N
ny,
Guest
You can thank the P/C queen Lea Soupata for that.
p.s. She was a terrible District Mgr-how did she get promoted to the VP of HR?
p.s. She was a terrible District Mgr-how did she get promoted to the VP of HR?
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G
gman
Guest
IMO, Appointment was/is a token gesture at breaking of glass ceiling at the BOD level.
B
buyorsellopl
Guest
used2bie,
What do you think. Would it be worth the gamble to gain 38% if the company went public &/or was bought out?!?
What do you think. Would it be worth the gamble to gain 38% if the company went public &/or was bought out?!?
A
anonymous
Guest
The odds of this guy getting fired are zero and this steward knows it. This is a more common problem than people are willing to admit. Firing someone because they are lazy and/or incompetent doesn't happen because all of a sudden grievances are filed and all sorts of alleged rights are assumed violated. The union also serves as the arbiter in these types of issues at the ground level and guess who usually wins.
U
used2bie
Guest
buyorsellopl,
As others have pointed out, Price-to-book is not the only way to measure the value of an insurance company. This may be especially true for OPL, which owns --in addition to the future value of its ongoing businesses-- a very nice real estate portfolio and an investment portfolio of some $2.5 billion +. I am buying more, and my reasoning is that the Board of Directors is populated with some of the same people who added so much wealth to my UPS shares. I know these guys, I am comfortable with them, and I am certain that they will act in the best interests of all shareholders over the long term.
As others have pointed out, Price-to-book is not the only way to measure the value of an insurance company. This may be especially true for OPL, which owns --in addition to the future value of its ongoing businesses-- a very nice real estate portfolio and an investment portfolio of some $2.5 billion +. I am buying more, and my reasoning is that the Board of Directors is populated with some of the same people who added so much wealth to my UPS shares. I know these guys, I am comfortable with them, and I am certain that they will act in the best interests of all shareholders over the long term.
B
buyorsellopl
Guest
usedtobeie,
My sentiments exactly. I really do believe that opl will be bought or will go public on the simple fact opl shares were offered for sale, just like ups shares were made possible to hourly people. By doing this a few years ago, ups was taking a way the complaint that only managment was able to take advantage of the win fall, giving everyone the smae opportunity to buy and if you didn't take advantage of the shares when they were offered to you.......sucks to be you!! From what First Union told me last weem, it looks like a few more weeks before anyone can buy opl, still waiting for SEC approval.
My sentiments exactly. I really do believe that opl will be bought or will go public on the simple fact opl shares were offered for sale, just like ups shares were made possible to hourly people. By doing this a few years ago, ups was taking a way the complaint that only managment was able to take advantage of the win fall, giving everyone the smae opportunity to buy and if you didn't take advantage of the shares when they were offered to you.......sucks to be you!! From what First Union told me last weem, it looks like a few more weeks before anyone can buy opl, still waiting for SEC approval.
K
kingsorter
Guest
Anonymous,
I will agree with you there is probably zero chance of firing this guy. BUT......soner or later this guy will make a mistake doing something else and then..WHAMO..no breaks because he is a slug. I have seen it time and time again. A poor employee rairly gets fired for the REAL reason the get fired but get caught on something else or a technicality. My feelings are this....there are too many things we have to do right and eventually, somewhere, sometime you will go down, if you deserve to. Yes, it might take a long time, maybe even ten years, but what would be worse....getting rid of someone within the first few years they are with the company or long after they are use to the money and benefits they are receiving. I also am a firm believer in this statment....Good things happen to good people and bad things happen to bad people.
I will agree with you there is probably zero chance of firing this guy. BUT......soner or later this guy will make a mistake doing something else and then..WHAMO..no breaks because he is a slug. I have seen it time and time again. A poor employee rairly gets fired for the REAL reason the get fired but get caught on something else or a technicality. My feelings are this....there are too many things we have to do right and eventually, somewhere, sometime you will go down, if you deserve to. Yes, it might take a long time, maybe even ten years, but what would be worse....getting rid of someone within the first few years they are with the company or long after they are use to the money and benefits they are receiving. I also am a firm believer in this statment....Good things happen to good people and bad things happen to bad people.
A
anonymous
Guest
I think these types of people should be removed ASAP because they are a cancer in the workplace. These are the types of people who milk the system to their advantage. They serve no purpose in the workplace.
K
kingsorter
Guest
Anonymous,
I agree 100 percent. My other favorite saying is waht goes around, comes around. And I 'm sure some day people like this idiot will get shoved right up his.....
I agree 100 percent. My other favorite saying is waht goes around, comes around. And I 'm sure some day people like this idiot will get shoved right up his.....
S
seahorse1
Guest
We all have to believe that OPL is the "next" hot property. There's just too much coincidence in the lack of recall for Y2K and the opening of 10K share purchases between now (soon) and November this year. I suspect a lot of the Tender Offer will roll into OPL ( I'm pretty sure mine will).
