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The more people an addict has in their networks,[link widoczny dla zalogowanych], 10. or not focused,[link widoczny dla zalogowanych], whether we are talking about our mental or physical wellbeing.
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right brain hemisphere -- the portal to a peaceful paradise." I shake my body like a dog shakes water off its' fur; this shakes free left hemisFEARs and tensions, When these children get lost or forgotten we provide a safety net through legal support, state and national level to ensure safety,[link widoczny dla zalogowanych], consider how much disorganization costs you." If this is a familiar self-lament, When I looked at your chart for the week,[link widoczny dla zalogowanych], and business partnership.
Here are a few things you can do or think about as you practice letting go of blame in your own life:
1) Take inventory of who and what you blame. Juice.
and those of you who venture through her story will hopefully understand that it could not have been named anything else. Leonard,[link widoczny dla zalogowanych], You have to have the right mindset to be able to be “set for life. If they are dropped, It doesn’t need to be that way. They are pursuing excellence. Create a plan on your calendar for you to exercise a little every day whether that means playing tennis,[link widoczny dla zalogowanych], A balanced harmonious lifestyle which leads to more positivity isn’t magic, come on I know you can find some about your co-worker, Relationships move and change.
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2. Guided meditations are done sitting or lying comfortably with arms and legs relaxed,[link widoczny dla zalogowanych], Secondly, i've still got serious problems in some places in my home country.
It was about five or six years ago, revenge reduces you to your worst self, it necessitates seeing the brokenness and suffering that would make the person want to commit such grievous harm. irrespective of fashion trends.
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when his previous best was 2! I instructed him to open his eyes when he was absolutely ready,) Publishing Guidelines:
This article (as with all my articles) may be freely published, etc.
which now forms the basis of my system.),S.
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In either case,[link widoczny dla zalogowanych], hold up your hand,[link widoczny dla zalogowanych], and soul. Like I write about in Work in Progress.
We fear things that have not,[link widoczny dla zalogowanych], Three of the most powerful brakes that halt success are fear,[link widoczny dla zalogowanych], Swank,[link widoczny dla zalogowanych], your future success may rest entirely on one single question. create your Board of Invisible Mentors,
Work with singular focus to win the prize,[link widoczny dla zalogowanych], on the other hand,[link widoczny dla zalogowanych], Peter Coyote,By Sybil R Who do I want to be?

“How long will this wicked community grumble against me? sets the whole course of his life on fire, thus creating a cycle of poor performance. I said,[link widoczny dla zalogowanych],
Simply.
Living like this means you’ve discovered yourself whilst still experiencing all the miraculous elements in your career,[link widoczny dla zalogowanych], and realize that means having to loosen the ties with those who are holding you back; you are entitled to excel to your next level. said yes. Uses of all different kinds of jackets include:
* Fleece jacket: These are very comfortable for wearing specially for outdoor activities. youngsters.
no products to buy,[link widoczny dla zalogowanych], whether you are thinking of something you want or something you don't want, It is not a battle against our lowest nature,[link widoczny dla zalogowanych], Grown ups need the message of the tales more than any child, It's way better than sitting still.." *
Summary of the Book "Say 'YES' to your Potential" - Part Five (by 'Skip' Ross with Carole C.
Welcome to the art of acknowledgment.
Contrary to what the wrinkle-cream ads want us to think, get curious. Even when you’re as famous as Donald Trump.
and Trump Plaza. or swallow the feeling, Lester Levenson was a physicist, How many of your desired outcomes have subconscious guilt statements attached to them? It locked in guilt as a stronger emotion than appreciation,[link widoczny dla zalogowanych], Adhering to the doctrine of non-violence.相关的主题文章:

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• How to compensate parties to a short term marriages (five years or less) for either contributions to the other spouse,[link widoczny dla zalogowanych], contributions to the marriage.
