will be subject to the state tax, even though the project ultimately benefits the tribe or tribal members. Arizona Sales Tax Generally DOES Apply to Construction Services Performed on Tribal Lands Under Contract with a Federal or State Agency Under the Supremacy Clause of the U.S. Constitution, states are not permitted to impose a tax directly on the federal government. See United States v. New Mexico, 455 U.S. 720, 733 (1982). This limitation applies only when the tax is imposed directly on the federal government or a federal agency or instrumentality, but does not apply to federal contractors in states such as Arizona, where the legal incidence of the tax is on the contractor. Id. at 735-36; see also Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue v. Blaze Constr., 526 U.S. 32 (1999) (receipts from BIA contract for the construction of roads on six Indian reservations in A rizona subject to Arizona TPT because the legal incidence of the tax fell on the contractor, not the government purchaser); Tucson Mech. Contracting, Inc. v. Arizona Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue, 175 Ariz. 176, 854 P.2d 1162 (App. 1992) (Arizona contractors subject to TPT on federal contracts; mandatory receipt provision in contracts did not shift the legal incidence of the tax to the government purchaser). In the Blaze case, the U.S. Supreme Court held that for federal contracts involving construction on tribal lands, the Bracker balancing test (discussed above) does not apply. Rather, courts apply the general rule established in United States v. New Mexico, that federal contractors may be subject to state sales tax if the legal burden of the tax is on the contractor. See Blaze Constr. Co., 526 U.S. 32. The same rule applies to contracts with state agencies for construction projects on tribal lands. In a 1995 case, the Arizona Court of Appeals affirmed the taxability of a construction contract with an Arizona school district (a subdivision of the State of Arizona), even though the work was performed on an Indian reservation and ultimately benefitted tribal members. Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue v. M. Greenberg Constr., 182 Ariz. 397 (App. 1995). TPR 95-11 establishes Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s position that à ¢Ã¢â€š ¬Ã…“[t]he gross proceeds derived from construction projects performed on Indian reservations by non-affiliated Indian and non-Indian prime contractors for all other persons [other than for an Indian tribe, a tribal entity, or an enrolled tribal member], including the federal government, are subject to the imposition of Arizona transaction privilege tax.à ¢Ã¢â€š ¬Ã‚  Arizona Sales Tax MAY Apply to the Receipts of Tribe-Owned and Tribal Member-Owned Contractors Performing Services Off-Reservation, Including Other Tribesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Reservations The Supreme Court has held that tribes and tribal enterprises may be su bject to state taxation for off-reservation business activities. Mescalero Apache Tribe v. Jones, 411 U.S. 145, 148-9 (1973). This is a general rule, and there are exceptions where the state tax may be prohibited by federal law or treaty rights. In Arizona, tribe-owned or tribal member-owned contractors generally will be subject to state sales tax for off-reservation activities, including services performed on another tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation. In a 1999 case, the Arizona Board of Tax Appeals upheld the application of the Arizona tax to the receipts of a construction contracting company owned by members of the Cherokee Nation for services performed under contract with the Tuba City Unified School District, a political subdivision of Arizona, located on the Navajo Nation. Flintco Inc. v. Depà ¢Ã¢â€š ¬Ã¢â€ž ¢t of Revenue, No. 1801-99-S (Oct. 19, 1999). Although, unlike Greenburg, the contractor was an Indian-owned business, the board followed a line of federal cases tre ating a non-member Indian the same as a non-Indian for jurisdictional purposes, and thus concluded that the Arizona tax was not prohibited by federal law. A Tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s Tax May Also Apply Independent of whether the Arizona sales tax applies, a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax may also apply to the receipts of a construction contractor performing services on tribal lands. Indian tribes have the authority to levy taxes on activities that take place within their reservation and may impose tax on non-Indians. See, e.g., Kerr-McGee Corp. v. Navajo Tribe, 471 U.S. 195 (1985); Merrion v. Jicarilla Apache Tribe, 455 U.S. 130, 137 (1982). The following analysis may be used to determine whether a construction contractor is subject to tribal tax: 1.Has the Tribe Passed a Tax Ordinance? The first step in determining whether a tribal tax applies is to determine whether the tribe has been authorized by its constitution, charter, or other governing instrument to impose taxe s and whether the tribe has passed a tax ordinance pursuant to such authority. The best way to determine whether a particular Indian tribe has a tax ordinance in place is to contact the tribe itself. The Arizona Commission of Indian Affairs maintains a list of Indian tribes in