Happy Trails
Happy Trails
H
hubrat
Guest
There is an article in the contract that allows the company to terminate a steward if he/she is part of a "work slowdown or work stoppage." The primeunload guy does need to go to the manager to solve this problem. We terminated a steward this week in the Hub for telling unloaders to "slow down." The unloaders even made write-ups. We need people who want to be part of the team. We do not need any liabilities.
A
anonymous
Guest
This is certainly great news. However, I know where I work these nonproducers are catered to. Their workloads are actually reduced and to top it off, it is the productive workers who pick up their slack. The only sure way out the door where I work is to steal something. Other than that, the bulk of people I have seen who were terminated were reinstated to their jobs. This is something I would like to see changed where I work.
F
frank
Guest
I agree with you Seahorse. We're buying more on the theory that the BOD is allowing purchases just before OPL's big move.
B
buyorsellopl
Guest
Does anybody know if opl will raise it's price per share at both board meetings (Feb & Aug) or will they stick to the annual move like in the past. Word on the street is they will raise it significantly in Feb and then again in Aug.
S
seahorse1
Guest
Hope you're correct about the OPL "twice as nice price" in Feb. and Aug. All I know for sure is that the 3rd qtr. report mentioned that the board would re-determine the share price at the 1st and 3rd qtr. meetings commencing with Feb. 2000.
S
seahorse1
Guest
OPL earnings for 1999 are due out at the end of February. Just friend.Y.I.
C
confused
Guest
Is there any way to buy before the price goes up? I was told no purchases before March.
S
seahorse1
Guest
I don't think we can buy until all the SEC "stuff" is done. I have been e-mailing OPL asking questions and that's the response I get. I am hoping that the Tender Offer is completed soon so I can sell-pay the IRS their share-and turn the rest into OPL. I just have a gut feeling that OPL is on the move (although it ain't done bad from the 25 cents it cost me...way back when).
Z
zippo
Guest
Tax court holds UPS shifted income offshore in sham tansaction
The Tax Adviser (New York) Vol. 31 Issue 1 Jan 2000
--------------------------------------------------------------------------------
United Parcel Service ofAmerica, Inc. (UPS), TC Memo 1999-268, the Tax Court held that UPS improperly shifted $70 million of income offshore to a related Bermuda corporation, Overseas Partners Limited (OPL). Citing Basye, 410 US 441 (1973) and Lucas v. Earl, 281 US 111 (1930), the court found that UPS itself was the true earner of the income under Sec. 61 and had improperly attempted to assign that income to OPL. According to the court, the transactional arrangements that would have allowed OPL to earn the income offshore, free of US. corporate income tax, lacked a legitimate, nontax business purpose. Therefore, under the sham transaction doctrine, OPUs participation in the arrangement should be ignored and the income should be taxed to UPS. In arriving at this conclusion, the court disregarded substantial testimony offered by UPS executives and relied instead on contemporaneous documentation as to the intent and purpose of the transactional arrangements. The court imposed penalties exceeding $15 million under Secs. 6653 (negligence), 6661 (substantial understatement of income) and 6621 (substantial understatements attributable to "tax motivated transactions"). UPS is engaged in the pick-up and delivery of small packages and parcels within the US. and in certain countries abroad. At all times, UPS's activities were regulated by the Interstate Commerce Commission (ICC), state transportation agencies, public utility commissions and the Civil Aeronautics Board. In connection with regulatory requirements, UPS's pricing structure was set forth in detailed tariffs filed with the ICC and most states' state transportation agencies. This pricing structure established certain "base rates," depending on the package size and delivery location. The base rate automatically provided the customer (the shipper) with coverage against loss or damage to its package up to $100. If a shipper desired to obtain additional coverage, it would declare the value of the package and pay an additional 25 cents ($0.25) of "Excess Value Charges" (EVCs) per additional hundred dollars of value declared. For all of its tax years through 1983, UPS collected the EVCs and included them in its gross income. In 1983, however, UPS was approached by an insurance brokerage firm with a plan to restructure the EVC aspect of UPS's shipping business. Because the EVCs provided shippers with coverage against loss or damage to their packages, the excess value business had significant attributes resembling insurance. Under the plan, UPS would collect the EVCs on behalf of shippers as "insurance premiums" payable to an unrelated insurer (NUF), which, in turn, would pay "reinsurance premiums" to OPL. UPS had recently created OPL and declared a dividend payable to UPS shareholders equal to one share of OPL stock for each share of UPS stock held. Under the arrangement, UPS required NUF to use OPL exclusively as its reinsurer; for its participation, NUF was reimbursed for expenses and received a share of the premiums (capped at $1 million annually). OPL:s reinsurance income (i.e., almost all of the EVCs) was subject only to a 1% Federal excise tax. Importandy, OPL performed little, if any, activity related to its role as reinsurer (e.g., UPS continued to investigate, settl'e and pay EVC claims).