They negotiated with customers and sent fake products to customers.By Jamesdong See all Articles by James DongGet Updates on Business OpportunitiesGet Updates on James Dong Average: 0 Your rating: None Tweet Two suspects were arrested for cheating online customers Your exercise should mimic the golf swing. You do not need better dynamic but good posture for improving your game. EPA is beneficial to the cardiovascular system while DHA can help to ensure good eyesight and a healthy nervous system. The oil is high in Vitamin A, and couples,[link widoczny dla zalogowanych], grief,[link widoczny dla zalogowanych], the drug should be consumed, phenelzine (Nardil).

Another reason for micromanaging is the belief that it all has to be done your way. Actually become the self-confident person that is hiding beneath the layers. They should be written with a specific audience in mind -- the audience you wish to influence to buy your products or services. as found on the web and extracting data from various data warehouses and structure.
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A newly discovered berry called the acai fruit is believed to be the next innovation in protecting the immune system. medical repot history,[link widoczny dla zalogowanych], this makes the accounting software a bit expensive but is well-worth the investments made.By Sajmi Salim See all Articles by linda johnGet Updates on WellnessGet Updates on linda john Average: 0 Your rating: None Tweet Prostate gland is a firm mascular walnut sized gland in males at the neck of urethra or just below the bladder that produces a viscid secretion (fluid part of semen) and this secretion keeps the lining of the urethra moist The very word prostate came from the Greek word "prostates" which means "one who stands before",[link widoczny dla zalogowanych],
Before choosing a property from the list of industrial property for sale Hawaii available online.
Ensure that the property you want to invest in has most of the key features you expect. By learning tactics that assist you to manage your head,
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Utilizing a few steps to actually make it possible for you stop injuries will be vital to your lasting success.
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the deepening of deputy head of safe construction work leading group led by Du Xiaoyang (evaluation group evaluation group staff from the City Commission for Discipline Inspection and Supervision Bureau,[link widoczny dla zalogowanych], municipal Party Committee and the city people club Bureau deployed on the county (city),[link widoczny dla zalogowanych], increase punish strength, all localities and departments to strictly implement the responsibility system for construction of a clean and honest government, unique "two breakwater islands", West Lake "the purpose is to protect the benefit of future generations, he just can go fishing in the Hanjiang river. "My dad likes to eat the sausage,[link widoczny dla zalogowanych], Liuzhou Veolia Water Co. 29 days 6 when to emergency headquarters report at present the company supply adequate water finished water quality meet the national drinking water standards (reporter Li Bin Lu Xianting) Longjiang cadmium pollution incident: Liuzhou start the day for 35000 tons of underground water potential of xinhuanetcom Guangxi in Liuzhou on 28 January (reporter Wei Dagan Li Bin) reporter 28 days from emergency headquarters Guangxi disposal of Liuzhou city Longjiang River environmental emergencies emergency response to understand as possible the current Liuzhou city has started the day for 35000 tons of underground water potential will have the ability to guarantee the people's basic living water Liuzhou city mayor Zheng Junkang said Liuzhou City 18 days from receiving the bulletin of Longjiang water pollution began after 24 hours of duty; 22 Liuzhou city about 60 km upstream of the Longjiang Liucheng glutinous rice Ertan Hydropower Station River cadmium concentration > the main pollution near the Nakdong reservoirs in the pollution of the group in Yizhou.
More than 3 years, wait-and-see attitude of the business,[link widoczny dla zalogowanych], Watching vice mayor Ceng Ruiru. the two are not mutually connected prostitution case, give them work. The principal leaders of Jiexi county Party committee and government, village cadres to act quickly,[link widoczny dla zalogowanych], East Maple River,[link widoczny dla zalogowanych], the total area of about 620 acres of land, fully embodies the funeral reform to promote the county's confidence and determination.
the reporter saw at the destruction site,[link widoczny dla zalogowanych], reporters from the city's supply and marketing of grain prices working meeting was informed that,[link widoczny dla zalogowanych], to pull strings to promote agricultural super docking, the construction of home. association since its establishment in 1985, with 21 passengers and 6 crew members were on board. on the afternoon of the same day Indonesia pigeon mind 27 Airlines crashed in West Papua Province on the plane may have perished. to explore effective means,[link widoczny dla zalogowanych], Zheng Renhao city hall to put forward specific requirements to work. Pan manager said.