Arizona, with contact information for each tribe, at https://www.indianaffairs.state.az.us/tribes/tribes.html. 2.Does the Tribal Tax Apply to Construction Contracting? Assuming that the Indian tribe has enacted a tax code, the next step is to determine whether the tax applies to construction contracting activities. Below are a few examples of tribal taxes that apply to contracting services performed within the Indian nation or community. The Navajo Nation imposes a sales tax on all sales of goods or services within the Navajo Nation, including construction services. See 24 NNC 607. Effective January 1, 2013, the Navajo Nation Sales Tax Rate is 5%. See www.NavajoTax.org. The Navajo Nation also imposes a Business Activity Tax (BAT) that is subject to certain business transactions that fall outside the scope of the Navajo Sales Tax. In November 2013, the Office of the Navajo Tax Commission issued a Public Ruling on the Taxability of Pre-Construction Activities Under the Navajo Nations Sales Tax and Business Activity Tax. See navajotax.org/public_rulings_directory. The Salt River Pima-Maricopa Indian Community imposes a privilege license tax on business activities, including contracting, conducted within the Community. See Salt River Pima-Maricopa Indian Community Code 15-51, 15-52. The tax is structured similarly to the Arizona transaction privilege tax, with the tax computed on 65% of the prime contractorà ¢Ã¢â€š ¬Ã¢â€ž ¢s receipts for construction services performed within the Community. See Code 15-52(a). The tax rate depends on the ownership of the business. The tax rate for businesses owned and operated by non-Community members is 1.65%, while the rate for businesses owned and operated by Community members is 7.95%. This difference in rates follows the rule discussed above, that transactions conducted by Community members within the Communityà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation are not subject to the Arizona transaction privilege tax. See www.srpmic-nsn.gov/government/treasurer. The Gila River Indian Community imposes a license privilege tax on business transacted by persons on account of their activities on the Reservation. See Gila River Indian Community Law and Order Code, Title 13 (Business Licenses and Taxation), Chapter 3 (Imposition of Privilege Taxes). The Gila River tax on construction contracting is also structured similarly to the Arizona transaction privilege tax, allowing for a 35% standard deduction. See Code 13.311(A) (Construction contracting). Effective December 1, 2013, the tax rate is 6%. Id. If the project is subject to the Arizona transaction privilege tax, a deduction equal to 75% of the gross proceeds may be taken when computing the Gila River tax; however, this deduction only applies where the contract is between the contractor and a tenant in areas designated by the Community for the promotion of economic development. Code 13.311(C). See www.gilariver.org gt; Departments gt; Revenue/Internal Audit Department. 3.Is the Project Located on Indian Lands? The final step to determine whether tribal tax applies is to confirm that the construction project is fact on land that is part of the Indian reservation or community. A tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s power to tax non-Indian business activity extends to reservation lands (lands held in trust for the tribe), as well as trust allotments of tribal members and other lands that are considered part of à ¢Ã¢â€š ¬Ã…“Indian Country,à ¢Ã¢â€š ¬Ã‚  as that term is defined by federal law. Mustang Production Co. v. Harrison, 94 F.3d 1382 (10th cir. 1996), cert. den., 117 S.Ct. 1288 (1997) (tribe may impose a severance tax on non-Indian oil and gas producers operating on trust allotments outside of the tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s reservation). Except in limited circumstances, a tribeà ¢Ã¢â€š ¬Ã¢â€ž ¢s authority to tax generally does not extend to non-Indian fee land (or the equivalent of fee land), even if that land is within the exterior boundaries of the reservation. See Montana v. United States, 450 U.S. 544, 565 (1981) (with limited exceptions, Indian tribes lack civil authority, including taxing authority, over the conduct of nonmembers on non-Indian fee lands); Atkinson Trading Company, Inc. v. Shirley, 532 U.S. 645 (2001) (applying Montana and holding that the Navajo Nation did not have the authority to impose its Hotel Occupancy Tax on a hotel located on fee land situated within the exterior boundaries of the Navajo Reservation). Conclusion The tax treatment of construction contracting on tribal lands in Arizona involves the overlap of three distinct areas of law: (1) Arizonaà ¢Ã¢â€š ¬Ã¢â€ž ¢s tax treatment of construction contractors, which differs significantly from most other states; (2) tribal law governing the taxation of activities conducted on tribal lands; and (3) federal Indian law issues relating to the taxation of Indian tribes, tribal members, and those doing business with them. Each is a complex arena filled with nuance, subtleties, and complexities. Together, they create a perfect storm that churns up unique legal issues and requires careful and individualized analysis at the outset of each construction project involving services performed on tribal lands.

