SiouxlandProud | Sioux City, IA | News, Weather, and Sports Born and raised in Sioux City Chase Foix joined the KCAU 9 news team as a multimedia journalist in May of 2024 Chase attended Western Iowa Tech Community College where he could follow his passion in video editing and to soon graduate with an associate degree in video and media production in 2024 Chase hopes he can bring you the best news out here in the Siouxland district Medievalists.net Archaeologists have uncovered buildings linked to a medieval forge in the town of Foix located in the Ariège region of southern France conducted by the French National Institute for Preventive Archaeological Research (Inrap) is shedding new light on the town’s urban development and its historical role in ironworking is taking place in the historic district of Faurie This area’s name derives from the Occitan word faurià meaning forge—an indication of its long-standing association with blacksmithing The dig is part of a preventive archaeological survey ahead of construction ensuring that historical remains are properly studied before modern development takes place Archaeologists have already identified around fifteen well-preserved masonry structures dating from the medieval to early modern period with some sections oriented along an east-west axis while others were later added on a north-south alignment This layered construction suggests a long period of occupation and modification One of the key questions surrounding the excavation is whether the uncovered buildings were used for residential purposes or for artisanal work Early evidence strongly suggests the presence of a blacksmithing workshop and heat-affected soil have been found across multiple areas of the site archaeologists have identified clay-rich deposits likely linked to the construction of hearths or other industrial features associated with metalworking The discovery of a forge workshop aligns with Foix’s medieval reputation as a center for blacksmithing conducted during urban redevelopment projects revealed a large crucible filled with unrefined ore and iron slag—further evidence of the area’s role in metal production The excavation is scheduled to continue through May 2025 and ceramics joining the research team to analyze the site’s findings in greater depth The results are expected to provide valuable insights into the organization of medieval artisan districts and the evolution of blacksmithing techniques in the region further analysis will take place in laboratories with a final report on the findings set for publication in 2027 This research will contribute to a broader understanding of medieval industrial activities in France and their impact on urban development We've created a Patreon for Medievalists.net as we want to transition to a more community-funded model We aim to be the leading content provider about all things medieval podcast and Youtube page offers news and resources about the Middle Ages We hope that are our audience wants to support us so that we can further develop our podcast and remove the advertising on our platforms This will also allow our fans to get more involved in what content we do produce Member Login Please select what you would like included for printing: Copy the text below and then paste that into your favorite email application This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply Service map data © OpenStreetMap contributors Metrics details Corticobasal syndrome (CBS) is a neurodegenerative disease diagnosed based on clinical manifestations such as asymmetrical parkinsonism The background pathology of CBS is commonly a variety of proteinopathies but association with cerebrovascular disease has also been reported Foix-Chavany-Marie syndrome (FCMS) is a rare neurological disorder characterized by facio-pharyngo-glossal diplegia with automatic-voluntary movement dissociation presenting with bilateral paresis of the facial Transactive response DNA binding protein of 43 kD (TDP-43) proteinopathy is also known as the pathological background of FCMS while the pathological background of the majority of CBS cases consists of diverse tauopathies instead of TDP-43 proteinopathy we describe a case mimicking FCMS that was finally diagnosed as CBS with suggested 4-repeat tauopathy A 68-year-old female started experiencing difficulty speaking followed by difficulty writing Her impairment had been gradually worsening She presented some characteristics suggestive of FCMS Her symptoms exhibited rapid progression and myoclonus and left-side dominant cortical sensory deficit occurred resulting in the fulfillment of diagnostic criteria for CBS after 9 months Tau PET imaging displayed notable ligand uptake in the brainstem suggesting that her pathological background was 4-repeat tauopathy she became unable to eat and passed away after 12 months We hereby present an atypical case of CBS showing clinical features mimicking FCMS at first presentation TDP-43 proteinopathy was suspected based on the clinical symptoms in the early stages of the disease; however the clinical course and imaging findings including tau PET suggested that her pathological background was 4-repeat tauopathy we report a case of CBS presenting with clinical features mimicking FCMS at the early stage of the disease in addition to the clinical course and other imaging findings Brain magnetic resonance imaging revealed bilateral frontotemporal lobar atrophy on T2/fluid-attenuated inversion recovery (FLAIR) (A) Tau positron emission tomography (PET) with Florzolotau (18F) demonstrated remarkable uptake of the ligand around the brainstem and bilateral subcortical frontal lobe (B) 123I-N-isopropyl-p-iodoamphetamine (123I-IMP) single-photon emission computed tomography (SPECT) showed reduced cerebral blood flow in the bilateral frontal lobe and basal ganglia (C-1) Easy Z-score imaging system (eZIS) analysis of 123I-IMP SPECT imaging also revealed significantly decreased regional cerebral blood flow (rCBF) in bilateral frontal areas The clinical course of the present case is shown subsequently exhibiting dystextia and apraxia of speech Initial evaluation did not reveal indications of probable 4R tauopathy and cortical sensory deficits on the left side occurred her criteria pointed to probable CBS and raised suspicions of underlying 4R-tauopathy Single Photon Emission Computed Tomography; DaT PSP with predominant ocular motor dysfunction; PSP-SL PSP with predominant speech/language disorder; CBD While no case of CBS presenting with dystextia has been reported thus far it may actually be considered an early manifestation of CBS upper motor neuron signs may be more prevalent in 4-repeat tauopathies than previously assumed the usefulness of tau PET for the antemortem diagnosis of GGT remains undecided FLAIR showed only faint high signal intensity lesions in the subcortical region of the frontal lobe and no prominent white matter lesions while vascular pathology may be associated with the development of CBS it is unlikely that cerebrovascular disease itself causes CBS in the present case The major limitation of this case was that no autopsy was performed and neuropathological examination results are lacking The pathology of this case could have been CBD we present an atypical case of CBS presenting with clinical features resembling FCMS at the early stage of the disease Despite the fact that initial symptoms were similar to the motor neuron disease she eventually met the diagnostic criteria of probable CBS with imaging findings including tau PET imaging supporting the presence of 4-repeat tauopathy as the background pathology As CBS is a heterogeneous syndrome with various clinical presentations it will be essential to accumulate more cases in order to understand this disease Anonymized raw data supporting the findings of the present study may be shared by the corresponding author upon reasonable request Transactive response DNA binding protein of 43 kD PSP with predominant speech/language disorder The Significance of Vascular Pathogenesis in the Examination of Corticobasal Syndrome Unilateral opercular infarction presenting with Foix-Chavany-Marie syndrome Progressive anterior operculum syndrome due to FTLD-TDP: a clinico-pathological investigation Foix-Chavany-Marie syndrome due to type E TDP43 pathology Criteria for the diagnosis of corticobasal degeneration High-Contrast In Vivo Imaging of Tau Pathologies in Alzheimer’s and Non-Alzheimer’s Disease Tauopathies Agraphia in intellectually normal Japanese patients with ALS: omission of kana letters Agraphia in mobile text messages in a case of amyotrophic lateral sclerosis with frontotemporal dementia Clinical diagnosis of progressive supranuclear palsy: The movement disorder society criteria Atypical Progressive Supranuclear Palsy With Corticospinal Tract Degeneration Primary lateral sclerosis mimicking atypical parkinsonism Classification of primary progressive aphasia and its variants Prevalence of amyloid-β pathology in distinct variants of primary progressive aphasia A new MR imaging index for differentiation of progressive supranuclear palsy-parkinsonism from Parkinson’s disease The many faces of globular glial tauopathy: A clinical and imaging study Tau-positron emission tomography correlates with neuropathology findings Imaging-pathologic correlation in corticobasal degeneration Could hyperlipidemia be a risk factor for corticobasal syndrome Download references The authors thank the patient and her caregivers in this study as well as the clinical research coordinators and research ethics advisers at Niigata University for their assistance with the current projects We also thank Arndt Gerz and Mikhail Ratanov for their help in proofreading We are grateful to APRINOIA Therapeutics (Suzhou China) for providing the tosylate precursor used for 18F-florzolotau radiosynthesis This study was supported in part by JSPS KAKENHI Grant-in-Aid