Writing comparison essay
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Wednesday, August 26, 2020
Leonardo da Vinci and Filippino Lippi Assignment
Leonardo da Vinci and Filippino Lippi - Assignment Example Da Vinciââ¬â¢s works are exceptionally particular. His lines are delicate and perfect, exceptionally definite and life-like. He additionally utilizes cross incubating for concealing. In his work, ââ¬Å"Self Portrait c.1512 red chalk on paperâ⬠, his master procedure is additionally appeared. The subject should be Leonardo da Vinci himself. It is a picture of an elderly person, with the face inclined towards the second from last quarter see. The subject isn't confronting the crowd however one can see the articulation in his eyes: grave. Like most Renaissance craftsmen at that point, his hair was long and he was bearded.The materials for this work of art are paper and red chalk. Like other da Vinci fine arts, this outline of a face of an elderly person (expected to act naturally), is anatomically great. The lines and wrinkles, up to the point that he hopes to have lost his front teeth, is depicted amazingly well in the representation. The lines are very fine and light, and the shadowing was finished by cross-incubating, which is exceptionally commonplace of da Vinci. Most researchers accept this was additionally done by a left hand. Lippi was the ill-conceived child of another painter, Fra Filippo Lippi. Under his fatherââ¬â¢s tutelage, he realized how to paint and outline. Likewise with da Vinci, Lippi was additionally an ace of life systems. Be that as it may, not at all like da Vinci who was progressively logical in nature (as in he imagines, he builds stuff, in addition to other things), Lippi was increasingly contracted and commission to work for chapels as he made frescoes. His style resounded quite a bit of Boticelliââ¬â¢s style. Truth be told, a portion of his past canvases have been marked, ââ¬Å"A companion of Boticelliâ⬠.
Saturday, August 22, 2020
Resource Management Developing Sustainable Business Organizations
Question: Examine about the Resource Management for Developing Sustainable Business Organizations. Answer: Presentation Universal Human Resource Management (HRM) alludes to the arrangement of human asset exercises that deal with the HR at national and worldwide level. The International HRM alludes to the ordinary HRM capacities, for example, enrollment, choice, preparing and improvement, execution examination and end of workers led at a global level. Alongside it, the universal HRM likewise relates to the exercises, for example, worldwide expertise the executives, preparing and multifaceted issues (Harzing Pinnington, 2014). In worldwide organizations, there are three sort of representatives, home nation workers which allude to the representatives having a place with the nation of origin where the corporate headquarter of the firm is arranged, have nation workers which alludes to the representatives having a place with the country where the auxiliary is arranged and third nation workers which alludes to the workers who are not from the host or the nation of origin yet from some other nation. The Inter national Human Resource Manager coordinates HR Policies and practices in various auxiliaries with the goal that the association can accomplish its objectives (Truss, Mankin Kelliher, 2012). Also, the International Human Resource Manager is dependable to build the adaptability in the associations strategies with the goal that it can suit the social contrasts in various nations (Nkomo, Fottler McAfee, 2010). In the current report, the worker connection issues in universal HRM have been investigated. Toyota is driving vehicle Manufacturer Company. The HR Manager of the association is moved from its auxiliary in Australia to the USA. While moving from Australia to the USA, the director will confront a few issues because of contrasts in economy and work arrangements of the two nations. In the current report, all the human asset issues looked by the association have been talked about. Effect of Presidency Change on Economy and Business in the US Tasks in worldwide condition can be trying for the business associations. The organizations need to adjust the strategies and business activities as per the nearby laws and foundation. The presidential appointment of the United States of America have been the most marvelous occasion of 2017 and the determination of Donald Trump as the enhanced US President will have a few long haul impacts on the nation. The new government has made a few laws, for example, expanding the duty on the merchandise, migration boycott and quitting Trans-Pacific Partnership Trade Deal in the USA (Garcia, 2017). The financial specialists and business associations are content with the presidential guideline because of the low corporate duties, less guideline, lower burdens on the intrigue and profit of the associations. Be that as it may, the presentation of fringe charges at a high rate has made noteworthy difficulties for the human asset the executives of the association. The fringe expense will climb the c osts of the car fundamentally (Lippert, 2017). Trump government has additionally cautioned Toyota for building up vehicle producing office in Mexico. The organizations will not, at this point have the option to make the vehicles in Mexico at less expensive rates and sell them in the USA at more significant expenses. In the USA, the nation has likewise restricted migration which will decrease the measure of accessible work for the association (Roberts Dason, 2017). One of the significant duties of the HR administrator is to guarantee that the association follows by the work laws and guidelines (Condrey, 2010). It is an imperative segment of the HR supervisors obligations. Guaranteeing lawful consistence with the work and the expense laws is significant for the proceeded with presence of the association. With the adjustments in the laws, the new HR supervisor will think that its difficult to actualize laws. The administration continually makes new guidelines with respect to the working long periods of representatives, charge stipends, break times, the lowest pay permitted by law and approaches on segregation (Cohen, 2010). The Trump government has rolled out some extreme improvements in least wages, expenses and segregation arrangements. The methodologies of the administration will require the HR chief to inspect the progressions required in the tasks of the association and execute them. In the ongoing turn of events, Donald Trump has given a danger against Toyota Motor Corp for building another plant in Mexico. The duly elected president cautioned the vehicle maker that it they will do the plans, they will confront huge fringe charge. Donald Trump made the danger as he was worried that the new plant will remove the work of the US residents. On the off chance that the organization would have had the option to re-appropriate work from Mexico, it would have been profited by the relative modest work of the nation. Obligations of International HR Manager The International HR Manager is at risk to adequately deal with the HR in the organizations which are working all around. They require having a profound