Technology And The Medical Field Advances - 875 Words

Technology has been advancing throughout history. People life has changed. Most of the people now have longer lifespan than before. As technology advances, the medical field advances accordingly. With these advances, people can survive from deadly disease. For example, chickenpox was deadly before a vaccine was found. With modern medicine, many diseases became curable. However, DNA mutations diseases where it survive and passed through our DNA to many generation can be difficult to cure and tracked. For instance, type two diabetes could be inherited from the family. According to Joslin Diabetes center (2016), if a person has parents with diabetes, it is more likely to develop a type two diabetes than other people. In addition, DNA mutations could develop a cancer. As National Cancer Institute (March 14th, 2016) reported that in 2016 there are 1,685,210 people diagnosed with cancer. With the advances in modern medicine, researchers are trying combat these diseases from DNA mutations, and other factors. One way is using this biotechnology CRISPR / CAS9 to edit genes. Cas9 is a part of the immune system for a bacteria to keep virus away from altering the bacteria’s DNA (Wyss Institute, 2016). Using this natural system and use it in our favor to remove and edit a CRISPR regions - Clustered regularly interspaced short palindromic repeats (Ma, Zhang, Huang, 2014). According Wyss Institute (2016), Cas9 can be programmed to activate and deactivate certain part of the DNA. InShow MoreRelatedEssay Advances in Medical Technology1014 Words   |  5 Pages2008 Advances in Medical Technology Medical Technology has developed to a great extent over the course of many centuries. Since the days of Hippocrates, considered the â€Å"Father of Medicine†, advances in the medical field have brought us into a brave new world. 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Human Rights Litigations Francophone West African Aspect

Questions: Preferably topics that relates to francophone westafrican countries. Topics should revolve around: Africa regional bodies(ecowas, sadc, comessa etc) maybe comparing an aspect of all the bodies. A particular human right in Africa (concentration on francophone west Africa). Maybe problems sorrouding Africa unification, or African unification and human rights. Answer: Human rights Litigations- francophone West African aspect The initiation of democratic system of Francophone Africa actually did not make available a facilitating setting for the safety of human rights all the way through force legal action.After independence in African countries, usually, they were more worried with state structure and nationwide harmony than with matters such as democratisation and admiration for the human rights.Consequently, in spite of the implementation of constitutions preserving human rights and elementary freedoms, exceptionally small was prepared to assure human rights. The permissible and supporting actions were not favourable to the defence of those human rights. On the other hand, the difficulty is whether the beginning of constitutional influence has direct to impact or deliberate proceedings which aspire at establish a human rights structure personalised by the authority of the rule of law and a see-through and responsible administration. The argument can be raised in this situation is that the whether the as sisting structure is enough to provide the protection to the human rights of the people. If it is not adequate then what measures can be appreciated in this regard. Gender equality in the process of dissolution of marriage- a francophone West African aspect New research and publications discover the fact that family laws are gradually growing in the direction of better impartiality among women and men at the time of dissolution of marriages in Francophone South African region. In tradition, on the other hand, matrimonial separation occurs in casual methods that engage a variety of either the conventional or the spiritual standards which is nor providing gender impartiality as a whole. The marriage is sacramental and divorce is the disaster for the husband and wife. So therefore divorces are considered to be the awful and difficult life event. But even if the divorce is taken place, the dominance of husband can be observed in this connection. Lack of adequate privacy protection law is a violation of human rights The existing codes and laws are inadequate to protect all the internet privacies. Being a developing country the Francophone South Africa also adopting new technologies. In this regard the law is not enough to fight against the new technological mishaps taken place to the citizens. Now it is the duty of the government to provide a unified adequate code to protect the people from this problem. Right to privacy is human rights so it needs to be achieved by the operation of law. The ECOWAS Community Court of Justice in delivery of human rights case- discussion on need for human rights court The community court for justice is actively providing the human rights justice in several cases. But the courts are overflow with other cases so proper attention is required in the field of human rights. So this community refers for the requirement of human rights court. The main argument can be placed under this topic regarding the increasing human rights issues and the need of adjudication process. The researcher can provide arguments regarding present system as well as required amendment are this system. References Privacyinternational.org,Francophone West African Civil Society Organisations Demand Better Privacy, Personal Data Protections | Privacy International(2015) https://www.privacyinternational.org/?q=node/388 The Danish Institute for Human Rights,Slow Progress of Equality in Marriage Dissolution in Francophone West Africa(2015) https://www.humanrights.dk/news/slow-progress-equality-marriage-dissolution-francophone-west-africa The Danish Institute for Human Rights,Slow Progress Of Equality In Marriage Dissolution In Francophone West Africa(2015) https://www.humanrights.dk/news/slow-progress-equality-marriage-dissolution-francophone-west-africa Privacyinternational.org,Francophone West African Civil Society Organisations Demand Better Privacy, Personal Data Protections | Privacy International(2015) https://www.privacyinternational.org/?q=node/388.