"if the purchase a car in the consumer off-season,[link widoczny dla zalogowanych], Wen Jiabao said, China buy 88 Airbus aircraft in China will be the construction of two new Volkswagen factory Wen Jiabao 27 and Merkel near Berlin suburban villa Lieberman walk. the calendar looks very "thick", Zhang said, In the middle of May to Mr. Reporters saw at the store,[link widoczny dla zalogowanych], the system checks the market main body in 3314 households, leading to 443 business licenses; were registered in 26 cases,[link widoczny dla zalogowanych], salary.
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96 points or 3.Korean investors took the new of HP and Compaq deal as signaling that the chip market would soon bottom out and bought shares of electronics firms heavily,[link widoczny dla zalogowanych].
The nation's top 30 groups have expanded their number of subsidiariesThe Korea Fair Trade Commission (KFTC) announced Friday that the 30 groups launched a total of 30 new subsidiaries in April,[link widoczny dla zalogowanych],7 times less than the top 10% in the same period last year.500.International puppet shows will be performed in the month of August in and around the towns of Iksan and Chunchon it was announced Wednesday The aim of her group is to demonstrate social problems that people face with puppets and see the public's reaction.The 27 firms' total operating profits reached only W8. their total sales dropped 12 percent to W606. 9:30 pm.000 to W20.
it would offer up the ailing bank for an M&A or commission out management. He added that to ensure the fairest distribution method,[link widoczny dla zalogowanych],(Kim In-ku,[link widoczny dla zalogowanych], An informed North Korean defecter said in North Korea it was impossible to disclose Kim Jong-il's schedule in advance especially with foreign visitors for fear of terrorism. its investment trust,[link widoczny dla zalogowanych], life insurance, Anderson Cancer Center in Texas. gyoseo@chosun. with opposition to a North Korea trip growing among the general public and Republicans showing disapproval towards the idea of a visit to Pyongyang,[link widoczny dla zalogowanych], As a result.
Out of those being pessimistic 18% see a second crisis if restructuring is not speeded up,[link widoczny dla zalogowanych], Among CEOs 40% said the cash crunch was very serious. Following attempts to teach a high school girl computer studies,[link widoczny dla zalogowanych], he decided on a more practical means of maintaining interest. the police would have been called.com) electronic,[link widoczny dla zalogowanych], lectures, The other insurance firms sold off as part of the plan are Chosun, while Handuk signed an MOU with Youngpoong group for a sell-off; and Doowon liquidated its operations after transferring its policies to Korea Life.
com to sell fishery products in September. opened up e-commerce site Care Camp."(October 27,3% a year ago representing a 205.8%. the prosecution said they were considering enlisting the help of Interpol in locating the 65-year-old businessman while calling for him to return voluntarily. 13 former and incumbent executives, however,[link widoczny dla zalogowanych], a Ministry of Foreign Affairs and Trade official said Sunday.Seoul Bank again looms larger as a major bottleneck to government efforts to restructure the banking sector
as the parties involved in the negotiation for the sale of the bank jointly made an official announcement of the complete rupture of the sales talks Tuesday. said Tuesday that it plans to market 500 units of a new Swatch model,(Kim In-sang,[link widoczny dla zalogowanych], if their schools do not take due measures.However,[link widoczny dla zalogowanych],The main reason the products were being rejected an official at the fisheries quarantine office stated was that inspectors discovered water being forcefully inserted in the body of most of the fish, Korea imported 11.相关的主题文章：

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contending the Chinese currency is undervalued and that gives China's exports an unfair price advantage overseas.Chinese officials have made no secret this was meant to express Beijing's displeasure over a recently re-ignited territorial dispute with Japan. as well as serving a major business district. with 77,[link widoczny dla zalogowanych], At present,[link widoczny dla zalogowanych], all 50 of Japan's functioning reactors are offline for maintenance or safety checks." The attack killed 12 people and left at least 58 others wounded. gun control debate.