comprehension of various societies and the capacity to react rapidly. The fundamental elements of the human asset experts are to deal with exercises, for example, enlistment, talking with, recruiting, preparing and advancement of the representatives so the business association accomplishes its objectives (Harzing Pinninton, 2014). The Human Resource Manager is additionally capable to create arrangements with the goal that profitable and safe working environment condition can be made. In worldwide condition, it is basic to spur and urge representatives to work cooperatively ignoring their social contrasts. One of the significant elements of human asset experts is to give preparing to the HR to guarantee a gainful domain is set up in the association (Collings, Wood Caligiuri, 2014). Preparing guarantees that the representatives have th e right stuff and the information to achieve the activity errands. The human asset supervisor makes course of action for the preparation of the workers with the goal that they are better gifted to play out their capacities. Preparing additionally guarantees that the organizations submit to the administration guidelines as it builds the representative information. In the global condition, the profile of human asset experts is turning out to be more generalist (de Juana-Espinosa, 2011). In the present, the association of the human asset experts with the inward activities of the association is decreasing and they are increasingly worried about coordinated effort and profitability of the association in general. Today, the human asset experts are worried about expanding the upper hand, monetary endurance and the productivity of the association. In such manner, the human asset experts play out a few activities, for example, recruiting workers, overseeing advantages and taking care of disc iplinary activities toward the representatives. They are additionally capable to deal with the medicinal services cost, decreasing the representative whittling down and taking an interest in the network (Chalofsky, 2014). They additionally work with directors in a joint effort with the tasks administrator in the enlistment of new faculty. In worldwide settings, the HR chief needs to work in a joint effort with the tasks administrator to enroll proper competitor and later in his exhibition assessment. The global human asset director has another provoking duty to assemble universal groups and bolster their coordinated effort. They need to take suitable measures to guarantee that assorted groups cooperate. The human asset experts receive a few techniques, for example, directing group building workshops, aiding coordinated effort of the socially differing individuals and worker commitment and inspiration strategies to accomplish the vital objectives of the association (Ehnert, Harry Zink, 2013). HR Implications of the Presidency Change in Automobile Industry The monetary capital and wages are likewise huge in the re-appropriating choice of the nation. The redistributing is utilized to spare expenses and increment the monetary advantages to the association. The nations like China and Mexico, whose economy is needy upon the redistributing exercises have created adaptable approaches to urge the remote organizations to contribute. The Human asset branch of the association gets profited by the profoundly gainful workforce, modest work cost and adaptable exchange arrangements (Grisham, 2011). Re-appropriating is likewise helpful for the association as it can upgrade the center skill of the association and result in new monetary development of the organization (TingTing, 2014). With the presentation of the present arrangement, either the firm needs to move its assembling plant in the USA or face high fringe charges. With the improvement of plant in the USA, the business worker relations will get influenced. The business relationship can be characterized as the legitimate connection among boss and the representatives. The business relations are framed when an individual works or offer types of assistance in the work environment consequently of pre-decided compensation. With the business relationship; equal rights and commitments are set up between the business and the representatives. The representative connection is the principle instrument through which laborers can access the rights and advantages related with the business laws and government managed savings of the nation. It decides the nature and the degree of managers rights and commitments towards their laborers. In addition, as the business and the worker work in closeness, they create proficient associations with one another. The administration of the business relationship is significant for an association as it is corresponded with the joy and the profitability of the workers. The business representative relationship is commonly dependent as the business is needy upon the worker to play out his obligations though representative is reliant upon the association to help him monetarily. In Australia, there is national work environment relations s
Tuesday, August 18, 2020
2019 Freshman Denial - UGA Undergraduate Admissions
2019 Freshman Denial - UGA Undergraduate Admissions 2019 Freshman Denial We plan to make the final wave of freshman decisions available today, March 15th in the late afternoon time frame. Unfortunately, we are not able to admit a number of strong applicants as we are limited in the size of our freshman class. We know that you have a number of other strong college options and suggest you focus on the other great opportunities that are ahead rather than on a denial from UGA. If your ultimate goal is to graduate from the University of Georgia, then we suggest you look at transfer opportunities down the road. For now, focus on your current college options, find one that fits you best, and have a great freshman year there. Please read ourDenied Student FAQif you have questions.If you decide to contact us next week, please understand that we will not be able to give you a specific reason for a denial, as in this process we have looked at everything within an applicants file, and the overall reason is really that the overall applicant pool is very large and very strong. Things to Remember: UGA does not use the GPA from a HS transcript, but instead we calculate our own HS GPA based on core academic courses. For our admitted freshman, roughly 88% of their core grades were As, and 11.5% were Bs. In our holistic review, we also look at grade trends to see how a student has progressed through their HS years. UGA looks closely at academic rigor, specifically what a student will take over four years as compared to what is available. This is not based simply on the number of AP/IB/DE courses, but instead we look at the overall coursework over four years in the five core areas and the progression of rigor over those four years. When we are looking at activities in the holistic review (clubs, sports, pt work, artistic activities, etc.), we are looking at depth and time commitment in these areas in addition to the actual organizations. Please remember that this is not a blog where you should post statistics or throw fellow classmates under the bus. These types of comments will be deleted.