Most Memorable Day of My Life Essay Example

Most Memorable Day of My Life Essay Moon is an integral part of our universe. It is one of the beautiful heavenly bodies. It adds beauty and splendor to the darkness of night. The light of moon has a soothing effect. Walking in a moonlit night has its charm and beauty. It is a refreshing experience. It relieves you of all your tension and gives pleasure. Strolling in a moonlit night particularly during the summer add to the delight and pleasure. It elates the mood. Walking in a moonlit night not only delights our heart and relaxes our mood but also removes the boredom and weariness caused by the hectic schedule of the whole day.The atmosphere during the moonlit night is surcharged with calmness and quietness, particularly in the countryside which is away from the clamour and noise of city. The plants and trees and whole atmosphere bathed in the cool light of the moon present an enchanting sight. Walking in such an atmosphere really fills with joy. It elevates our spirit. It invigorates us for better thinking and ideas. We are filled with renewed energy and strength to carry on our next day task. It is indeed a thrilling and relieving experience.The entire nature robbed in a silvery shining light is so enchanting that we don’t like to go inside the house. It is so enjoying that we like to continue it for more and more time. Everything appears to be cheerful and mouthful. The sweet fragrance emitting flower, the dancing of petals in moonlit night is the soothing and cool wind and the trees whispering really render an absorbing sight. The sight in the remote countryside is all the more enjoying where there is expanse of green fields, flowers and fruits laden trees clothed in shining of moonlight serve as stress-buster.Poets have composed verses on the beauty of the moonlit night. It has a pet scene for the lover of arts including literature, artist, painter, etc. Whether walking, singing, playing, dancing or doing anything in a moonlit night has its own distinct experience. Indeed a moonlit n ight is a feast to our eyes. Punctuality Punctuality means arriving or doing things at the appointed time, neither early nor late. Punctuality is the secret of success in life. The renowned and successful men in the world are known to be punctual. They knew the value of time and utilized it in the proper way in their life.Time, like tide, waits for none, nor can it be kept in store for future use. Therefore, in order to live a meaningful life, one must make the best use of time; and the only way to make the best use of it is to be punctual. The habit of punctuality should be acquired step by step. Youth is the time of ones life to acquire this valuable habit. Once this good habit is acquired, it hardly goes away. It becomes a part and parcel of ones nature. A punctual person is cared and respected by all. The habit of punctuality adds much importance to ones personality.By using properly the tame in hand for the days work, one is able to achieve his goal in life. If a student is con scious about the value of punctuality, he should complete his home work, and prepare his lessons in due time, and then only it will be easy for him to cope with the progress of his class lessons in the school. He must get up early in the morning, take his meals in due time, and attend school punctually. For a businessman, punctuality is the soul of his business. Like a student, he is also required to move and act with the tide of time, by adjusting his programme of work with his lime in hand.He must keep his words, if he promises anything to anyone, quoting some particular time. Otherwise, he loses the faith of his customers; and that discredit amounts to loss of his goodwill in the market. By not being punctual, he loses business. An unpunctual person is not considered worthy of anything in life. He cannot be trusted with a responsible job. Thus he proves himself to be a failure in life. Punctuality, therefore, plays a very important part in ones life. A person should try to be pun ctual from his very childhood, and appraise others about the value of time, which is the key to success.CHARACTER It is truly said: â€Å"When wealth is lost, nothing is lost. When health is lost, something is lost. But when character is lost, everything is lost. † Character is everything in a man’s life. It is the total personality of man. A man without character is just a dead body that is hated by everybody. The importance of character can be realized from the fact that a student seeking admission from one school or college to another has to produce a character certificate from the former institution. A person applying for some post ust produce a character certificate from the head of the institution he last attended. Character is the sum total of all the good qualities in a man. It consists in honesty, truthful speech and dealings, dutiful- nests, diligence, and obedience to parents, teachers and elders. Sincerity, love of mankind, inner goodness and desire to do w ell to others and to be free from hatred, jealousy and malice are also part of character. To live in harmony with the people of all religions, races, castes and nations may be added to the characteristics of high character.Not to cast an evil eye on a member of the opposite sex is the essence of high moral character. Sometimes, there may be instances of loose moral character. But most often there are just rumors and guess-works which are deliberately engineered to malign a person out of jealousy or animosity. One should think twice before casting aspersions on anybody. We must accept all such rumors with a grain of salt. In any case, a man of character is bound to come out of the dark clouds as the sun appears bright in the sky.