for Scientific Research (B) and (C) (Grant Number JP23H02825 and JP18K07543) by JST FOREST Program (Grant Number JPMJFR220R) by the Japanese Society of Neurology Novartis Pharma Grants for Basic Research 2022 This study was supported in part by JSPS KAKENHI Grant-in-Aid for Scientific Research (B) and (C) (Grant Numbers JP23H02825 and JP18K07543) JST FOREST Program (Grant Number JPMJFR220R) the Japanese Society of Neurology Novartis Pharma Grants for Basic Research 2022 Department of Functional Neurology & Neurosurgery Department of Biological Magnetic Resonance Quantum Life and Medical Science Directorate National Institutes for Quantum Science and Technology Analysis and Interpretation of Data; (2) Manuscript: A The manuscript does not contain clinical studies or patient data The PET study conducted for the present report was approved by the Niigata University Certified Review Board (UMIN 000050731) Written informed consent was obtained from the patient Written informed consent was obtained from the patient’s next of kin for publication of this case report Hitoshi Shimada holds patents on compounds related to the present report (JP 5422782/EP 12 884 742.3/CA2894994/HK1208672) and received honoraria for lectures from Eizai Co. All other authors declare that they have no conflict of interest Springer Nature remains neutral with regard to jurisdictional claims in published maps and institutional affiliations unless otherwise stated in a credit line to the data Download citation DOI: https://doi.org/10.1186/s12877-023-04564-z Anyone you share the following link with will be able to read this content: a shareable link is not currently available for this article A Salem man was sentenced to 30 years in prison Wednesday after he pleaded guilty to raping and sexually abusing an 8-year-old girl.  Darrin Foix-Jones, 23, was arrested in November on 12 counts of rape During his interview with Salem police investigators Foix-Jones repeatedly blamed his victim for initiating the sexual contact over a two-month period he said he just "went with it" following the girl's alleged advances.  The victim told investigators Foix-Jones abused her on multiple occasions — more times than she "could count on both hands." She told him the abuse hurt Marion County prosecutor Ashley Cadotte said Foix-Jones showed some cooperation by pleading guilty and not forcing his young victim to endure a trial he deserved more than the 25-year minimum sentence.  along with his "steadfast shift of blame to the shoulders of an (8-year-old) girl he was entrusted to care for .. whose trust he violated in the most heinous of ways," demands a longer sentence Cadotte recommended a 33-year and four-month prison sentence.  Foix-Jones pleaded guilty to three counts of first-degree sodomy four counts of first-degree sexual abuse and one count of first-degree rape.  Marion County Judge Tracy Prall sentenced him to 30 years in prison He was also sentenced to lifetime post-prison supervision and will be required to register as a sex offender upon his release.  email reporter Whitney Woodworth at wmwoodwort@statesmanjournal.com call 503-399-6884 or follow on Twitter @wmwoodworth the Federal Court of Appeal (FCA) issued its decision in Foix,[1] a case that involved a complex series of transactions put in place to sell a Canadian business to an unrelated third party Upholding a decision of the Tax Court of Canada (TCC) the FCA concluded that funds or property of a Canadian corporation had been distributed or appropriated to or for the benefit of its shareholders and that subsection 84(2) of the Act[2] therefore applied to deem some of the sale proceeds paid to the shareholders to be taxable dividends the lifetime capital gains exemption (LCGE) and the capital dividend account While the reasons for judgment do not include a complete recital of all the steps that were taken or the tax benefits the taxpayers were seeking from each step the taxpayer’s Notice of Appeal filed with the TCC helps fill in some of the blanks While the facts in Foix are somewhat unusual The court stated that an anti-avoidance provision such as subsection 84(2) should be given a broad interpretation and that the uncertainty and unpredictability that results is appropriate and the implications it may have in the context of other anti-avoidance provisions Souty met while doing consulting work for Videotron and they incorporated a Canadian corporation called Watch4Net Solutions Inc The company prospered: its main activity was the exploitation of proprietary software (called “APG”) that it had developed: it also provided IT advisory services.  By 2012 EMC US had approximately 65,000 employees globally and annual gross revenue of US $13 billion But it was always looking for acquisitions and growth In 2006 it made an offer to purchase the shares of W4N for an amount of US $3 to $5 million: Messrs Foix and Souty found the amount to be far too low and rejected the offer EMC offered to buy an exclusive license of the APG software from W4N in exchange for annual royalties a deal was finally struck: EMC US or its Canadian subsidiary EMC Canada would purchase the shares of W4N Foix’s holding company (Holdco) which held shares of W4N for an amount of US $50 million.[3] The tax advisors leapt into action the parties agreed to convert the transaction into a hybrid sale of W4N’s shares and assets: EMC Canada would purchase the shares of W4N and Holdco,[4] and EMC US would purchase most of W4N’s business and assets contracts with customers (except for customers located in Canada) and goodwill The parties signed a Hybrid Sale Agreement on or around May 24 Foix and Souty completed share-for-share exchanges and received new shares of Holdco and W4N respectively using election amounts of $750,000 under subsection 85(1) of the Act to crystallize capital gains sheltered by the LCGE The following four steps were then completed: The Capital Dividend Promissory Notes of $22 million were paid as dividends to the shareholders of W4N as part of the closing steps and elections filed under subsection 83(2) of the Act:[6] the notes were then settled by cash payment. The total cash amount received by W4N’s shareholders, including the cash of $18,170,078 received on the share dispositions in steps 1, 3 and 4 above, was therefore $40,170,078.[7] However in what the court viewed as the most critical issue the Balance Note of $19,750,000 was not paid at closing The corporate tax rate that applies to asset sales in hybrid transactions depends in part on the nature of the assets being sold and whether or not the target corporation is a “Canadian-controlled private corporation” (CCPC) at the time of the asset sale the Minister accepted the position that the assets were “eligible capital properties” (goodwill) and that the 50 percent income inclusion was therefore business income to W4N (taxed at the general federal-Quebec rate of 26.9 percent) rather than a taxable capital gain.[8] Had the sale resulted in a taxable capital gain the income would have been taxed at a much higher rate (about 46.6 percent but only if W4N was a CCPC at the time of the sale.[9] Accessing the lower corporate rate is critical to these types of hybrid sale transactions,[10] and one consequence of the new “Substantive CCPC” provisions is that the higher corporate rate now applies: as a result these transactions are no longer viable.[11] The Minister’s position was that subsection 84(2) applied to deem some of the sale proceeds paid to the shareholders of W4N to be taxable dividends.[12] Curiously the Minister only applied the provision to proceeds of $3,191,155 — representing some of the proceeds in steps 1 and 4 — in the words of the Minister to “transform” capital gains for which the LCGE had been claimed into dividends.[13] “Where funds or property of a corporation resident in Canada have at any time after March 31 1977 been distributed or otherwise appropriated in any manner whatever to or for the benefit of the shareholders of any class of shares in its capital stock discontinuance or reorganization of its business the corporation shall be deemed to have paid at that time a dividend on the shares of that class equal to the amount (a) the amount or value of the funds or property distributed or appropriated by which the paid-up capital in respect of the shares of that class is reduced on the distribution or appropriation as the case may be,” [Emphasis added] stated that the taxpayers had correctly asserted that the target corporation (W4N) must be “impoverished” to the benefit of its shareholders and that funds or property must leave the target corporation and end up in the hands of the shareholders unless the Balance Note of $19.75 million owing by EMC US to W4N (and to the successor corporation) was in fact paid the funds that would have been used to pay the debt were in fact used to pay for the shares of W4N found key parts of the testimony of Messrs Foix and Souty to be inconsistent with the Hybrid Sale Agreement Foix was “difficult and evasive” during his cross-examination stated that the “heart of the debate” was what became of the Balance Note: either the debt was paid or it was not all that was needed is for the appellants to require the EMC group to produce the accounting entry confirming the payment” concluded that it was open to the trial judge at the TCC to find that the debt of $19.75 million evidenced by the Balance Note was used to fund the cost of W4N’s shares While W4N or its successor corporation may have been impoverished (and EMC US enriched) if the Balance Note was cancelled or extinguished for no consideration,[14] did the funds related to the Balance Note “end up in the hands” of the former shareholders of W4N as required for the application of subsection 84(2) I suggest that it was appropriate for the court to conclude as it did Had EMC US paid the Balance Note of $19.75 million at closing W4N would have been holding the cash at the time its remaining shares were purchased in step 4.