Sunday, May 24, 2020
Does Spousal Abuse Have Permanent Effects - 1259 Words
Marcus Neeley Professor Ghanayem English 111 17 September, 2014 Does Spousal Abuse have permanent Effects? Imagine running down the street, with the bare minimum clothing, bleeding rapidly and you do not know where you are going. You feel like you have no one to go to or call, what can you do? Although domestic violence has been around for centuries, it was not until the advent of the womanââ¬â¢s movement about 25 years ago that the issue began receiving serious attention. Today, the issue of spousal abuse is the subject of countless books, films, and stage plays, because domestic violence often goes unreported, it is difficult to get a firm grasp on exactly how many domestic assaults occur each year. Furthermore, causes and effects of spousal abuse have been investigated for some years; leaving emotional and noticeable scares for life. Domestic violence often goes unreported because the victims are living in fear, and are to afraid to report the incidents. Women living in an abusive relationship are in constant fear of their abuser. Many wo men think reporting the abuse makes their abuser beat or even kill them if finding out. ââ¬Å"Some women who have left an abusive partner have been followed and harassed for months or even years, and some have been killedâ⬠(Lloyd Ohlin and Michael Tonry, 207). In addition, the wives do not want the husband to be put in jail because she needs them to help to take care of their children, although she would like to have some protection. She isShow MoreRelatedEssay about The Effects of Different Types of Abuse2444 Words à |à 10 Pages There are several different types of abuse and each type affects people differently. There is child abuse and spousal abuse, but there is also physical and mental abuse. This paper will go over each type of abuse, how the abuse affects the person, how people can recover from abuse, and just some general information. To start off I will discuss spousal abuse and its affect on people. Surveys in the US and Canada have shown each year about 12 percent of all spouses push, grab, shove or slap theirRead MorePsychology and Geology965 Words à |à 4 Pagestantrums, freezing or clinging on to their caregiver (DSM-APA). This can also be seen in sever phobias in adults but rarely does the adult have a temper tantrum, rather, a more developed emotional response is provoked. Typically, the amount of anxiety or fear that is actually observed during a phobic episode is entirely inordinate to the actual threat that a specific phobia may have (DSM-APA). For example, a man afraid of water howls and blubbers at the sight of a pool when the pool holds no threatRead MoreThe Domestic Violence And The Addictive Behavior1802 Words à |à 8 Pagesfurther, addictive and abusive behavior is not acceptable under any circumstance. The future is dependent upon the past, and when problematic issues are realized, this a ssists in resolving such in one owns life. More often than not however, that does not occur. The processes and procedures that now occur assist with this, and help children as well as other victims get through this. Roles of parents The traditional roles that parents play are usually one like a nuclear-family, where there isRead More A Lifetime of Damage Essay2397 Words à |à 10 Pagespractice of corporal punishment in the home and the lasting harmful effects on the children involved. The research is based on the opinions and finding of professionals in mental health and child development and offers little to no support for the use of physical punishment. This research outlines several areas of a childââ¬â¢s life that are acutely affected by the violent form of punishment called ââ¬Å"spankingâ⬠. Within our community I have seen first hand that children who are subjected to such punishmentRead MoreProblems of Society (Law, Crime, Punishment)7483 Words à |à 30 Pagesterm in prison. Probation Yet another widely used form of punishment, probation is most often used in lieu of imprisonment. A person is sentenced to probation for misdemeanours as well as a felony of a lesser degree. In some cases the convict may have to spend a part of his sentence in the prison. The person on probation is supposed to abide by the probation conditions set by the court. For instance, he is restricted from possessing weapons or moving out of the area of jurisdiction. The probationRead MoreThe Impact of Domestic Violence Against Women in Tanzania5091 Words à |à 21 Pagesit is perhaps the most pervasive In Tanzania women have been subjected to domestic violence in different situations and ways many women found them self doing things that they never wished to do such as, forced prostitution, this is when a women is engage in sexy activities un willingly in exchange of basic needs such a food cloth or shelter, men use their bodies to satisfy their needs in exchange of the basic needs. In Tanzania women have been subjected in domestic violence difference situationsRead MoreTaking a Look at Domestic Violence1955 Words à |à 8 Pagesestimated number of 960,000 incidents per year. Domestic violence is an aggressive or a violent behavior within the home, involving the violent abuse of a spouse or partner. ââ¬Å"Domestic violence is domestic abuse, spousal abuse, battering, family violence, dating abuse, and intimate partner violence (IPV), is a pattern of behavior which involves the abuse by one partner against another in an intimate relationship such as marriage, cohabitation, dating or within the familyâ⬠(NA, April 21, 2014, In WikipediaRead MoreGender Based Violence4083 Words à |à 17 PagesIN THE MINISTRY OF WOMEN, YOU RECEIVE A REPORT THAT THE LEVEL OF GENDER BASED VIOLENCE IN CHIEF MUNYUMWBEââ¬â¢S AREA HAS GONE UP. DESCRIBE THE SEQUENTIAL PLATFORM OF ACTIONS THAT YOU CAN MAKE TO ADRESS THIS ISSUE. Gender inequality is both a cause and effect of gender based violence, yet gender based violence is in part responsible for its continuation. This is because a person who has been abused is likely to feel subordinate to the abuser hence increasing the gender gap (inequality). Therefore, thisRead MoreTheology of the Body32011 Words à |à 129 Pagesof the sections. This will help those who want to become familiar with the main ideas of the theology of the body to do so rather quickly ââ¬â in 30 pages rather than 400 ââ¬â as well as assist those who are already students of the theology of the body to have them presented in an annotated outline form to facilitate their passing on this Gospel of Human Love in the Divine Plan to others. Eventually, I hope to do a commentary to accompany the various sections, but that will come later! I. The original unityRead MoreIssues in Divorce Essay2330 Words à |à 10 Pagesvery different. Divorce rates have continued to climb through the centuries as religion has had less of a pull on peopleââ¬â¢s lives. More and more couples have entered into marriages that simply could not last for the long-term. This can be due to many different factors, including more relaxed divorce laws, women having more of a say in family matters than they did in the past, and changes in societyââ¬â¢s acceptance of divorces. More important than why divorces have been increasing is the impact it