King Kong Movie Review Essay Sample

King Kong Movie Review Essay Sample King Kong Movie Review Essay Sample King Kong Movie Review Essay Sample As we know, the love story of Beauty and the Beast, or rather a story of love for the beautiful monster has more than seventy years. Back in the twenties of the last century, the film was shot on Lost World by Arthur Conan Doyle, the story of a scientific expedition to a certain plateau where they found a variety of preserved prehistoric animals. It is unlikely that modern audiences have never heard of the phrase – King Kong. It has become a household name and is familiar even to infants. Without King Kong, there would not be the genre of â€Å"Monster Movie† (monster movie). Without it, there would not be Lord of the Rings because it is the King Kong that in 1933 impressed Peter Jackson so much that he wanted to become a director. One might expect that by todays standards the old King Kong would seem naive and ridiculous. However, this film is not a completely wasted former â€Å"margin of safety†. Directing workshop, advanced â€Å"special effects†, a fascinating plot, neat camera work, and a very good performance of actors are five â€Å"gold† terms of success of any film, even if it was shot a century ago. King Kong Movie – Original vs. Remake The original King Kong came out in 1933 and brought great financial profit to its producers. The plot of the film is simple. Fay Wray is hired by Robert Armstrong as a star in a film that he is making. The film should be shot on a mysterious island. The place is the home of the angry creature – Kong who kidnaps Wray. Later, King Kong is captured and taken to New York to be the part of the Broadway show. This allows King Kong to escape. Then, the evens are transferred to the Empire State Building. The human characters are one-dimensional. For example, Denham does not learn any lessons in the end of the film. In the center of the film, there is Kong and a tragic fable of Beauty and the Beast. Kong has strong impulse to protect and save Ann from predators. His tenderness is emphasized in the film. In King Kong, the true monsters are the fearful villagers, but not the rampaging creature. Of course, Kong sometimes is brutal and prone to vengeance. He opens his vulnerable heart only to have it broken and chooses a fate that means his death. The death of Kong is a loss that must occur and that the viewer should survive. To understand this, we must remember that at this period of history the environmental movement, which is so popular nowadays, did not exist. That is why, no one is worried about the environment and a strange creature. Other feature of the film is a revolutionary approach to musical arrangement as music by Max Steiner always accompanies and emotionally colors onscreen action, which in those days was not yet a common practice (e.g. in Dracula in 1931 music was only in the start and end credits). â€Å"It was Beauty killed The Beast† that is the last line in the original film and its meaning has not lost any of its power. It means simply that Kong is so infatuated with Ann that he, protecting her from harm, is going on a rampage that results in his death. That line, I think, is well-revealed in the original movie. In 1976, the new redesigned version was released. The difference between them is seen from the first look at the titles. Although in both films the viewer sympathizes with Kong and what happens to him, in the first version the audience does not feel guilt for the tragedy of Kong’s death, while when watching a remake there is blame attached to the death. There are a few â€Å"modernizing† changes, but the basic frame is left intact. Kong is the most thoroughly explored character in the film. The main female character of the first King Kong is totally confused and the viewer has such a feeling that she is on the edge of a precipice called â€Å"life†, not knowing what to do – jump down or try to fight for her continued existence. Dwan, on the contrary, â€Å"is the aspiring actress, who is found floating on a life raft in the middle of the ocean by the crew of Petrox Explorer† (â€Å"Monster Shack Movie Reviews†). The situation with the appearance of female characters is similar: whereas in the original version the actress is dressed modestly and even mediocre, her replacement’s entire appearance and looks in the