[15] Whether W4N had cash of $19.75 million at closing or a Balance Note of the same amount those assets were not required in its business: in fact substantially all of its business had already been purchased by EMC US instead of causing W4N to pay taxable dividends of $19.75 million its shareholders received the funds as proceeds of disposition for their shares with the result that the funds owned by W4N related to the Balance Note did arguably end up in their hands the Minister could have applied subsection 84(2) to the entire sales proceeds of more than $18 million received from EMC Canada rather than restricting the assessment (as was done) to amounts that were relevant to LCGE deductions While the FCA’s conclusion in Foix may be restricted to the somewhat peculiar facts involved including the TCC decision in Robillard,[16] that have argued for a strict and textual interpretation of anti-avoidance provisions “…the appellants argue that the trial judge’s broad interpretation of subsection 84(2) makes the application of this provision unpredictable and that it should be rejected on that account an anti-avoidance measure will necessarily raise question marks in the minds of those who choose to test its limits.” Compare the above to the very first sentence in the recent 6-3 decision of the Supreme Court of Canada (SCC) in Alta Energy,[17] in which the majority states that “The principles of predictability and fairness for the right of taxpayers to legitimate tax minimization are the bedrock of tax law.” The decision was sixty-six pages long but it was hardly necessary to read any further to know that the taxpayer had prevailed Alta Energy was a treaty-shopping case involving the sale of shares of a Canadian corporation to a shell company in Luxembourg to avoid tax on a capital gain of $380 million The majority concluded that the general anti-avoidance rule (GAAR) did not apply and that the gain was therefore exempt from Canadian tax: its position was that a largely textual interpretation was appropriate having regard to the facts of the case and the relevant tax treaty provisions contextual and purposive manner:[18] however how much emphasis is placed on a textual rather than a broader interpretation will depend on the particular facts of each case and the statutory provisions involved the FCA concluded that a broader interpretation was appropriate This was a breath of fresh air: a broader interpretation will invariably strike a more reasonable balance between the rights of taxpayers and those of the Crown only time will tell whether courts will now place a greater emphasis on a broader interpretation in the context of other anti-avoidance provisions Allan Lanthier is a retired partner of an international accounting firm and has been an advisor to both the Department of Finance and the Canada Revenue Agency Provide your email address to receive a weekly list of all content posted in the past seven days Follow Canadian Accountant on our social media channels Services will be at 10:30 A.M. Wednesday at the Holy Spirit Retirement Home Chapel. Burial will be in Calvary Cemetery. Visitation will be from 4:00 – 8:00 P.M. Tuesday with the family present from 6:00 – 8:00 P.M. and a Vigil Service at 7:00 P.M. all at Meyer Brothers Colonial Chapel. Online condolences may be sent to www.meyerbroschapels.com KS; she was the daughter of John and Daisy (Spriggs) Kenefake KS area and graduated from Kanorado High School Dorothy worked at the Sioux City Auditorium Concessions for 18 years and also worked for Aalfs Manufacturing and Gerkins Windows She was very active in the Altar Society and Rosary Society of the Church Survivors include her children: Michael Foix of Sioux City Aaron Foix and his wife Cynthia of Hornick Timothy Foix of Sioux City and Mary Miller of Sioux City; 14 grandchildren 34 great grandchildren and 1 great great grandchild Dorothy was preceded in death by her parents her son-in-law Gregory Bogenrief and her siblings: Mildred Carpenter Foix,“ Girard passed away Saturday August 3 2019 at her residence.  Memorial services will be 5:00 p.m 2019 at Meyer Brothers Morningside Chapel.  Visitation will be from 3:30 until 5:00 p.m 1949 in Sioux City Iowa the daughter of Merl and Alta (Sitzmann) Baxter.  She graduated from Heelan High school and attended NBT Business College.  She was a home maker and was Co - owner and office manager of Girard Top Shop.  Marlene was previously married to James Foix and Martin Girard rescuing injured wildlife and spend many years boating on the Missouri River.  She and her best friend and sister were captivated by supernatural phenomena and enjoyed many trips together to the Crescent Hotel in Arkansas.  Marlene will be fondly remembered by many for her infectious laugh but most of all her great joy was being “Grandma Marmaleen” Marlene is survived by her two children: Mona Foix of Sioux Falls and Joel Foix and his Wife (Karisa) of Sioux City.  Two grandchildren Riley and Chase Foix.  Four brothers: Bob and his wife (Maureen) Mike Chuck and his wife (Liz) and Pat; Three sisters: Nancy Prince Sue Christensen and her husband (Bill) several nieces She was preceded in death by her parents and two sisters: Marie and Mary Memorials may be directed to Noah’s Hope Animal Rescue.     Enter your phone number above to have directions sent via text Your access to this service has been limited If you think you have been blocked in error contact the owner of this site for assistance If you are a WordPress user with administrative privileges on this site please enter your email in the box below and click "Send" You will then receive an email that helps you regain access Wordfence is a security plugin installed on over 5 million WordPress sites The owner of this site is using Wordfence to manage access to their site You can also read the documentation to learn about Wordfence's blocking tools or visit wordfence.com to learn more about Wordfence Click here to learn more: Documentation (opens in new tab) 6 May 2025 14:23:09 GMT.Your computer's time: document.write(new Date().toUTCString()); Please enable JS and disable any ad blocker Metrics details Before discussing the spectra, it is worth noting that all precautions have been taken to prevent any contact of the samples with air by maintaining them in dry argon atmosphere or in high vacuum at all steps (details in “Methods” section). Charge compensation from oxygen (anionic redox) as deduced by HAXPES Evolution of O 1s photoelectron spectra at 6.9 keV (highest probe depth) during the a first and b second cycles Black dots are experimental data and red curves are fits Lattice O2– peak is at binding energy (BE) ≈ 529.5 eV On– grows at BE ≈ 530.5 eV (pink peak) followed by its reduction on discharge Surface deposits appear at higher BEs (gray peaks) Each O 1s panel has been normalized to keep the same intensity of the O2– component (green peak) for all spectra Note that the pristine sample was never in contact with the electrolyte and that its oxygenated surface species are those commonly observed at the surface of oxides The other samples are electrochemically prepared and hence show new surface oxygenated species compared to the pristine which come from electrolyte decomposition and passivating surface film formation An extra satellite peak at BE ≈ 535–536 eV is seen with 6.9 keV (and also weakly with 3.0 keV) The effect of probe depth on the O 1s spectra is shown for two samples c first charged at 4.80 V and d first discharged at 2.00 V Surface deposits diminish at high photon energies in contrast to the steady On– Changes in the monochromator energy resolution at different photon energies affect the shape of spectra (the worst energy resolution is obtained for 3.0 keV) Note that each O 1s panel has been normalized to keep the same intensity of the O2– component for all spectra Estimated percentage of oxidized lattice oxygen is plotted as a function of capacity to understand the anionic charge-compensation during the e first and f second cycles Results from 3.0 and 6.9 keV are overlaid in e and f The ±3% absolute error bars represent the uncertainty in the fitting procedure which was determined by comparing the effect of different initial conditions on the resulting fits To answer the important question about bulk vs. surface anionic redox, we compare the effect of different probe depths as shown here for two samples, i.e., first charged (Fig. 2c) and first discharged (Fig. 2d) While gradually going deeper into the two samples the intensity of On– component is not dependent on the photon energy and we do not observe much variation in % On– (percentage of oxidized lattice oxygen) defined as On–/(On– + O2–) by considering the integrated areas the contribution from surface deposits neatly decreases as hυ increases we can unambiguously conclude that On– is present in the bulk the quantification of % On– with HAXPES is more reliable than with surface-sensitive in-house XPS because the polluting O 1s signal from surface deposits is diminished at high hυ and hence the On– peak is not overshadowed but the ±3% absolute error is not insignificant as it leads to rather high relative errors when % On– is low (33% for % On– = 9 ± 3% vs 10% for % On– = 33 ± 3%) and further work is needed to overcome this uncertainty via improved energy resolution or surface cleaning Hysteresis and path dependence in activated LR-NMC studied by voltage window opening a Voltage profiles and b corresponding dQ/dV curves as the charge window is opened stepwise from 2.0 to 4.8 V LR-NMC is first activated by a few formation cycles in 2.0 to 4.8 V All curves in a and b start on the charge direction from 2.0 V (at 0 mAh g−1) and trace identical charging paths whereas the discharges vary with cutoff voltages Different regimes are highlighted with different colors