Wednesday, May 13, 2020
Literary Analysis Of The Cask Of Amontillado - 1231 Words
Kaitlin Hunter Mrs. Laszik ENGL 1302.001 27 Oct 2017 The Cask of Amontillado One of the most memorable short stories by the American writer, mainly known for his gothic literature ââ¬Å"The Cask of Amontilladoâ⬠, written by Edgar Allan Poe is short story about revenge against an ââ¬Å"old friendâ⬠who betrayed another. This strong expression of gothic literature through the drastic change of settings and surroundings. Also, the main characterââ¬â¢s, Montressor, narration of the story that he has kept to himself for half a century only adds to the sinister, dark night that leads the two men into the cold, wet catacombs for only one to return. Although it is never revealed to the reader who Montressor is telling his darkest secret for all of these yearsâ⬠¦show more contentâ⬠¦Its walls had been lined with human remains, piled to the vault overhead, in the fashion of the great catacombs of Paris. Three sides of this interior crypt were still ornamented in this manner. (Poe 119) The reader is shown how Poe intended you to feel as if you were in the catacombs as well through this gothic literature. While Poe made the setting a critical factor in this story, he also provided the readers the main characterââ¬â¢s point of view. In addition to Montressor being the central character in ââ¬Å"The Cask of Amontilladoâ⬠and with that he provides his point of view with the way he describes his unrelenting drive to get his revenge against Fortunato. The author decides to make the narrator as Montressor to show this story in first person to get his perspective, thoughts, and actions through his eyes for the night ahead. In the beginning of this story, Montressor is giving his thoughts toward Fortunato to show the many expressions he delivers to make this story complete: It must be understood that neither by word nor deed had I given Fortunato cause to doubt my good will. I continued, as was my wont, to smile in his face, and he did not perceive that my smile now was at the thought of his immolationâ⬠(Poe 116). This perspective makes the reader consider how different this story would be if it were written in Fortunatoââ¬â¢s point of view. Would we know what he did to dishonorShow MoreRelatedLiterary Analysis Of The Cask Of Amontillado 1493 Words à |à 6 PagesBrooke Womack Literary Analysis Paper Into to Literature: American I Dr. Julia Pond 12 October 2017 The Cask of Amontillado The Cask of Amontillado is a tale of terror written by Edgar Allen Poe. This short story is from the point of view from Montresorââ¬â¢s memory. The setting of this story is in a small unnamed European city, at a local carnival and then at the catacombs under Montresorââ¬â¢s home, around duck. The brief synopsis of this story is about the revenge that the Montresor, the antagonistRead MoreLiterary Analysis Of Cask Of Amontillado1219 Words à |à 5 PagesEdgar Allan Poe is a well-known writer in writing detective stories and fear stories. One of his fear stories, ââ¬Å"The Cask of Amontilladoâ⬠was talking about how a man took his payback to his friend. However, to look intensely in this story, I found that this story was not just simply a fear story about how a man gets his revenge in the harmless way. Instead, it also demonstrates much irony in several areas: the title, the event, the season, the costume, the environment, the charactersââ¬â¢ personalitiesRead MoreLit erary Analysis - Cask of Amontillado Essay examples680 Words à |à 3 PagesIn The Cask of Amontillado Edgar Allan Poe takes us on a journey into the mind of what many would perceive as a mad man. The story tells of what seems to be a horrible revenge made even more horrible by the fact that the vengeance is being taken when no real offense had been known. This notion sets the mood for true evil. The plot of the story is simple. Montresor takes revenge on his friend Fortunato by luring him into the wine cellar under the family estate. There he leads Fortunato into theRead MoreRole of Realism in Edagar Allan Poeà ´s The Tell Tale Heart and The Cask of Amortillado1014 Words à |à 5 Pagesââ¬Å"The Cask of Amontilladoâ⬠written by Edgar Allan Poe are dark short stories relevant to murder, revenge, and mystery. Poe writes both stories in a Gothic style in order to deal with ideas of realism. One may ask were the murders and punishments justifiable in either short story? One ma y also ask did Poe accurately depict realism in each story? Realism, defined as a technique in literature that accurately represents everyday life, is questioned in Poeââ¬â¢s works: ââ¬Å"The Tell Tale Heartâ⬠and ââ¬Å"The Cask ofRead MoreEdgar Allan Poe s The Cask Of Amontillado1232 Words à |à 5 Pagesabout the text ââ¬Å"The Cask of Amontilladoâ⬠by Edgar Allan Poe, some sources will be used to support the thesis statement, which is ââ¬Å"The author uses irony in the text to illustrate the murder of Fortunado by Montresor, who seeks salvation through deathâ⬠. Also, there is going to be an analysis on the irony found in the text in relation with the story. To support this thesis, I am going to use some examples from some sources such as ââ¬Å"Literary analysis: Irony in The Cask of Amontillado by Amelia TibbettRead MoreThe Cask of Amontillado and Hills Like White Elephants577 Words à |à 3 PagesAnalysis of ââ¬Å"The Cask of Amontilladoâ⬠by Edgar Allan Poe amp; ââ¬Å"Hills Like White Elephantsâ⬠by Ernest Hemmingway Analysis of ââ¬Å"The Cask of Amontilladoâ⬠by Edgar Allan Poe Abstract ââ¬Å"The Cask of Amontilladoâ⬠by Edgar Allan Poe, is a short story about a man named Montessor who gets revenge on one of his ââ¬Å"friendsâ⬠named Fortunado by trapping him and burying him alive. Treatment Setting: Two kinds Plot: Man gets revenge on his ââ¬Å"friendâ⬠Characters: Montresor, Fortunado, Montresorââ¬â¢s familyRead MoreThe Cask Of Amontillado By Edgar Allan Poe1575 Words à |à 7 PagesIs there anything that someone could do to you that would cause you to commit murder? Could you get away with it? Montresor is the murderous narrator who has committed the perfect murder in just such a tale, ââ¬Å"The Cask of Amontillado.