UPS contended that NUF earned the EVCs as insurance premium income, that OPL earned reinsurance premium income, and, therefore, that the EVCs did not constitute income taxable to UPS. In support of the arrangements, UPS asserted that it had several legitimate, nontax business reasons for restructuring the EVC business. For example, UPS asserted that it feared state insurance regulators would find it was conducting an illegal insurance business, given that UPS was not a licensed insurer. UPS also asserted that it desired to leverage the EVC profits into the creation of a new reinsurance company.
In evaluating UPSs purported business motivations, the Tax Court started with the proposition that the "determination of whether the taxpayer had a legitimate purpose in entering into the transaction involves a subjective analysis of the taxpayer's intent." Regarding UPS's state insurance concern, the court wholly disregarded testimony from UPS executives on point, and stressed " [n] o contemporaneously prepared documentary evidence was presented to indicate that petitioner had such concerns ...... Given that no documentary evidence supported the claim, the court simply did "not believe that [UPS] would have restructured a significant portion of its business in order to avoid a potential State law problem without having thoroughly analyzed and considered the matter and the ramifications that any proposed change might have. "As to the claim that UPS desired to leverage the EVC profits into a new reinsurance company, the court noted that "any investment of money into OPL could accomplish this purpose,"
In sum, the court found that the UPS/NUF/OPL transactional arrangement was a prearranged plan designed to avoid Federal income tax on UPSs EVC income. The court's findings relied on several corporate documents generated at the time of the restructuring that referred to NUF as a "fronting" company and to OPL as a "captive" insurance company. Finding that the arrangement was devoid of nontax business reasons, the court held that the arrangement was a sham to be disregarded for tax proposes. As such, the court required UPS to include all of the EVCs in its gross income, and disallowed the deduction of any expenses or fees paid to NUF. Finally, the court held that UPS was liable for additions to tax under Sec. 653 for negliance and Sec. 660 fpr substantial understatements of income tax, and for increased interest under Sec. 6621 for substantial understatements attributed to "tax motivated transcations."
UPS is a significant victory for the Service in tis use of nontechincal judicial doctrines in the context of international transcations, when classic "tax shelters" are not involved, such as ACM Inveterings Partnership, TC Memo 1998-305. In particular, while ACM and ASA Investerings involved relatively short-lived capital transcations, UPS involved a transactional arrangement encompessing its standard, day-to-day package delivery activities.
The Tax Adviser (New York) Vol. 31 Issue 1 Jan 2000
--------------------------------------------------------------------------------
United Parcel Service ofAmerica, Inc. (UPS), TC Memo 1999-268, the Tax Court held that UPS improperly shifted $70 million of income offshore to a related Bermuda corporation, Overseas Partners Limited (OPL). Citing Basye, 410 US 441 (1973) and Lucas v. Earl, 281 US 111 (1930), the court found that UPS itself was the true earner of the income under Sec. 61 and had improperly attempted to assign that income to OPL. According to the court, the transactional arrangements that would have allowed OPL to earn the income offshore, free of US. corporate income tax, lacked a legitimate, nontax business purpose. Therefore, under the sham transaction doctrine, OPUs participation in the arrangement should be ignored and the income should be taxed to UPS. In arriving at this conclusion, the court disregarded substantial testimony offered by UPS executives and relied instead on contemporaneous documentation as to the intent and purpose of the transactional arrangements. The court imposed penalties exceeding $15 million under Secs. 6653 (negligence), 6661 (substantial understatement of income) and 6621 (substantial understatements attributable to "tax motivated transactions"). UPS is engaged in the pick-up and delivery of small packages and parcels within the US. and in certain countries abroad. At all times, UPS's activities were regulated by the Interstate Commerce Commission (ICC), state transportation agencies, public utility commissions and the Civil Aeronautics Board. In connection with regulatory requirements, UPS's pricing structure was set forth in detailed tariffs filed with the ICC and most states' state transportation agencies. This pricing structure established certain "base rates," depending on the package size and delivery location. The base rate automatically provided the customer (the shipper) with coverage against loss or damage to its package up to $100. If a shipper desired to obtain additional coverage, it would declare the value of the package and pay an additional 25 cents ($0.25) of "Excess Value Charges" (EVCs) per additional hundred dollars of value declared. For all of its tax years through 1983, UPS collected the EVCs and included them in its gross income. In 1983, however, UPS was approached by an insurance brokerage firm with a plan to restructure the EVC aspect of UPS's shipping business. Because the EVCs provided shippers with coverage against loss or damage to their packages, the excess value business had significant attributes resembling insurance. Under the plan, UPS would collect the EVCs on behalf of shippers as "insurance premiums" payable to an unrelated insurer (NUF), which, in turn, would pay "reinsurance premiums" to OPL. UPS had recently created OPL and declared a dividend payable to UPS shareholders equal to one share of OPL stock for each share of UPS stock held. Under the arrangement, UPS required NUF to use OPL exclusively as its reinsurer; for its participation, NUF was reimbursed for expenses and received a share of the premiums (capped at $1 million annually). OPL:s reinsurance income (i.e., almost all of the EVCs) was subject only to a 1% Federal excise tax. Importandy, OPL performed little, if any, activity related to its role as reinsurer (e.g., UPS continued to investigate, settl'e and pay EVC claims).