Hysteresis is triggered above 4.1 V as the capacity expected from high-potential charge (4.1–4.8 V red) is split on discharge between high and low potentials the cell’s resistance (right axis in a) is also estimated by Ohm’s law applied to the voltage relaxation during a 10 s rest-step applied when switching from charge to discharge c Voltage profiles and d corresponding dQ/dV curves as the discharge window is opened stepwise from 4.8 to 2.0 V in a fashion opposite the first experiment All curves in c and d start on the discharge direction from 4.8 V (fully charged initially) The capacity expected from low potential discharge (3.4–2.0 V orange) is spread from low to high potentials on charge The cell resistance (right axis in c) is estimated from the voltage relaxation during a 10 s rest-step applied when switching from discharge to charge The SoC with cell resistance minimum on discharge path is shaded since cationic redox has the same dQ/dV peak on either charge or discharge it can be concluded that voltage hysteresis is associated with anionic redox which takes place asymmetrically between charge and discharge the cationic redox peak at 3.8 V is not affected by current (meaning fast kinetics) To further investigate the role of positive electrode in these results three-electrode electrochemical impedance spectroscopy (EIS) was performed at different SoCs Via detailed spectroscopic and electrochemical analyses of LR-NMC cathodes, we have revealed (i) their charge-compensation mechanism from anionic/cationic redox, and (ii) how the interplay between these two processes governs application-wise important challenges, such as kinetics, hysteresis, and voltage fade. Next, we connect our results with published knowledge in this area. The small Mn3+/4+ contribution is restricted to low potentials (shaded blue) on charge with some anionic activity also Further charge to 4.1 V (shaded gray) leads to the peak at 3.8 V mainly from cationic oxidation (Ni2+/3+/4+ and Co3+/4+) along with some anionic contribution the discharge curve (shaded gray) shows two peaks due to cationic (3.8 V peak) and anionic (3.2 V peak) reductions If charging is continued to 4.8 V (shaded red and green) it is mainly charge compensated by anions and then the corresponding discharge capacity is split at high potential (shaded green) and low potential (3.2 V reduction peak Fast kinetics accompanies cationic redox on either charge or discharge LR-NMC powders were synthesized with a two-step process involving carbonate co-precipitation followed by heat treatment stoichiometric Ni-Mn-Co carbonate was co-precipitated from an aqueous solution of transition-metal sulfates by introducing in it an aqueous solution of sodium carbonate (2 M) and ammonia (0.2 M) This was carried out in a controlled manner (pH = 8 stirring speed = 1000 rpm) by using a continuously stirred tank reactor (Bioflow 320 Eppendorf) to regulate the morphology and homogeneity of particles The resulting Ni-Mn-Co carbonate powders were heat treated with Li2CO3 at 850 °C for 12 h to obtain the LR-NMC powders with a primary particle size of ~100 nm as characterized by SEM (FEI Helios NanoLab 650) The crystal structure was confirmed with X-ray diffraction (BRUKER D8 Advance diffractometer with Cu Kα radiation) and the targeted elemental composition was verified with inductively coupled plasma mass spectrometry Li half-cells having LR-NMC powders hand mixed (to preserve morphology) with conductive Carbon Super P in a 90:10 mass ratio at the positive electrode (total weight kept ~20 mg for each cell to ensure repeatability) and Li metal foil at the negative electrode were assembled in Swagelock-type cells in an Argon glovebox (O2 < 0.1 ppm Positive and negative electrodes were separated with two layers of Whatman GF/D borosilicate glass-fiber sheets as the separator soaked with an electrolyte—LP100 (Merck) having 1 M LiPF6 dissolved in ethylene carbonate:propylene carbonate:dimethyl carbonate in a 1:1:3 weight ratio All cells are rested for 12 h before testing Once the desired SoC is achieved using a constant current density of ± 20 mA g−1 the Swagelok cells were disassembled in the glovebox carefully (ensuring no short circuiting) and as soon as possible (to prevent self-discharge under open circuit) The positive electrode powders were rinsed thoroughly three times with anhydrous dimethyl carbonate (DMC) to get rid of the electrolyte and soluble surface deposits DMC was evaporated by leaving the samples in vacuum (using the glovebox antechamber) for at least 1 h Note that our ex situ electrode samples were recovered as loose powders that were thoroughly mixed This averaged out any concentration gradients which can bias XPS results if slurry electrodes are used instead Great attention was paid to preserve the samples from air and moisture exposure during transfer and handling They were constantly maintained in dry argon atmosphere or in vacuum they were transferred directly from the argon glovebox (O2 < 0.1 ppm H2O < 0.1 ppm) connected to the spectrometer they were transferred from the on-site argon glovebox to the beamline introduction chamber (that was kept under vacuum) via a specially designed detachable stainless-steel transfer system (“suitcase”) The samples were first sealed in this “suitcase” inside the glovebox and then transferred to the beamline within 15 min All series of ex situ experiments (in-house XPS HAXPES and XAS) were performed on the same samples by pasting the powders on carbon tape HAXPES measurements were carried out at the GALAXIES beamline of SOLEIL synchrotron facility in France Photon excitation energies of hυ = 3.0 and 6.9 keV were obtained from the first- and the third-order reflections of the Si(111) double-crystal monochromator Photoelectrons were analyzed by a SCIENTA EW4000 spectrometer and the obtained energy resolution from the Au Fermi edge was 0.32 eV for 3.0 keV photon energy and 0.14 eV for 6.9 keV photon energy and the analysis chamber pressure was maintained around 10−8 mbar during the measurements Experiments were carried out using the single-bunch mode (lowest synchrotron brilliance) to minimize degradation under the X-ray beam The binding energy scale was calibrated to match the in-house XPS spectra on the same samples XAS spectra at Co LII,III edges were collected on the ANTARES beamline of SOLEIL synchrotron in France The ex situ cathodes were transferred from an Ar-filled glovebox to the analysis chamber using the same procedure as for HAXPES measurements in order to avoid air and moisture exposure Acquisition using a Bruker detector was carried out in TFY mode with about 100 nm probe depth The radiation was monochromatized using a plane-grating monochromator (PGM) which is characterized by a slit-less entrance and the use of two varied linear spacing gratings with a variable groove depth along the grating lines All measurements were performed over the range of 765–805 eV with a step size of 0.1 eV a linear background was subtracted from the XAS spectra and then they were normalized by the integrated area Lorentzian curves were used to fit the peak positions of the normalized XAS spectra T-shaped Swagelok-type cells were prepared with Li metal foil as the counter electrode and a small piece of Li metal as the reference electrode that was fixed at the exposed tip of an otherwise enameled thin copper wire (180 μm diameter) the reference electrode was placed well within the electrode-sandwich formed by the positive and negative electrodes Activated LR-NMC was used at the positive electrode after retrieving it from a coin-cell which had undergone five formation cycles as stated above This was achieved by disassembling the coin-cell (in discharged state) in the glovebox and quickly transferring the electrode to the fresh three-electrode cell Glass-fiber sheets soaked with LP100 (Merck) were used as separators After a few hours of rest to allow wetting and a cycle to confirm the expected electrochemical response EIS measurements were performed at varying levels of SoC achieved using a GITT protocol A 10 mV wave was applied with frequencies varying from 200 kHz to 1.4 mHz The data supporting the findings of this study are available from the authors on reasonable request Li, B. & Xia, D. Anionic redox in rechargeable lithium batteries. Adv. Mater. https://doi.org/10.1002/adma.201701054 (2017) Download references We thank Yin Yang for synthesizing the pristine materials Sarma for the fruitful discussions concerning HAXPES Experiments were performed on the GALAXIES beamline at SOLEIL Synchrotron We are grateful to Denis Céolin and Jean-Pascal Rueff for their assistance and to the SOLEIL staff for their smooth operation of the facility We also thank José Avila and Maria-Carmen Asensio from the ANTARES beamline for recording the Co-XAS spectra acknowledge the funding from the European Research Council (ERC) (FP/2014)/ERC Grant-Project 670116-ARPEMA Chimie du Solide et de l’Energie—UMR CNRS 8260 Gaurav Assat & Jean-Marie Tarascon Réseau sur le Stockage Electrochimique de l’Energie (RS2E)—FR CNRS 3459 Gaurav Assat, Dominique Foix, Charles Delacourt, Antonella Iadecola, Rémi Dedryvère & Jean-Marie Tarascon Dominique Foix & Rémi Dedryvère Laboratoire de Réactivité et Chimie des Solides (LRCS)—UMR CNRS 7314 prepared the samples and performed electrochemical measurements performed the in-house XPS measurements and analyzed the spectra supervised HAXPES experiments and analyzed the data wrote the manuscript with contributions from all authors The authors declare no competing financial interests Download citation DOI: https://doi.org/10.1038/s41467-017-02291-9 Sign up for the Nature Briefing newsletter — what matters in science Metrics details reporting on a patient with a spinal arteriovenous fistula and false-positive aquaporin-4 IgG test This patient was misdiagnosed as having neuromyelitis optica spectrum disorder (NMOSD) we