â⬠Montresor plots and kills an unwary friend/foe during carnival time for motives that are unclear. The author of this tale, Edgar Allan Poe, influenced by his somewhat tragic life and one of the most influential Gothic writers, uses symbolism and irony to show the multitudeRead MoreLiterary Analysis Of The Cask Of Cask Essay981 Words à |à 4 PagesLiterary Analysis on the Cask of Amontillado In the Cask of Amontilado, Poe uses pride as a theme to explain the reasons for murder. Pride will push a person to the extremes and that has been proven many times throughout history and even now. Pride just recently made a man kill a teenager. They were in a fight and because the teen won the fight others laughed at the man and made fun of him, he shot the teen in the chest and he died. An example of pride driving one to murder is depicted in the CaskRead MoreFor the Love of God, Poe! Essay1359 Words à |à 6 Pages-- ââ¬Å"The Cask of Amontilladoâ⬠. This story recounts how a man called Montresor seeks revenge upon a ââ¬Å"friendâ⬠who allegedly insulted him. In ââ¬Å"The Cask of Amontilladoâ⬠, the brilliant use of situational irony and macabre humor creates significant parallels between the plot and the authorââ¬â¢s own strange life. From the very first sentence, ââ¬Å"The Cask of Amontilladoâ⬠is absolutely saturated with both verbal and dramatic irony. In fact, even the title has an element of irony to it -- the word ââ¬Å"caskâ⬠(whichRead MoreThe Cask Of Amontillado By Edgar Allan Poe1463 Words à |à 6 Pagessince Edgar Allan Poe described the death of a gullible fool, yet the taste of a murdererââ¬â¢s Amontillado wine remains bittersweet. Although the work is fictional, ââ¬Å"The Cask of Amontilladoâ⬠provides a nefarious and dismal libretto, depicted as a tale of pride, revenge, and a murder in cold blood. Through the use of symbolism, theological allusion, and foreshadowing, Edgar Allan Poeââ¬â¢s ââ¬Å"The Cask of Amontilladoâ⬠suggests taking pride in seeking revenge on enemies is addictive and intoxicating. Edgar
Wednesday, May 6, 2020
Electrical Circuit Free Essays
Electrical circuità is a path whichà electronsà from aà voltageà orà currentà source flow. Electric currentà flows in a closed path called an electric circuit. The point where those electrons enter an electrical circuit is called the ââ¬Å"sourceâ⬠of electrons. We will write a custom essay sample on Electrical Circuit or any similar topic only for you Order Now The point where the electrons leave an electrical circuit is called the ââ¬Å"returnâ⬠or ââ¬Å"earth groundâ⬠. The exit point is called the ââ¬Å"returnâ⬠because electrons always end up at the source when they complete the path of an electrical circuit. The part of an electrical circuit that is between the electronsââ¬â¢ starting point and the point where they return to the source is called an electrical circuitââ¬â¢s ââ¬Å"loadâ⬠. ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â- Electrical-circuits Electrical circuits usually useà alternating currentà sources. The load of an electrical circuit may be as simple as the electrical appliances like refrigerators, televisions, or microwave ovens. But the loads for electrical circuits can also be quite complicated, such as the load upon the output of a hydroelectric power generating station. ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â Electronic circuits Electronicà circuits usually use low voltageà direct currentà sources. The load of an electronic circuit may be as simple as a fewà resistors,capacito rs, and a lamp, all connected together to create the flash in aà digital camera. Or an electronic circuit can be complicated, connecting thousands of resistors, capacitors, andà transistorsà to create theà microprocessorsà that make computers possible. ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â- Circuit-and-wiring-diagrams Electrical and electronic circuits can be complicated. Making a drawing of the connections to all the component parts in the circuitââ¬â¢s load makes it easier to understand how circuit components are connected. Drawings for electronic circuits are called ââ¬Å"circuit diagramsâ⬠. Drawings for electrical circuits are called ââ¬Å"wiring diagramsâ⬠. Circuit diagrams and wiring diagrams are usually drawn by skilleddraftsmen, and then printed. But they can also be simple pencil sketches drawn byà techniciansà or other workers. Wiring and circuit diagrams use specialà symbolsà recognized by everyone who uses the drawings. The symbols on the drawings show how components like resistors, capacitors,à inductors, motors, outlet boxes, lights, switches, and other electrical and electronic ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â- Circuit-breakers The current flowing in an electrical or electronic circuit can be suddenly increased when a component part fails. The increase in current can cause serious damage to other components in the circuit. Or the failure can create a fire hazard. To protect the other components, or to prevent a fire hazard, a device called a ââ¬Å"circuit breakerâ⬠can be wired into a circuit. The circuit breaker will open, or ââ¬Å"breakâ⬠, the circuit in which it is installed when the current in that circuit becomes too high. ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â- [change]Ground-fault-interrupt-(GFI)-devices The standard return for electrical and electronic circuits is the earth ground. When an improperly designed electrical or electronic device fails, it may open the return circuit to the earth ground. The user of the device could become a part of the deviceââ¬â¢s electrical circuit by providing a return path for the electrons through the userââ¬â¢s body instead of the circuitââ¬â¢s earth ground. When the userââ¬â¢s body becomes part of an electrical circuit, the user can be seriouslyà shocked, or even killed byà electrocution. To prevent the danger of electrical shock and the possibility of electrocution, ground fault interrupt devices detect open circuits to earth ground in attached electrical or electronic devices. When an open circuit to earth ground is detected, the GFI device immediately opens the voltage source to the device. GFI devices are similar to circuit breakers, but are designed to protect humans rather than circuit components. How to cite Electrical Circuit, Essay examples
Monday, May 4, 2020
Case Study - Corporate Veil Of A Company - Liabilities On Shareholders