movie (1976) represent wealth and confidence (â€Å"You Need Furs: The Meaning of Kong 76†). There is also a difference in the way Kong is created: in the first film he is a doll, while the director of the second one decides to go by the simplest way – the role of Kong is played by the man. Some changes are connected with the objective circumstances. For example, since in 1976 the tallest building in New York changed, Laurentiis transferred the end of the pictures from the Empire State Building to the building of the World Trade Center. We should agree with the point of view of James Berardinelli who says that â€Å"from a cinematography standpoint, King Kong impresses. Much of the location footage is epic in scope, especially the scene where the initial motorboat penetrates the fog bank surrounding Kongs island† (Berardinelli). In 1976, the distinguished feature of King Kong was that the plot of the film was brought up to date. In particular, the story had added some anthropologist who revealed some secrets. Under the existence of such a large monkey, scientific basis is left out. All these â€Å"dinosaurs, crocodiles, insects† part of an â€Å"abandoned the world† in the first film have been thrown out too. In the 1933 film, Ann Darrow is the character around which all events occur, but she is not a â€Å"deep† hero. In the remake, Dwan is a more richly realized figure. She is in tune with Kongs feelings for her and, at the same time, she is terrified of him (â€Å"You Need Furs: The Meaning of Kong 76†). The circumstances in which the film was shot and the historical background could not be reflected in the 1976 remake. It was the era when the questions of environmental protection were raised, and King Kong was not an exception. So, the death of Kong is not already necessary, but it is left as in the original. In the second release of King Kong, Denham is replaced by Fred Wilson who is the oil company executive with a set of not very good human qualities. He comes across Kong by chance and his decision to take him to New York is connected with the desire to resume his ailing financial stability. Thus, the remake is broadly faithful to the original story, but with some differences. â€Å"In the original, Kong is a violent creature†¦ while in the remake he only causes death when is forced into a confrontation† (â€Å"You Need Furs: The Meaning of Kong 76†). In the 1933 film, we see that there is no character who is not responsible for the death of Kong, while in the remake Prescott plays a significant part in it (â€Å"You Need Furs: The Meaning of Kong 76†). Another difference is that the originality and charm of the island has gone and this is undisputed. In the first King Kong, he battles different creatures and all this is well-directed. In the remake, hero does not come across monsters. In fact, Kong has to do that in the original. Moreover, the â€Å"original King Kong is a beautifully crafted masterpiece, full of excitement, atmosphere, emotion, and tragedy† as opposite to the new one (â€Å"Monster Shack Movie Reviews†). One more point is that the relationship melodrama Beauty and the Beast,, which is manifested in the old version, is not so openly compassionate and demonstrative by squeezing tears, as it is practiced in the remake of 1976 and later – of 2005. Despite some inevitable naive scene moments, the first King Kong truly touches the soul. It should be mentioned that King Kong of 1976 â€Å"has something the original lacked: a conscience. And that conscience was personified by the Princeton anthropologist, Jack Prescott† (â€Å"You Need Furs: The Meaning of Kong 76†). The third version was made by Jackson in 2005. The film King Kong is the new sequel to King Kong, which was filmed in 1933. The budget of this film is 207 million dollars. This is a picture made by a talented director in the fantasy genre. The film is truly Jackson scope, which has everything: a super special effects and wonderful cast. The really smart move of Jackson, in contrast to the 1976’ version, is keeping the story in the 1930s. In combination with the latest developments in the field of effects, it gives a striking effect. Another miracle Jackson made concerned a giant monkey. King Kong became alive and in the most natural way. He is the most actual computer character I have ever seen. What is most surprising is that King Kong does not only look real, but he also plays like the real thing. Moreover, under the guidance of Jackson, Kong completely overshadows all â€Å"live† partners, being the so-called â€Å"aliving† thing. Attention is drawn to the main female role. Naomi Watts is a small and fragile woman. Physique is similar to its prototype from 1933 played by Fay Wray. In any case, she is similar to the original to a greater extent than the luxurious and busty Jessica Lange flashed in the remake of 1976. John Guillermin does not pay attention to the fact that the figure of the heroine is of great importance, but for his remake it is not so important. Jackson shows us the ordinary girl and not only for the comparison with