are bringing for discussion another case of longitudinal extensive transverse myelitis in a middle-aged man This patient was initially considered to have NMOSD or primary progressive multiple sclerosis (MS) but in fact he had Foix-Alajouanine syndrome Presentation of this case report was approved by the Ethics Committee at Universidade Metropolitana de Santos and the patient signed a consent for our report provided that his identity remained confidential Magnetic resonance imaging revealed longitudinal extensive transverse myelitis from D6 to D12 without paramagnetic enhancement (a) Flow voids in the posterior epidural space of the dorsal and lumbar segments suggested vascular etiology for the spinal cord disease (b) Spinal cord angiography revealed a dural fistula starting at D8 in the left intercostal artery (c) Publisher’s note Springer Nature remains neutral with regard to jurisdictional claims in published maps and institutional affiliations Clinical pitfall: false-positive aquaporin-4 IgG leading to misdiagnosis of neuromyelitis optica spectrum disorder in patient with spinal arteriovenous fistula Rapid recovery from paraplegia in a patient with Foix-Alajouanine Syndrome Reversible acute and subacute myelopathy in patients with dural arteriovenous fistulas: Foix-Alajouanine syndrome reconsidered Clinical outcomes following corticosteroid administration in patients with delayed diagnosis of spinal arteriovenous fistulas Download references Guilherme L da Silveira & Rodrigo A Oliveira The authors declare no conflict of interest Download citation DOI: https://doi.org/10.1038/scsandc.2017.58 Feature Films Database Southern Mediterranean films database Scriptwriters European Film Schools Production Companies Distributors International Sales Submit a Film Industry Reports Co-Production Podcast Online Screenwriting Training Course Guided Course for Feature Film Writing Script Analysis Analysis of the potential of your series Cineuropa's Training Catalogue Film Festival Photographs Newsletter Photogalleries EUFCN Location Award Euro Film Fest 27 Times Cinema GoCritic! Advertise on Cineuropa Logos and Banners PRODUCTION / FUNDING France by Fabien Lemercier 19/07/2023 - Produced by DACP - De l’Autre Côté du Périph’ in league with Kissfilms the Guadeloupian director’s debut feature film is set for distribution in France by The Jokers Having kicked off on 30 May, shooting on Zion by Nelson Foix wrapped in Guadeloupe on 13 July This first feature film by the director (whose 2019 short film Ti Moun Aw also turned heads) stars Sloan Decombes the story revolves around 26-year-old Guadeloupian Chris who divides his time between crack deals in dark back alleys and getting his end away with young women His talents as a biker one day catch the eye of Odell who asks him to transport something in exchange for a shiny-new T-Max But as soon as Chris accepts this dangerous mission an unexpected and anonymous gift is left on his doorstep: a baby… Please subscribe to our newsletter to receive more stories like this directly in your inbox 02/05/2025Production / Funding – Italy Shooting begins on Walter Fasano’s Nino, a portrait of scoring maestro Nino Rota 02/05/2025Production / Funding – Belgium Wallimage is backing Michaël R Roskam's Le Faux Soir 30/04/2025Production / Funding – Italy The final clapperboard slams on Il falsario, starring Pietro Castellitto 30/04/2025Production / Funding – UK/France/Germany Sally Potter’s Alma to star Pamela Anderson and Dakota Fanning 29/04/2025Production / Funding – Spain Claudia Pinto finishes filming Morir no siempre sale bien 29/04/2025Production / Funding – Latvia The National Film Centre of Latvia unveils the recipients of its latest round of funding Subscribe to our newsletter to receive the most important daily or weekly news on European cinema Crossing Europe 2025 Review: Slackers Crossing Europe 2025 Review: Callas, Darling Cannes 2025 Marché du Film The Party’s Over! leads France TV distribution’s Cannes slate CPH:DOX 2025 CPH:DOX Industry Europa Distribution explores the release of documentaries at CPH:DOX Cannes 2025 Marché du Film AFCI runs its second annual Global Film Commission Network Summit at Marché du Film Festivals / Awards Czech Republic Czech Republic’s Anifilm goes sci-fi Distribution / Releases / Exhibitors Europe European Arthouse Cinema Day set to return on 23 November Cannes 2025 Marché du Film Indie Sales presents a three-star line-up at Cannes HOFF 2025 The Shadow and U Are the Universe win at Estonia’s Haapsalu Horror and Fantasy Film Festival Crossing Europe 2025 Awards The New Year That Never Came and The Flats crowned at Crossing Europe Cannes 2025 Marché du Film Be For Films to sell Love Me Tender in Cannes Cannes 2025/Sponsored Latvia set to shine bright at Cannes, led by Sergei Loznitsa’s competition entry Two Prosecutors Market TrendsFOCUSA busy spring festival season awaits the European film industry. Cineuropa will continue to keep its readers up to date with the latest news and market insights, covering the buzziest events, including Cannes, Kraków, Karlovy Vary, Tribeca, Hot Docs, Annecy, Brussels, Munich and many others Distribution, Exhibition and Streaming – 06/05/2025Europa Distribution explores the release of documentaries at CPH:DOXThe network has held a case study workshop as part of its brand-new partnership with the Copenhagen-based festival Distribution, Exhibition and Streaming – 02/05/2025Slovak crime-thriller Černák becomes the highest-grossing film in domestic cinemasThe second film in the saga about a local mafia boss, directed by Jakub Króner, outgrossed its first part, which dominated Slovak cinemas last year Jaśmina Wójcik • Director of King Matt the First The Polish director discusses her approach to taking on a 1920s children’s literary classic in an unexpected way Želimir Žilnik • Director of Eighty Plus The Serbian director discusses his deep suspicion of ideologies in relation to his irresistibly charming latest feature, which follows a man whose life spans three political systems Paulina Jaroszewicz • Distribution and marketing manager, New Horizons Association Cineuropa sat down with the Polish distributor to discuss her company’s strategy as well as the connection between its distribution line-up and BNP Paribas New Horizons Festival’s programme Lorcan Finnegan • Director of The Surfer The Irish filmmaker discusses his mystery-thriller, how he created the character with Nicolas Cage and his approach to the use of colours in the film Privacy Policy The images used on this website have been provided by journalists and are believed to be free of rights if you are the owner of an image used on this website and believe that its use infringes on your copyright We will remove the image in question as soon as possible We have made reasonable efforts to ensure that all images used on this website are used legally and in accordance with copyright laws About us | Contact us | Logos and Banners Mission | Partners | Team | Donations | Terms and conditions A Salem man was arrested on suspicion of sexually abusing a girl under the age of 12 was arrested by Salem police Saturday on three counts of first-degree sodomy and six counts of first-degree sexual abuse He was taken to Marion County jail and held without bail Foix-Jones is accused of abusing the girl over a two-month period in 2016 Dave Okada said Foix-Jones is involved in an open investigation He appeared for arraignment Monday before Marion County Judge Vance Day and was ordered to have no contact with his victim First-degree sodomy and first-degree sexual abuse are Measure 11 crimes with mandatory minimum sentences First-degree sodomy requires a sentence of at least eight years and four months and a first-degree sexual abuse conviction demands a minimum sentence of six years and three months Share on FacebookShare on X (formerly Twitter)Share on PinterestShare on LinkedInWICHITA FALLS TX - There is new information on a traffic stop that led to drugs and several arrests.Elizabeth Foix Johnathan Foix and Chelsea Hoyt were all arrested and sent to Wichita County jail following a traffic stop Monday afternoon.Around 2 p.m officers pulled over a vehicle on Van Buren and Seymour Highway for failing to signal.During a search of the vehicle officers found a ziploc bag containing marijuana and several sleeves of THC Wax Copyright 2016 KAUZ News All Rights reserved Israel-Premier Tech places two Canadian riders on podium in the Tour's first day in the Pyrenees The Canadian attacked out of a reduced leading group ahead of the Mur de Péguère playing off the work of his compatriot and teammate Michael Woods and soloed in for over 27 kilometres to give Israel-Premier Tech its second stage of the race after Simon Clarke's stage 5 victory Houle dedicated the win to his brother Pierrick who died after being struck by a drunk driver in 2012 while out for a run The emotion was clear on the 31-year-old's face a decade later as he celebrated his success Valentin Madouas (Groupama-FDJ) out-sprinted Woods for second with Matteo Jorgenson (Movistar) - who crashed on the descent of the Péguère "This means a lot to me," an elated Houle said "I had one dream: to win the stage for my brother who died when I turned professional it was to set the table for Michael Woods but they let me go and Mike made a gap I hung on and hung and was suffering so much on the steep part of the climb "I knew that if I got to the top with 30 or 40 seconds It was tight and a long time at 30 seconds but I never gave up When they showed me I was at one minute [after Jorgenson's crash -ed.] it was unreal and I knew I was going to do it "I was a bit afraid and suffered with cramps because I couldn't get to the team car for the last 60km but I made it." Despite numerous dodging and parrying on the two category 1 climbs that punctuated the second half of the 178.5km stage from Carcassonne to Foix the top