Question: Discuss about the Corporate Veil. Answer: The company is a separate legal entity; it has the right to sue another person, and the liability to be sued by another person. According to the provisions of law, a person cannot be held liable for the liabilities of another unless he has expressly or impliedly assumed responsibility, indemnified or guaranteed the other person[1]. In the same way, the directors and other shareholder of the company cannot be accounted for the rights and liabilities of the company, as it is a separate legal person. The corporate veil can be lifted by the court if the company had been formed with the intention of fraud. If the court is satisfied that fraud was the main reason for the creation of the company than in the ends of justice, it can pierce the corporate veil. The concept of corporate veil can be traced since 1612, in the case of Suttons hospital (1612)[2]. In the facts before the court was to determine whether or not the corporate veil can be lifted. In this case, the court provided that the incorporation of the company was valid and the corporate veil cannot be lifted[3]. One of the most significant about case with relation to the lifting of corporate veil is the case of Solomon v Solomon Co ltd 1986. In this case the defendant had solely owned the shares of a company incorporated by him. The defendant was also the debenture holder of the company. The company suffered losses and was ultimately wound up. The defendant as the debenture holder of the company claimed his debenture amount through the companys assets at the time of the winding up. There were very little assets left after the denture was claimed for the payment of other creditors who were the plaintiff. The court in this case dismissed the claim made by the plaintiff highlighting the concept of corporate veil between the owner and the company. The concept of piercing the corporate veil in the united kingdom had been highlighted in united kingdom through various cases such as Macaura v Northern Assurance Co Ltd 1925[4] and Solomon v Solomon Co ltd 1896[5] , where the court decided not to life the corporate veil in ends of justice. In the cases of Gilford Mortar Co Ltd v Horne and Tunstall v Steigmann 1962[6] the court lifted the corporate veil as the company for formed for a fraudulent purpose.[7] Dignam and Lowry have stated that the decisions made by the judges with respect to the cases involving the lifting of corporate veil is not clear and confusing and the judges hide such confusion behind apparent clarity. In the United Kingdom, the lifting of corporate veil is a very rarely used phenomenon. The doctrine of control for piercing the corporate veil and economic reality theory was tried to be established by the court of appeal in the early 1970s for the purpose of lifting the corporate veil. However, the House of Lords reasserted the orthodox approach to this concept. In the landmark case of Adam v cape Industries plc, the court provided that the corporate veil of the corporation can only be pierced by the court when the purpose of the formation of the corporation was fraudulent and had been established in order to evade an existing obligation. There are still various significant statements that are made by the judiciary to support the lifting of corporate veil in a broade r aspect with respect to the ends of justice. This concept provided by the judiciary is discussed in details in the landmark case Prest v. Petrodel Resources Ltd 2013[8]. This case discusses the concept of resulting trusts, piercing of corporate veil and equitable proprietary remedies with respect to English Family Law[9]. In this case, Ms Yasim Prest had made a claim under the provisions of section 23 and 24 of the Matrimonial Causes Act 1973 for an ancillary relief against a company that was totally owned by her husband Mr. Michale Prest. According to the claimant, the husband had legal title with respect to the properties beneficially owned by him, which included a house worth 4million. She also claimed that her husband did not abide by the provisions of making a total and correct disclosure with respect to his financial position. According to the provisions section 24 of the Matrimonial Causes Act 1973, the court has the power to make an order for the transfer of property, if the person against whom the claim is made, holds the legal title of the property. It was provided by the defendant that he did not hold the title of the properties which were claimed by the plaintiff.[10] The high court in this case held that, as the defendant had the powers to transfer the property in practice, it is assumed that he holds the legal title of the property in context with respect to section 24 of the Matrimonial Causes Act 1973. It was held by the high court in this case that control and ownership themselves were not enough for the purpose of piercing the corporate veil. The court also provided that in case where there is no existence of a third party interest, the corporate veil cannot be pierced even for the purpose of serving the ends of justice. The court provided that only when there is a case of impropriety can the corporate veil is pierced. Such impropriety must have been related to misuse of the corporate veil for the purpose of avoiding an existing liability. In order to pierce the corporate veil the control of the person who has done a wrongful act is also needed along with the concept of impropriety[11]. The high court in this case justified the pairing of the corporate veil; however, such justification was not based on the general principals but on the provisions of the Matrimonial Causes Act 1973. In the same case, when an appeal was made to the court of appeal, the court provided that the decision made by the high court about distribution of the assets owned by a company according to the provisions of Matrimonial Causes Act 1973, was out of the jurisdiction of the court, unless the court had abused the corporate veil of the company[12]. The court of appeal provided that the decision of the high court was incorrect as for the purpose of piercing the corporate veil the company had to be formed based on a fraudulent purposes and it must have been shown by the court that the properties held by the company were on trust of the defendant. The decision made by the judges of the high court was not consistent with the decisions in major cases like Salomon v Salomon Co Ltd, Woolfson v Strathclyde Regional Council and Adams v Cape industries plc. In this case Justice Patten, further provided that this system of family courts with respect to the adoption and development of new approaches towards the assets owned by companies in ancillary relief enforcement is a different system of laws, which has no relevance for the existing laws. These approaches by the lower courts have to be stopped with immediate effect. There was again a difference of opinion in the same case between the two LJs of the court of appeal. Dissenting to concept provided by Patten LJ, Thorpe LJ provided a different concept with respect to the case[13]. He said that the reality in this case was very simple. The defendants used the company to provide for the extravagant lifestyle of himself and his family. This could only have happed if the company was in total control of the defendant and was not liable for any interest with respect to the third parties. As there was a complete control of the