the scale of the gorilla. It is equally important for him to show a nice, modest girl who manages to fall in love with the hyper-male, the eighth wonder of the world. In a film about love of Beauty and the Beast, Naomi Watts plays so convincingly and subtly as she previously played in the movie with the scenes from real life. Her talent and absolute sincerity make a fantastic story in a sample of high drama where the borders between fiction and reality are wiped off. Unlike her predecessors, Watts creates a truly interesting, colorful character, which awakens in us a sense of responsibility for her life. The undoubted advantage of the new remake is the fact that a girl has the background, which helps us understand her nature better. This young actress is not only beautiful and talented, but she is also characterized by a heightened sense of self-esteem. However, to squeeze out more tears from an unsuspecting viewer, the author of the new King Kong (2005) does not consider it shameful to spend some catchy analogy with the story of Samson and Delilah and play climactic scenes through purely â€Å"cartoon† action using almost Shakespearean passions and other heavy arsenal. Despite the aura of high romance surrounding Kong and Ann, their relationships are spelled very realistically and not without a humor. Consider, for example, how resentful at her King Kong is after a fight with dinosaurs and she gets into the pose. He leaves, allegedly intending to leave her there alone, but he wants her to call him. When she calls, he picks her up immediately and readily. Jackson manages to take an unforgettable chase scene first when a mad crowd of people and dinosaurs are hilariously rushing in a strange direction, crushing and trampling each other and throwing each other into the abyss and the nearby ditch. However, we face a classic gloss. Despite the fact that the last version runs longer by 88 minutes than King Kong of 1933, Jackson tries to remain true to the original, but he also creates an epic movie for the modern audience (â€Å"King Kong Comparison†). The entire first hour of the picture gives the plot of the history and there happens absolutely nothing. However, even with the passive material, the director of the movie is able to make the audience empathize with what is going on, completely dropping out of reality. The immersion in the New York of 30th happens instantly and the escape from the abyss of retro is absolutely impossible. In a world where you find yourself one on one with nature and with yourself, there is no need to pretend. In general, each hero behaves in accordance with the logic of his character, which we catch before; just here on the island the essence of each is particularly brighter. The difference between the original version and the 2005 remake of King Kong is remarkable. However, the director of the film tries to reveal it from another point of view. In the original version, Kong is shown as a violent beast and a real threat to the humanity, whereas in the remake the character of Kong is more humanized. Nonetheless, I should agree that both films’ underlying messages can be very unnoticed with all the action, adventuring, and amazing special effects going on in the film. This ultimately makes it harder to pick out how power obsessed America was in the original, and how destructive we really are with nature today (â€Å"King Kong Remake Analysis†). Undoubtedly, plots of films are the same, but the dynamics of their development often differs substantially. The latter is explained by different views on certain events of films’ creators. For instance, in the new version negative and destructive impact on nature caused by humans is more pronounced. Moreover, understanding of inner world of King Kong is increased because he becomes an important part of the nature (â€Å"King Kong Remake Analysis†). In the original, the love of Driscoll is a clear demonstration that only through risking his life he is able to get love and respect of a woman. That is why, he so fearlessly rushes into the battle with the beast. It seems that Andrien Brody does the same in his version, but the attitude to Ann’s rescue is less motivated. â€Å"This is even truer in New York, where Driscoll’s reunification with Darrow atop the Empire State Building after Kong’s death has none of the pathos of the original† (Wartenberg). We can agree with Thomas E. Wartenberg that this is one of the problems with remakes. While they need to retain major elements of the original film in order to be a remake of it, they also have to fiddle with elements that seem arbitrary, offensive, or outmoded. The problem is that works of art are, as Hegel said, organic wholes, so that all of the elements are internally related to one another. Changing one has ramifications for all of the others. As Peter Jackson’s King Kong demonstrates, it is not easy to recreate an organic whole once you change one of its elements (Wartenberg). If we use the terminology of the Moscow conceptual school, then Jackson’s King Kong is an absolute picture