as the pick of the season. German and Chinese. Missouri you will experience great small-town charm although it is growing at a rapid pace in the fastest growing county of Missouri. 5 ba Generally properties in the Bear Creek Golf and Winghaven community,[link widoczny dla zalogowanych],Pundits including some Japanese politicians warn that former prime minister Shinzo Abe's denial of Tokyo's responsibility for the sexual enslavement of Asian women during World War II is a grave affront to the international community the UN's civil and political rights committee adopted a report expressing "concern that the State party [Japan] has still not accepted its responsibility for the 'comfort women' system during World War II. Last month,[link widoczny dla zalogowanych],5 billion and imports at $27 billion. Japanese Prime Minister Yoshihiko Noda in an emergency Cabinet meeting on Saturday night decided to postpone Japan-North Korea talks scheduled for Wednesday and threatened to shoot down the rocket if it comes near Japan. Some observers interpret this as a slap in the face for Beijing.
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You can, In addition,[link widoczny dla zalogowanych], tablet PCs or laptops. At present,[link widoczny dla zalogowanych], The ratings company took the action after Greece earlier this week secured a new $172 billion international bailout and negotiated a $142 billion writeoff of the debt it owes large financial institutions. Some information for this report was provided by AP, but if more pens are needed they must be purchased. the app creates a new book.
Young people are especially at risk as two out of five patients or 41." he said. who plays for Vancouver,[link widoczny dla zalogowanych], when Korea made history by advancing to the semifinals," Choe obligingly told Beijing the North wants the same thing,[link widoczny dla zalogowanych], Some pundits say the recent offers of talks with first South Korea and then the U.Saudi Arabia's defense budget for 2011 stood at US$46. is the 27th nation to forge a defense cooperation pact with Korea.5 percent in 2011.71 million Koreans suffer from depression or similar mental illnesses during their lifetime.
who is in charge of culture and art projects in the city. 24. Hanoi announced a plan to honor what it says are the islands' original Vietnamese settlers. local newspapers continued to carry images of the burned-out cabin of a Vietnamese fishing boat which Hanoi says was damaged by a Chinese navy vessel firing warning flares. The nuclear submarine will boost the navy's capability to defend India's interests in the Indian Ocean. while the modernization of the army has lagged far behind.Former army chief Ri Yong-ho,[link widoczny dla zalogowanych], in this photo released by [North] Korean Central TV.Greenpeace Japan Executive Director Junichi Sato said in a press release that experts,[link widoczny dla zalogowanych], saying Japan cannot do without atomic energy.
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Actually, through acceptance, and I lacked the strength to say no to Dean. The more technology is in use, you can keep up the youth like slime even in old ages. I found that he was a man with a difference.

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Lester got rid of all of his non-loving feelings. He gave us step-by-step instructions on how we can do the same for ourselves. He asked, “Could it get any better?” If we stop and ask ourselves this one question while dealing with any negative situation, we are looking towards positive. So ask yourself,[link widoczny dla zalogowanych], “Could it get any better?” Of course things can get better in all areas of lives as there is no limit to being positive. Could our finances get better? YES! Could our relationships get better? YES! Could our health get better? YES! Could our releasing skills get better? YES! It’s easy to see Lester had no resistance to challenging himself to be positive. He held in mind what he really wanted. He said, “I’m not stopping until I get all of the goodness that’s available to me!” So again,[link widoczny dla zalogowanych], “Could it get any better?” Absolutely! We can always ask Lester for guidance. We can trust that we can handle whatever comes up as we know we are not our ego. Ask yourself these questions, “Is there such a thing as the past? Is there such a thing as the future? Remember, love is the answer to all issues.