overall favourites finished together Tadej Pogačar (UAE Team Emirates) tried to land a knock-out blow on the Port de Lers but found a well-armored Jonas Vingegaard well-supported by his Jumbo-Visma teammates Vingegaard was led to the line by green jersey holder Wout van Aert after being called back from the day's breakaway shut down any potential moves by second-placed Pogačar Also present was Geraint Thomas (Ineos Grenadiers) and David Gaudu (Groupama-FDJ) although they struggled briefly on the Mur de Péguère Adam Yates and Tom Pidcock (Ineos Grenadiers) and Louis Meintjes (Intermarché-Wanty-Gobert) lost touch and finished 1:19 behind the Vingegaard group but the biggest loser on the day was Romain Bardet (Team DSM) who lost touch on the Mur de Péguère and tumbled down the rankings from fourth to ninth Vingegaard continues to lead the Tour de France by 2:22 over Pogačar Quintana climbed over Bardet and Yates into fourth at 4:15 while Gaudu climbed three spots Meintjes remains in seventh at 5:46 while Aleksandr Vlasov (Bora-Hansgrohe) made the day's breakaway and gained over four minutes to scramble over Bardet Pidcock and Enric Mas (Movistar) into eighth the Tour de France peloton was down to 147 riders after Jakob Fuglsang (Israel-Premier Tech) left due to broken ribs from a crash on Sunday Lennard Kämna (Bora-Hansgrohe) who is sick with a non-COVID-19 cold and Aurélien Paret-Peintre and Mikaël Chérel (AG2R Citroën) who tested positive for the coronavirus Their departure left AG2R Citroën with only three riders: Benoît Cosnefroy Stan De Wulf and stage 9 winner Bob Jungels Neilson Powless (EF Education-EasyPost) started the attacking from the first kilometres sparking a 29-rider escape on the first stage in the Pyrenees With two category 1 ascents in the final half of the stage the breakaway wanted to gain as much time as they could as the Jonas Vingegaard - Tadej Pogačar battle would be in full flight Jumbo-Visma put green jersey Wout van Aert in the move Ineos Grenadiers launched Dani Martínez and Pogačar's team had Brandon McNulty there Aleksandr Vlasov (Bora-Hansgrohe) was the best-placed rider to make the breakaway in 11th place at 10:32 Stefan Bissegger (EF Education-EasyPost) led the escape over the first climb with a 5:05 lead on the yellow jersey group and over the top an attack from Mathieu Burgaudeau (TotalEnergies) Matteo Jorgenson (Movistar) and Alexis Gougeard (B&B Hotels-KTM) tried to go clear Jorgenson wisely sat up and let the French duo contest the Col de l'Espinas on their own His solo move was never going to stick and he was back in the escape with 125km to go The bunch remained together to the intermediate sprint in Lavelanet with 110.7km to go where Nils Eekhoff (Team DSM) surprisingly out-sprinted Van Aert and got a stern talking-to for it when Pogačar's teammate Marc Soler went out the back to the doctor's car Damiano Caruso (Bahrain Victorious) attacked the breakaway and was joined by Michael Woods (Israel-Premier Tech) and Michael Storer (Groupama-FDJ) That group caught the trio ahead before the top of the Port de Lers where Geschke added to his tally for the polka dot jersey as the leaders enjoyed a 9:20 gap but the action behind would soon distract from the lead group Movistar launched an attack from the yellow jersey group to try and pull Mas away He and two teammates gained nearly a minute before the summit and the surge whittled down the group significantly Meintjes spent some matches trying to spark a chase but the real action would happen closer to the crest Pogačar threw his gloves down and sprinted away from Vingegaard twice The chasing group were collateral damage and Bardet was among those wounded Just 12 riders were with the maillot jaune on the descent and they reeled in Mas before the next climb All of that action distracted from the counter-attack that brought Houle to the leading group along with several other riders Houle put attacked with 38.5km remaining and never looked back He made it to the Mur de Péguère with 31 seconds on the chasers Tony Gallopin (Trek-Segafredo) attacked to try and catch Houle only Woods and Jorgenson were on the heels of Houle with Madouas and Geschke picking up points behind Pogačar's teammate Rafał Majka kept them in check but came to an abrupt stop after snapping his chain Kuss came forward to set a brisk tempo near the summit Martínez came back from the breakaway and was there to help The Pogačar-Vingegaard tussle was over - for now it looked as if the top three on the stage would be North American with Houle being pursued by Jorgenson and Woods Woods let Jorgenson return to follow him to the finish but the gap to Houle was enough for him to celebrate the first major victory of his career while Madouas bridged across to the chase and out-sprinted Woods Results powered by FirstCycling This website is using a security service to protect itself from online attacks. The action you just performed triggered the security solution. There are several actions that could trigger this block including submitting a certain word or phrase, a SQL command or malformed data. You can email the site owner to let them know you were blocked. Please include what you were doing when this page came up and the Cloudflare Ray ID found at the bottom of this page. By continuing to use this website, you agree to the use of cookies in order to offer you content and services that are tailored to your interests. When Chris draws the attention of local gang leader Odell Chris finds that a baby has been left at his doorstep a race begins for Chris as he finds himself forced to make a crucial decision.. as well as representatives based in the U.S The organisation currently brings together more than 1,000 French cinema and TV content professionals (producers etc.) working together to promote French films and TV programmes among foreign audiences Look out for your first newsletter in your inbox soon We help you navigate a myriad of possibilities Sign up for our newsletter for the best of the city By entering your email address you agree to our Terms of Use and Privacy Policy and consent to receive emails from Time Out about news Sign up for our email to enjoy your city without spending a thing (as well as some options when you’re feeling flush) Our newsletter hand-delivers the best bits to your inbox Sign up to unlock our digital magazines and also receive the latest news By entering your email address you agree to our Terms of Use and Privacy Policy and consent to receive emails from Time Out about news, events, offers and partner promotions. Barcelona Do you know the oldest castle in Alt Penedès Have you ever walked along the banks of the Foix River Would you like to find out about an 18th century country house dedicated to wine and cava production Read on and get the most out of 48 hours in the Catalan wine region par excellence IN COLLABORATION WITH BARCELONA ÉS MOLT MÉS AND THE DIPUTACIÓ DE BARCELONA © Josep CanoUpon arriving in the region, we go up to Subirats Castle an excellent viewpoint to get an idea of what surrounds us and the many vineyards in the municipal area of Subirats We have references to the castle dating back to the year 917 and it was the first construction of these characteristics in the region The master or homage tower stands proud before the visitor marking the highest point of the building Partially rebuilt ‒ the castle suffered its biggest destruction in the 17th century such as a stone from the Via Augusta around 2,000 years old that was converted into a sarcophagus old bells or the stretchers used for hundreds of years to carry the deceased of the nearby country houses along the path of El Ordal to the church of Sant Pere de Subirats This former church of Sant Pere has been the shrine of the Virgin of la Fontsanta since 1726 and is located on a lower level of the fortress with side chapels and a semicircular apse partly carved out of the rock We have the whole of the second day to enjoy the region of Penedès We think it is worth discovering the path of the Foix River a route that follows the banks of this short river that crosses Alt Penedès and that you can combine with the Joc del Foix a game available online that consists of solving questions and riddles that emerge throughout the route if you buy the game you have a free meal in a restaurant in Sant Martí Sarroca and a visit to a winery You can start the route wherever you like and do part or all of it (in the second case we should mention that if you are still there today the stretch of the river path that goes through the town is the best way to discover its different population centres and explore the vine crops Thanks for subscribing! Look out for your first newsletter in your inbox soon! facebooktwitterspotifytiktokAbout us Contact us Time Out Worldwide One person has died and two others are in serious condition following a two-vehicle crash near the Town of Swiss in Burnett County according to a press release from the Burnett County Sheriff's Office the Burnett County Sheriff’s Office received a report of a two-vehicle crash on State Highway 35 near County Highway H in the Town of Swiss Three minutes before the crash was reported the Burnett County Sheriff’s Office received a 911 call reporting a southbound vehicle operating at a very high rate of speed in the northbound lane of STH 35 Initial investigation of this incident indicates that a 2002 Dodge Dakota operated by Michael James Sanders WI was southbound in the northbound lane of STH 35 when it struck a northbound vehicle driven by Arthur Foix struck several trees and caught fire; he was pronounced dead at the scene by the Burnett County Medical Examiner Foix and a juvenile passenger in his vehicle were airlifted to Twin Cities area hospitals with serious injuries No updates on their conditions were available at the time of this release Webb Lake First Responders and North Memorial Ambulance also