defendant over the company, he must have ignored the provisions of the company law towards the operations of the company. After the marriage had come to an end the defendant used the corporate veil as a defense to deprive his wife of her rights. If the present provisions of laws in this respect allows him to escape with such an act it would end the make the effort of the family court to achieve a fair result irrelevant[14]. The confusing in the approach of lifting the corporate veil by the courts can clearly be identified by the difference in these opinions. Further, the Supreme Court had overturned the decision of the court of appeal with respect to this case. The Supreme Court held that as the defendant has contributed personally to the purchase price of the property in context, he had a beneficial interest in the property. The court further provided that in this case there was no necessity of lifting the corporate veil, as this concept is applicable in a very limited situations. The court provided that as the defendant had the title with respect to the assets of the companies with respect to a resulting trust so the transfer of rights under section 24 of Matrimonial Causes Act 1973 was valid[15]. The first judgment in this case as given by lord Sumption, he provided that the corporate veil could be pierced in very rare circumstances, when the company had been formed with the fraudulent motive of escaping an existing obligation[16]. The lifting of corporate veil can only be used to dispossess the controllers of the company of the powers, which they have obtained through the concept of corporate veil. In this case, it cannot be proved that the defendant had created the company to escape the obligation arising out of the divorce, thus corporate veil cannot be lifted. He also provided that the high court had no powers to order the transfer of property under section 24 of the Matrimonial Causes Act 1973. Such powers could only arise if the defendant held beneficial interest in the property, the evidence of which in this case of obscure because of mendacity and obstruction of the defendant[17]. The justice in this respect said that there are ways in which, remedies can be provided without lifting the concept of the corporate veil of the companies. he provided examples that an person who is the controller of the company can be held liable as he is the agent of the company, or properties belonging to the companies can be transferred as the controller holds beneficial interest in the property. He provided that there can be many remedies like injunctions, specific performances, provisions of the company act and competition law which been be given without lifting the corporate veil of a company[18]. He added that when the concept of lifting the corporate veil is being talked about, these rules could not be related to it, only in cases, which are truly exempted from the rule of the case Salomon v Salomon co ltd can be related to the doctrine of piercing the corporate veil[19]. Lord Neuberg in this case provided that lifting of the corporate veil should only be done as a last resort. Lord Wilson in this regard gave another view, he provided that the piercing of corporate veil in all cases cannot be classified into cases of evasion or concealment. Lord Mance gave a view that the future situations in which the veil might have to be lifted should not be foreclosed. Concurring to this judgment, lord Clarke provided that corporate veil should only be lifted when there is no other option left. Lord walker in this case gave the view that lifting the corporate veil of a corporation is not at all a doctrine it is only a label. [20] It can be concluded with the decisions of all the judges in this case that, the concept of piercing the corporate veil was unclear and confusing; this concept was not helpful for most of the judges. When it comes to piercing the corporate veil, the judges are always engaged in the process of finding the appropriate principles to adequately address and govern this concept. The judges in order to make their decisions with respect to lifting or piercing the corporate veil rely on several factors such as sham or fraud, agency, determination of nationality, tax evasions and single economic entity[21]. The landmark case of Adams V cape Industries 1991[22] the argument based on a single economic entity was rejected by the court. In this case, the court denied to disregard the legal form to glance at the economic substances. In the recent case of Hashem v. Shayif, it was held by justice Munby after considering many cases with respect to the lifting of corporate veil that, in order to pierce the corporate veil of a company the defendant should have total control over the company and there should be a presence of some kind of impropriety. [23] Although the argument of a single economic unit was rejected in the case of Adams V cape Industries, the case provided for an argument based on the rule of agency. The court in this case provided that agency not only mean a contractual relationship, but an agency arising out of facts. On the other hand, in the case of Hashem v. Shayif it can be concluded that justice Munby did not consider agency as an argument as he insisted on the term of impropriety[24]. In many instances the judges have also based their decisions on the concept of interest of justice whereas, justice Munby had rejected this approach. He provided that after analyzing several cases he found two factors to be present in each case, one was control and the other was impropriety, and the only case in which the court can lift the corporate veil is when there is existence of a faade. The arguments based on agency are not enough to lift the corporate veil because of the presence of impropriety[25]. The courts in most of the cases are unclear, when the phrase lifting the corporate veil is used by them. Prof. S. Ottolenghi in a seminal article in Modern Law Review (May 1990) divided judicial proceedings with respect to corporate veil into four types[26]: Peeping: This concept is used by the court only to determine the control of the defendant over the company. Penetrating: In this case, penetration is done in the corporate veil of a company to tie up liabilities on shareholders for the actions of the company or for giving the shareholders a direct interest with respect to the companys assets. This concept does not mean to provide that the company does not exist. It only provides that the shareholders are being directly looked at by the court because of the existence of certain factors. Extending: This approach is adopted by the courts in both factual agency and single economic unit arguments. This process involves piercing the corporate veil of one company and again reinforcing it to bring another company into the same