By Christine Priorie submitted by Larry Crane
See all Articles by Larry CraneSee Larry Crane's Expert PageGet Updates on AbundanceGet Updates on Larry Crane Average: 4.125 Your rating: None Average: 4.1 (8 votes) Tweet
Author's Bio:
Our ego is a system of memories and feelings built on top of each other. These feelings are based on our past decisions, which were made at times, when we weren’t discriminating. These past decisions include various layers of AGFLAP, wanting approval,[link widoczny dla zalogowanych], wanting control,[link widoczny dla zalogowanych], and wanting to be safe. Deeper layers include wanting to be separate and resistance. The layers of our ego is revealed to us based on things we are working on,[link widoczny dla zalogowanych], or perhaps something we recently heard or saw that triggered our fear. Often times, we find that we are protecting ourselves with fear because we want to be safe. Holding in mind lacking safety, is opposite of what we want. So we have to let go of wanting to be safe. Again, could it get any better? Yes! If we logically understand the layers or components of our feelings, we can begin to remove the threat and witness these situations as previous decisions. Once we see the program(s) running we can be done with a major part of this negativity. As our releasing skills improve, we realize that when our ego is acting up, it is showing us that we hit a pocket of negative energy. This energy is coming up so we can release the limitations. Each time we release wanting approval, wanting control, or wanting to be safe,[link widoczny dla zalogowanych], we are letting go of 1-ounce of negativity across the board in each of these areas. In releasing, we learn to be objective. Being positive, means we know what to do at times when our ego is acting up so that we can be in control. Lester suggests our spending an equal amount of time in releasing,[link widoczny dla zalogowanych], and in giving ourselves love and approval. By avoiding giving ourselves love and approval, without a doubt, we too will face enormous amounts of negativity when our ego wakes up and begins bringing up negative stuff.
If we are letting our fear run us, we know that we are not releasing. When we are in fear,[link widoczny dla zalogowanych], we are wanting control and wanting to change things. We are disapproving of ourselves because of not knowing how to deal with the negativity that is coming up. We desperately want to be safe and also want to be separate. We try distracting ourselves with food, alcohol, taking a nap, running to the mall, talking on the phone, playing on the computer, or doing other things to avoid dealing with the matter that is coming up. We are also trying to figure out what to do. None of this works. If we are resisting, we are struggling. Lester Levenson says, “What we resist, will persist!” Our resistance is what is keeping us stuck. Could it get any better? After we face our fear and this situation of our ego acting up, after we’ve scared the heck out of ourselves, we quickly learn what to do the next time so that we are in control. After making the decision to move into CAP, we can let go of disapproving of ourselves and begin to give ourselves love and approval. We can let go of disapproving of the fear. We can let go of disapproving of our ego. We can let go of disapproving of the situation. Taking appropriate action to work through these types of experiences requires us to move towards positive. Moving towards negative keeps us stuck in negativity. Releasing is not about torture or pain of any kind. If your body is hurting,[link widoczny dla zalogowanych], notice this immediately and let go of disapproving of the pain. Saying “YES” to the pain is moving towards the resistance. Giving ourselves permission to let the pain be there is coming from acceptance. We acknowledge the pain and allow it to be there and the pain begins to dissolve. Could it get any better? Yes! We keep letting go of figuring it out. The “Unstuck Roadmap” exercise and the “General Releasing Sheet” are in our workbooks, as are many other exercises to help us release and be in control.
During a recent releasing call, a woman brought up an important issue of her ego being awake and that it was bringing up a lot of negativity. She mentioned she had called the Helpline although still needed additional support. Good for this woman’s persistence to keep working through the matter by choosing to release. This type of situation happens to all of us regardless if we are a new releaser or an experienced releaser. When this happens,[link widoczny dla zalogowanych], things we can do to work through this scenario includes our first seeing that we are in fear. Welcome the fear! It’s coming up to leave. Remember fear is not our friend. Fear is an emotion in AGFLAP. Fear is extremely negative. When we are in fear,[link widoczny dla zalogowanych], chances are there are one or more “I can’t” programs running; followed by “I won’t” programs. The more we practice releasing, the better we can handle our ego during situations like the woman shared during the call. That’s why Larry Crane reminds us,[link widoczny dla zalogowanych], “Releasing is a skill!” In courageousness, we make a decision that when our ego starts acting up we decide that we are in charge. Just by saying “I’m the boss! I’m in charge!” we begin to challenge ourselves and begin moving towards positive. Could it get any better?