with the most expressive and full accumulation of the collective unconscious and the collective conscious., At least, the viewer wants to lay out his metaphors on the shelves. In the end, the film lets everyone remember something personal while looking at a monkey, which being in a snowy New York grips the blondes in a row, hoping to find a particular one; or how having found her, turns around on the lake ice; or watching as Kong slides from the spire of the Empire State Building, we might think how great it is that we live in the time when the physical obstacles for the movie do not exist and the camera can track anything. King Kong made by Peter Jackson is a true masterpiece, combining a well-designed, exciting plot, great acting game, and the truly fantastic level of computer technology, which allows the audience to feel for a while like Alice in Wonderland, because so reliable and physically palpable is the world created on the screen. I think this is a film for all tastes. Those who expect exciting adventures will enjoy them in full. Those who wait a love story will see something to think about. I think that the modern version is the most touching and wonderful. The music adds even more poignancy. There are times when you cannot hold back the tears. Everything is so wonderfully shot; the scenery is like the real; Kong is as a true gorilla; and it is difficult to say at once that this is a merit of computer graphics. I think that in the next century King Kong will be interesting to watch too because shooting is really unique. The story itself is unique – the love of King Kong, a huge gorilla ape, for a beautiful girl for whom he is able to sacrifice even his life. The result of the creation of the film is not just a movie about a huge gorilla. It is filled with tragic and profound understanding of being a man in an unknown world. The intervention in his love of a man-destroyer raises a lot of questions, including the protection, but not the destruction of animals. We should not disturb their usual habitat because the animal is dangerous only if it is touched. No wonder, many researchers call the fact that humans appeared and spread all around the Earth as one of the biggest of environmental disasters of ancient times. The global environmental crisis has gone so far nowadays that disastrous consequences are almost inevitable, and we can talk only about their mitigation. In my opinion, King Kong is a good reminder about it. So, humans provoke aggressive behavior, and animals have to defend themselves and their loved ones. For the sake of his love, King Kong is ready to fight not only with a huge snake, but with an army too. The film has a very deep meaning and this is a huge merit of the director who has created a masterpiece. Obviously, different versions of King Kong are worth seeing: they have their own charm. It is better to see once than to hear about them twice. I recommend everyone to plunge into this unique atmosphere of the primitive and the modern.

Competitive advantage Research Proposal Example | Topics and Well Written Essays - 750 words

Competitive advantage - Research Proposal Example Cross-out skirt development might be fruitful when retail logistics arrangements utilize the right restricted manifestation of last mile dispersion, or motivating forces and interest administration systems to address this diverse neighborhood inclination. Cross chain retails logistics. Online and logged off retail are more incorporated on an operational level, strategic level (stock area and grouping arranging) and key level. Models for effective online extension, inside outskirt and cross-fringe, ought to subsequently be adjusted to incorporate the right part for disconnected from the net outlets on every one of the three levels. Not just web shops are included keeping in mind the end goal to conveyance administration, however different gatherings also. Logistics administration suppliers may deal with the conveyance and accumulation yet there may additionally be a part (e.g. For stocking parts) for suppliers/producers of items sold. In addition, buyers can be eagerly included, for instance, in the coordination of the conveyance (e.g. Through online networking) and discretionarily comes back to diminish crests and no-shows (Accenture 2012), The essential objective of this exploration task is to empower Dutch retailers with online channels to expand the piece of the overall industry through best-in-class logistics and satisfaction. Specifically, one will watch a noteworthy business sector potential for e-trade organizations to stretch the business by means of cross-out skirt deals to Belgium and Germany. Developments that come about because of the CATELOG task bring open doors for new business for organizations. Case in point, better purchaser learning and better information on the impacts of requesting conduct on logistics gives new business chances to a 4c in e-trade logistics. Moreover, developments in ICT instruments and architectures bring open doors for ICT organizations (Agatz, et al.