UPS contended that NUF earned the EVCs as insurance premium income, that OPL earned reinsurance premium income, and, therefore, that the EVCs did not constitute income taxable to UPS. In support of the arrangements, UPS asserted that it had several legitimate, nontax business reasons for restructuring the EVC business. For example, UPS asserted that it feared state insurance regulators would find it was conducting an illegal insurance business, given that UPS was not a licensed insurer. UPS also asserted that it desired to leverage the EVC profits into the creation of a new reinsurance company.
In evaluating UPSs purported business motivations, the Tax Court started with the proposition that the "determination of whether the taxpayer had a legitimate purpose in entering into the transaction involves a subjective analysis of the taxpayer's intent." Regarding UPS's state insurance concern, the court wholly disregarded testimony from UPS executives on point, and stressed " [n] o contemporaneously prepared documentary evidence was presented to indicate that petitioner had such concerns ...... Given that no documentary evidence supported the claim, the court simply did "not believe that [UPS] would have restructured a significant portion of its business in order to avoid a potential State law problem without having thoroughly analyzed and considered the matter and the ramifications that any proposed change might have. "As to the claim that UPS desired to leverage the EVC profits into a new reinsurance company, the court noted that "any investment of money into OPL could accomplish this purpose,"
In sum, the court found that the UPS/NUF/OPL transactional arrangement was a prearranged plan designed to avoid Federal income tax on UPSs EVC income. The court's findings relied on several corporate documents generated at the time of the restructuring that referred to NUF as a "fronting" company and to OPL as a "captive" insurance company. Finding that the arrangement was devoid of nontax business reasons, the court held that the arrangement was a sham to be disregarded for tax proposes. As such, the court required UPS to include all of the EVCs in its gross income, and disallowed the deduction of any expenses or fees paid to NUF. Finally, the court held that UPS was liable for additions to tax under Sec. 653 for negliance and Sec. 660 fpr substantial understatements of income tax, and for increased interest under Sec. 6621 for substantial understatements attributed to "tax motivated transcations."
UPS is a significant victory for the Service in tis use of nontechincal judicial doctrines in the context of international transcations, when classic "tax shelters" are not involved, such as ACM Inveterings Partnership, TC Memo 1998-305. In particular, while ACM and ASA Investerings involved relatively short-lived capital transcations, UPS involved a transactional arrangement encompessing its standard, day-to-day package delivery activities.
O
old
Guest
A management line, "30 days to hire them, 30 years to fire them"....If the management team knew the contract and took progressive, equal, and fair discipline, he could go - or at least feel enough heat to get the idea.
We always came up with fun ways to address an a-hole steward...like spend the entire preload walking his tired <FONT COLOR="ff0000"></FONT> all over the hub to monitor this or that. There were times he would walk 6 or 8 miles in a morning - and we would laugh until we turned blue. When you pay these guys, you can usually get away with more tricks than with the ordinary hourly employee. Hmmm... following the irreg train around for the entire sort is fun (of course, all in the spirit of giving his brother the benefit of the doubt on his work pace - "better observe him all night to be fair!"
The best game was with a driver who loved to work tons of hours - 10.5 was fine with him. He would not run scratch either...so...we gave him about 45 stops (5 hour day) and when he called for extra work, we would say - that's all - bring it on in. Sure we paid him 8, but it was straight time and after his first paycheck that was about $300 less than normal, he got the picture.
We always came up with fun ways to address an a-hole steward...like spend the entire preload walking his tired <FONT COLOR="ff0000"></FONT> all over the hub to monitor this or that. There were times he would walk 6 or 8 miles in a morning - and we would laugh until we turned blue. When you pay these guys, you can usually get away with more tricks than with the ordinary hourly employee. Hmmm... following the irreg train around for the entire sort is fun (of course, all in the spirit of giving his brother the benefit of the doubt on his work pace - "better observe him all night to be fair!"
The best game was with a driver who loved to work tons of hours - 10.5 was fine with him. He would not run scratch either...so...we gave him about 45 stops (5 hour day) and when he called for extra work, we would say - that's all - bring it on in. Sure we paid him 8, but it was straight time and after his first paycheck that was about $300 less than normal, he got the picture.
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