responded to this incident No further information will be released at this time; investigation and crash reconstruction continues by the Burnett County Sheriff’s Office and the Wisconsin State Patrol Submit A Story or Press Release: DrydenWire@gmail.com Advertising QuestionsGeneral QuestionsDrydenWire Insider Questions the sale of a private business can be structured as either a sale of shares Structuring the sale of a private business as an asset purchase or a share purchase is often tax-motivated for both the purchaser and the vendor a purchaser will prefer an asset purchase and sale because the cost base of those assets acquired will be increased this will translate into increased capital cost allowance deductions available in subsequent years to reduce taxable income A vendor will generally prefer to sell the shares of an incorporated business as opposed to its assets because where those shares are qualified small business corporation ("QSBC") shares the vendor can usually take advantage of Canada's Lifetime Capital Gains Exemption to shelter part of the proceeds of sale A "hybrid sale" of a private business occurs when a private business is sold by selling both the assets and shares of the business to the purchaser separately the purchase typically acquires specific assets of the target corporation (i.e. or other intangible assets like goodwill) that are most useful for the purchaser's business the purchaser will then acquire the shares of the target corporation A properly structured hybrid sale thus allows each party to access the best tax benefits of an asset purchase and a share purchase where each has a different tax motivation behind how to structure the agreement The viability of structuring a hybrid sale depends on a number of factors unique to a proposed transaction including the nature of the assets the target corporation holds and the ability of the target corporation's shareholders to increase the adjusted cost base of their shares prior to sale And while hybrid sales are not inherently offensive from a tax perspective they have often been viewed with skepticism by the Canada Revenue Agency ("CRA") given that tax reduction is almost always a principal goal The Federal Court of Appeal's ruling in Foix v His Majesty the King, 2023 FCA 38 has threatened to radically undermine the tax benefits of a hybrid sale when selling a private business At first blush, the FCA's ruling in Foix undermines decades of jurisprudence concerning the meaning of a "reorganization" for tax purposes, and the extent to which even a carefully planned hybrid sale can avoid triggering the anti-avoidance rules of the Income Tax Act This article will begin by briefly exploring the nature of subsection 84(2) of the Income Tax Act and the anti-avoidance rule with respect to business reorganizations We will continue by exploring the actions of the taxpayers that were in question in Foix and the judgments of the Tax Court and the FCA we will explore some of the implications of the FCA's ruling for Canadian entrepreneurs and advisors who might otherwise want to structure a private business sale as a hybrid sale Subsection 84(2) of the Income Tax Act is an anti-avoidance provision intended to prevent taxpayers from inappropriately extracting the accrued value of a corporation in the process of closing or reorganizing the corporation's business If the conditions of subsection 84(2) are met then any shareholder who receives a distribution or appropriation of the subject corporation's funds or property is deemed to receive a fully taxable dividend (to the extent those distributions or appropriations exceeded the "paid-up capital" ("PUC") of the shares on which that distribution or appropriation was made) The phrase "in any manner whatever" has been interpreted quite broadly by Canadian courts Distribution or appropriation is typically found where the subject corporation has been "impoverished" to the benefit of its shareholders That typically means that some property or funds must actually leave the subject corporation and be received by the shareholders But an indirect distribution of the subject corporation's property with the help of a related party or facilitator might also qualify it is usually obvious when a wind-up or discontinuance occurs because these require positive steps be taken by the subject corporation to terminate its own business occurs where there is an actual change to the way the subject corporation's business operates Whether a business has been reorganized is fact-specific and depends on the form of a particular transaction or transactions as well as the substance of the subject corporation's business An improperly structured hybrid sale can easily run afoul of subsection 84(2) if the subject corporation's business is impacted by the sale which could severely limit the tax benefits of the hybrid sale structure for the vendors The Tax Court and FCA both provided a very broad view of the facts concerning the taxpayers in Foix and it remains unclear from both decisions exactly how the hybrid sale of the taxpayers' corporation was structured But we can still glean some crucial facts about the taxpayers' affairs from both judgments the target corporation owned by the taxpayers earned a substantial profit exploiting its proprietary software the shareholders of W4N began arranging for the sale of its business to EMC public company and one of W4N's major competitors In what would prove to be a crucial move for the taxpayers EMC produced a letter of interest to W4N very early in the negotiation process agreeing that the excess cash held by W4N could be extracted by its shareholders through any pre-closing transactions W4N's shareholders and EMC then agreed to sell W4N as a hybrid sale of assets and shares W4N's outstanding shares were then sold to a subsidiary of EMC for roughly $3.3 million The taxpayers each reported a capital gain related to the sale of W4N's shares on their 2012 tax returns and each claimed the Lifetime Capital Gains Exemption to offset part of those gains The CRA subsequently audited the sale of W4N's shares and reassessed the taxpayers on the basis the $3.3 million were deemed dividends pursuant to subsection 84(2) the taxpayers' lawyer argued that subsection 84(2) of the Income Tax Act had not been triggered by these distributions The Tax Court found conclusively that subsection 84(2) had been triggered and that the transaction had resulted in a reorganization of W4N's business for two reasons when the initial transfer of shares in W4N to EMC's subsidiary occurred that W4N had been deprived of its core business assets W4N's business no longer resembled the business it had operated prior to the transaction it did not matter whether the cash or cash equivalents that were exchanged between parties could not be traced to the original cash held by W4N EMC had facilitated the reorganization and allowed W4N to structure the hybrid sale to distribute the $3.3 million indirectly from W4N as part of a series of interconnected transactions Each transaction was in contemplation of the same end-goal which was to enrich W4N's shareholders using the assets of W4N the cash used to pay the purchase price of W4N's shares could be indirectly traced to the cash it held on closing The taxpayers case in Foix laid at odds with that of the taxpayers in Geransky v R, 2001 DTC 243 and McMullen v R, [2007] 2 CTC 2463 wherein those hybrid transactions avoided triggering of subsection 84(2) because at least some specific division of the target corporation's original business and related assets were preserved after the sale had occurred the cash the taxpayer in Geransky received after selling the target corporation's shares could not be traced whatsoever to the assets of the target corporation the court found the amounts paid were deemed dividends under subsection 84(2) the taxpayers' lawyer again argued that the funds of W4N were not distributed for the benefit of the taxpayers within the meaning of subsection 84(2) the lawyer again argued that for subsection 84(2) to apply to the distribution W4N would need to be "impoverished" for the benefit W4N continued to hold its assts after its shares had been sold the amounts the taxpayers had received were distributions from EMC and its subsidiary The taxpayer's Canadian tax litigation lawyer also argued that a reorganization had not occurred because the manner in which its commercial activities were conducted had not changed but was run by EMC following the transaction using the same employees and assets that W4N had prior to the transaction The CRA's tax counsel argued that the two conditions precedent for a reorganization that (1) W4N was impoverished for the benefit of its shareholders and (2) W4N's business was reorganized as a result of the series of transactions The CRA argued it would be overly formulaic to hold that the funds of W4N were not distributed to its shareholders simply because those distributions were not made by W4N itself but by other participants in the transactions The FCA accepted the CRA's position and reaffirmed the judgment of the Tax Court The FCA found that the funds and property of W4N were appropriated for the benefit of its shareholders and that those appropriations occurred in the context of the reorganization of W4N's business the FCA spent considerable time criticizing the previous attempts by courts to interpret and apply subsection 84(2) the FCA found that prior rulings had validated a "formalistic and restrictive application" of subsection 84(2) wherein indirect distributions of property or funds were found not to have triggered subsection 84(2) because it was found those distributions were not traceable as property of a target corporation but were simply property "of the same quality and quantity" held by a target corporation The FCA emphasized that the decisions of prior courts to focus strictly on the "legal character" of transactions in a series failed to give the proper effect to the statutory phrase "in any manner whatever" and that the judge of the Tax Court in Foix had fallen prey to the same trap by distinguishing the taxpayer's case on these grounds It does not appear at first blush that the FCA's reasoning is inherently wrong Canadian courts have consistently interpreted the phrase "in any manner whatever" in extraordinarily broad terms It would vitiate the purpose of subsection 84(2) as an anti-avoidance rule if the provision could be defeated simply by involving a third-party in a transaction to receive and distribute property of the target corporation to its shareholders But the FCA's judgment goes one step further to discredit the court's prior rulings in Geransky and McMullen, which have served as guidelines for structuring hybrid sales for nearly two decades The FCA's ruling undoubtedly casts a shadow over the ability of practitioners to rely on the ruling in Geransky and McMullen as a means to avoid triggering subsection 84(2) But it is equally questionable whether the decision in Foix fully overrides these previous rulings It remains the case that to trigger subsection 84(2) there must be an impoverishment of the target corporation for the benefit of its shareholders Ignoring the distinction between the target corporation's assets and the purchaser's assets because of the fungible nature of cash in every case appears to stretch the language of subsection 84(2) beyond its statutory framework The Tax Court's judgment acknowledges that the evidence presented by the taxpayers was spotty and evasive and the details of how the cash ended up in the shareholder's hands before and after the share sale was unclear And so it also remains unclear whether the ruling against the taxpayers in Foix has actually undermined the ability for taxpayers to rely on Geransky and McMullen to avoid eventually triggering subsection 84(2) or if this ruling simply emphasizes the need to exercise caution to avoid there being any possibility of the cash distributed to shareholders being characterized as possibly ever being from the target corporation JD is the founding tax lawyer of Taxpage.com and Rotfleisch & Samulovitch P.C. a Toronto-based boutique tax law corporate law firm and is a Certified Specialist in Taxation Law who has completed the CICA in-depth tax planning course radio and TV and blogs extensively.   Read the original article in full on TaxPage Author photo courtesy Rotfleisch & Samulovitch P.C On the first day of May in the year of grace 1387 started drafting his Livre de la chasse (The Book of the Hunt) Such a precise date must give rise to plenty of questions Did Fébus not have better things to do that day than pick up his pen it was the day before the eve of the summer feast of the Holy Cross a formal occasion that coincided with the start of the hart hunting season the Count of Foix’s favourite form of hunting This assumes that the preceding days had been taken up with preparations for this festive event after the long months of winter when the hunt was put on hold one could continue to hunt wild boar until the end of November and even up to the beginning of Lent The hare and the roe deer could be hunted all year round this winter hunting remained an occasional event The legend to the “déjeuner sur l’herbe” which prefaces in all the illustrated manuscripts of Fébus’ work What is nowadays called the “report back” takes place in the open air The trees have retained their green foliage The pitchers of wine have been put to cool in a stream nothing evokes winter and its frosts; “winter” refers to what is known as the winter feast of the Holy Cross This festive meal on the miniature is that of the fine days of 3rd May and 14th September Fébus thus wanted to link the drafting of the first pages of his treatise to the opening of the hunt season by making the closest possible association between theoretical exposition and practice in the field this is no longer easily understood as the hunting season now coincides with the season of harsh weather Actual hunting commenced with the gathering which we have seen to be a meal in the open air where those who sought out game came to present their report to the Master what precedes the chase of the hart and other animals Hart and wild boar hunting is clearly favoured by Fébus; nevertheless he did not disdain the hunting of roe deer was less mythical than it is thought to be and it is carefully described it was not as the outcome of a bear hunt that Fébus suddenly died at a time when that animal had certainly returned to the mountains he considered hunting the wolf to be almost impossible as that animal could not be taken except by surprise after having been drawn to bait and dogs set upon it to prevent it fleeing is preceded by a long preface running to five folios but preceded almost regretfully with a picture where three beaters armed with staves or long spears drive animals of all species towards nets set out as barriers Fébus took no pleasure in drafting the instructions that follow: he explains himself unhesitatingly and bluntly: for thus there would be more beasts if one did not falsely kill them It was out of charity for those who could not do otherwise that he agreed to describe methods of which he disapproved Those who indulged in such vulgar practices generally looked bad: “so when our new Hunter wants to take the hart vilely and cutting short his pleasure for it is truly an occupation of a fat old man or one who does not want to work.” The original text adds to these fat old men excised from their translation into modern French: the prelates The Livre de la chasse of Gaston de Foix did not appear out of thin air What is best called “French style hunting” the only type that really interested the Count of Foix nonetheless only achieved its definitive form with the drafting of his treatise One could say that this work had been awaited it was translated into English by Edward Duke of York who died at the battle of Agincourt in 1415 which only reproduced what dealt with hunting “par force” and which was entitled Master of Game the Livre de la Chasse was the hunting enthusiast’s bible combines the conciseness of a lesson with the keen interest of a man devoted to the subject A small group of six dogs still close together and all hunting by sight harry a boar running away across open terrain or meadowland with a few trees This type of landscape is a regular feature in the two manuscripts commissioned by Fébus but the landscape artist of Français 616 often opts for different landscapes whilst the two kennelmen on foot armed with a spear and crossbow merely watch as they walk slowly behind their hounds A boar can be slain with a spear or sword or crossbow but the noble way is to slay it with a sword without dismounting from one’s horse Its curly tail is a trait normally only found in domestic pigs the medieval boar often had this sort of tail instead of the short Domestic pigs often roamed free in the woods particularly in search of pannage in November but since this was also the boar’s rutting time The wild boars depicted in our manuscript all have curly tails – a sign of their mixed breeding – even though they are black and long-haired This was an excerpt from the commentary volume of the Livre de la chasse by Yves Christe of the University of Geneva. Our thanks to Moleiro Editor for this article and images Bibliothèque nationale de France MS Français 616 but Hugo Houle became the first Canadian to win a stage of the Tour de France on Tuesday’s first day in the Pyrenees He dedicated the win to his deceased brother Tadej Pogačar took the race to yellow jersey Jonas Vingegaard on the first of two Cat but there was little in the way of movement in the GC although Romain Bardet’s podium bid suffered a sharp blow You can watch the 2022 Tour de France at FloBikes Although it didn’t have the summit finishes of Wednesday and Thursday’s stages Tuesday’s Pyrenean fare wasn’t stingy 1 climbs came in the final third of 178.5 km crested with 27 km from the finish in Foix Three mountain stages left at the #TDF2022, and the first one is today, between Carcassonne and Foix, over a course comprising two tough first-category climbs. pic.twitter.com/sYzA6U621W — Quick-Step Alpha Vinyl Team (@qst_alphavinyl) July 19, 2022 It its 29-strong ranks were Hugo Houle and Michael Woods 11th place Alexandr Vlasov and Wout Van Aert 10th place Enric Mas of Movistar surged away with two teammates Van Aert and three others including King of the Mountains leader Simon Geschke joined the Woods trio before the peak Pogačar made his first thrust but Vingegaard found his wheel Fourth place Romain Bardet couldn’t hang with all the skirmishing The Slovenian attempted to lose the Dane on the descent Pogattack !!!!#pogacar #tdf2022 pic.twitter.com/gE8qtnUjrI — Miroir du Cyclisme ?? (@Miroir2Cyclisme) July 19, 2022 Houle and a couple of others swelled the Woods group on the descent and then Houle went clear Houle started up the Mur de Péguère with 30 seconds over Tony Gallopin and 52 seconds ahead of a Woods quintet The yellow jersey peloton was much larger after the descent Woods and Matteo Jorgenson were 40 seconds behind Houle Rafal Makja paced for Pogačar on the steepest part Nairo Quintana and Majka for about a kilometre until David Gaudu Geraint Thomas and Adam Yates hauled themselves over Kuss took over and distanced several riders Jorgenson and Woods tipped over 26 seconds after Houle Kuss and Quintana just after the peak of the climb Jorgenson crashed on the drop and it took him a while to find Woods again Canadian cycling fans were on the edge of their seats Houle pointed to the sky as he crossed the line Houle’s exploits moved him up to 25th on the GC Get the digital edition of Canadian Cycling Magazine Δdocument.getElementById( "ak_js_1" ).setAttribute( "value"