veil. Ignoring: This concept involves eliminating the corporate veil of a company as a sham or a faade. After going through the decision of various cases, with respect the lifting of corporate veil it can be concluded that, there is an immense uncertainty in this aspect to law. The judges themselves are confused about the use of the doctrine of piercing the corporate veil. All cases provided with a different approach for this purpose and their no certainly and consistency at all between them. The courts, in spite of so many decisions, have not been able to identify a single, simple and clear approach in this field. Courts are making this doctrine more and more complicated by adopting a different approach to it in different cases. References: BOOKS Becker, Riaan. "Disregarding the separate juristic personality of a company: an English case law comparison." (2015). Chen, Chen.Piercing the Corporate Veil. Erasmus Universiteit, 2014. Lam, Chun Leung. "Piercing the Corporate Veil." (2015). Nelson, Josephine Sandler. "Frustration with the Intracorporate Conspiracy Doctrine Distorts Other Areas of Law."Available at SSRN 2581242(2015). Sharman, Jason Campbell. "Shell Companies and Asset Recovery: Piercing the Corporate Veil." (2014). JOURNAL ARTICLES Anderson, Helen. "Challenging the Limited Liability of Parent Companies: A Reform Agenda for Piercing the Corporate Veil."Australian Accounting Review22.2 (2012): 129-141. Booth, Richard A. "Close Encounters with Piercing the Corporate Veil."Vill. L. Rev.61 (2016): 393. Booth, Richard A. "Close Encounters with Piercing the Corporate Veil."Vill. L. Rev.61 (2016): 393. Butusina, Lorena. "Piercing the corporate veil."Revista Romana de Drept al Afacerilor8 (2013): 83. Farrar, John H. "Doctrinal incoherence and complex variables in piercing the corporate veil cases."Australian Journal of Corporate Law29 (2014): 23-37. Grantham, Ross. "Corporate Veil: An Ingenious Device, The."U. Queensland LJ32 (2013): 311. Hare, Christopher. "Family Division, 0; Chancery Division, 1: Piercing the Corporate Veil in the Supreme Court (Again)."The Cambridge Law Journal72.03 (2013): 511-515. Ho, May Kim. "Piercing the corporate veil as a last resort: Prest v Petrodel Resources Ltd [2013] UKSC 34;[2013] 2 AC 415;[2013] 3 WLR 1."Singapore Academy of Law Journal26.1 (2014): 249. Khimji, Mohamed F., and Christopher C. Nicholls. "Piercing the Corporate Veil Reframed as Evasion and Concealment."UBCL Rev.48 (2015): 401. Kim, Ho May. "Piercing the Corporate Veil as a Last Resort; Prest v Petrodel Resources Ltd."SAcLJ26 (2014): 249. Macey, Jonathan, and Joshua Mitts. "Finding order in the morass: The three real justifications for piercing the corporate veil."Cornell L. Rev.100 (2014): 99. Okoli, Chukwuma. "English courts address the potential convergence between the doctrines of piercing the corporate veil, party autonomy in jurisdiction agreements and privity of contract."Journal of Business Law(2014). Small, Rashied, Lucinda Smidt, and Achmad Joseph. "Piercing the corporate veil-separation of the business from the business owner: industry insights."Professional Accountant26 (2015): 24-25. Thompson, Sharon. "Behind the veil: Company or family property on divorce?."Journal of Social Welfare and Family Law36.2 (2014): 217-219. Tsang, King Fung. "The Elephant in the Room: An Empirical Study of Piercing the Corporate Veil in the Jurisdictional Context."Hastings Bus. LJ12 (2015): 185. CASE LAWS Adams V cape Industries [1991] 1 ALL ER 929 Macaura v Northern Assurance Co Ltd [1925] AC 619 Prest v. Petrodel Resources Ltd [2013] UKSC 34 Solomon v Solomon Co ltd [1896] UKHL 1 Suttons hospital (1612) 77 Eng Rep 960. Tunstall v Steigmann [1962] 2 QB 593 [1] Lam, Chun Leung. "Piercing the Corporate Veil." (2015). [2] Suttons hospital (1612) 77 Eng Rep 960. [3] Small, Rashied, Lucinda Smidt, and Achmad Joseph. "Piercing the corporate veil-separation of the business from the business owner: industry insights."Professional Accountant26 (2015): 24-25. [4] Macaura v Northern Assurance Co Ltd [1925] AC 619 [5] Solomon v Solomon Co ltd [1896] UKHL 1 [6] Tunstall v Steigmann [1962] 2 QB 593 [7] Macey, Jonathan, and Joshua Mitts. "Finding order in the morass: The three real justifications for piercing the corporate veil."Cornell L. Rev.100 (2014): 99. [8] Prest v. Petrodel Resources Ltd [2013] UKSC 34 [9] Ho, May Kim. "Piercing the corporate veil as a last resort: Prest v Petrodel Resources Ltd [2013] UKSC 34;[2013] 2 AC 415;[2013] 3 WLR 1."Singapore Academy of Law Journal26.1 (2014): 249. [10] Thompson, Sharon. "Behind the veil: Company or family property on divorce?."Journal of Social Welfare and Family Law36.2 (2014): 217-219. [11] Booth, Richard A. "Close Encounters with Piercing the Corporate Veil."Vill. L. Rev.61 (2016): 393. [12] Okoli, Chukwuma. "English courts address the potential convergence between the doctrines of piercing the corporate veil, party autonomy in jurisdiction agreements and privity of contract."Journal of Business Law(2014). [13] Kim, Ho May. "Piercing the Corporate Veil as a Last Resort; Prest v Petrodel Resources Ltd."SAcLJ26 (2014): 249. [14] Grantham, Ross. "Corporate Veil: An Ingenious Device, The."U. Queensland LJ32 (2013): 311. [15] Becker, Riaan. "Disregarding the separate juristic personality of a company: an English case law comparison." (2015). [16] Anderson, Helen. "Challenging the Limited Liability of Parent Companies: A Reform Agenda for Piercing the Corporate Veil."Australian Accounting Review22.2 (2012): 129-141. [17] Farrar, John H. "Doctrinal incoherence and complex variables in piercing the corporate veil cases."Australian Journal of Corporate Law29 (2014): 23-37. [18] Hare, Christopher. "Family Division, 0; Chancery Division, 1: Piercing the Corporate Veil in the Supreme Court (Again)."The Cambridge Law Journal72.03 (2013): 511-515. [19] Nelson, Josephine Sandler. "Frustration with the Intracorporate Conspiracy Doctrine Distorts Other Areas of Law."Available at SSRN 2581242(2015). [20] Butusina, Lorena. "Piercing the corporate veil."Revista Romana de Drept al Afacerilor8 (2013): 83. [21] Khimji, Mohamed F., and Christopher C. Nicholls. "Piercing the Corporate Veil Reframed as Evasion and Concealment."UBCL Rev.48 (2015): 401. [22] Adams V cape Industries [1991] 1 ALL ER 929 [23] Chen, Chen.Piercing the Corporate Veil. Erasmus Universiteit, 2014. [24] Lewis, Andrew. "Piercing the corporate veil has been extended: from the courts."Tax Breaks Newsletter327 (2013): 2-3. [25] Tsang, King Fung. "The Elephant in the Room: An Empirical Study of Piercing the Corporate Veil in the Jurisdictional Context."Hastings Bus. LJ12 (2015): 185. [26] Sharman, Jason Campbell. "Shell Companies and Asset Recovery: Piercing the Corporate Veil." (2014).
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