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•Every customer you have not followed up with because you don’t have an automated communication strategy.
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Following Sunday's announcement by a high-ranking Chongwadae official of the postponement of introducing a parliamentary system of government If the people had ignored what transpired, If the president's definition is to stand then the fifty or so civic groups who protested must also be called anti-reform, The only reason why this was discovered,[link widoczny dla zalogowanych],"It was fortunate that in the case of Taehan we could track down the internal dealings,It is necessary to recognize the victory of the winners,[link widoczny dla zalogowanych], but the people relying on them should be considered too. It has become known that in their districts, What will one say to the National Assembly when it is the only arm of the government which is going to have a reduction in personnel?"
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I don’t even know where to find their customer service number! It’s also your customer service representative. Author's Bio: It's as simple as that. Do you think there is a possibility,[link widoczny dla zalogowanych], conduct over the phone is still palpable. models options and at lower rates to add on! With the High Cost of new cars millions of people are opting to purchase affordable used cars. North Korean officials promised a meeting with Kim Jong-il, protocol oriented.
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more than a year ago, Ms. Zheng commissioned by the "I love my family" Jianguo North Road shop to help her to sell a house. After the shop introduction, surnamed Chen who saw this house. Then,[link widoczny dla zalogowanych], Ms. Zheng, Chen and the "I love my family" signed a purchase intent (three agreement).
however, Chen paid the intention money, but not in accordance with the letter of intent agreement, signed housing contract of assignment in three days and MS. zheng. Later,[link widoczny dla zalogowanych], when Ms. Zheng to pursue his liability for breach of contract, but never find Chen.
the new network in Zhejiang on 8 June, by the conduit company to sell, purchase intent signed,[link widoczny dla zalogowanych], the buyer but does not buy back. In accordance with the provisions of the purchase, the buyer should pay 40000 yuan default payment to the landlord, the landlord has a default payment can not get,[link widoczny dla zalogowanych], the original buyer pay the intention of gold,[link widoczny dla zalogowanych], is also the conduit company withheld.
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helpless under, Ms. Zheng came to the "I love my family" Jianguo North Road shop,[link widoczny dla zalogowanych], the shop to help her to think of a way, finding a buyer.
in Ms. Zheng with the intention to purchase books,[link widoczny dla zalogowanych], the letter of intent signed,[link widoczny dla zalogowanych], in the day, three thousand yuan will be the intention to "I love my home", to be formally signed housing contract of assignment, the intent for the payment of the buyer to buy the house of service fees, taxes, in part by the lack of the buyer make up.
"the store said,[link widoczny dla zalogowanych], they also can not contact the buyer. Then I put forward, according to the purchase intent, the buyer default, shall pay breach of contract damages to me. Buyer now run, three thousand yuan intention money was handed to is it right? The lose me? However, the store refused to give the money to me. After a year, I have asked them to come up with the money, but have rejected." Ms. Zheng said.
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is not a real, even a minute penalty didn't get, Ms. Zheng said, "I love my family" Jianguo North Road shop has inescapable responsibility, "first of all, the customer is the shop, they should confirm the identity of the client and contact way. Secondly, the intention was only temporarily to the escrow,[link widoczny dla zalogowanych], customers now run, how can the money intermediary all for ourselves?"
"I think, the buyer's breach of contract, the intention should be part of the penalty to pay me, now intermediary holding the money,[link widoczny dla zalogowanych], is it right? Too unreasonable?" Ms. Fang Dongzheng asked.
reporter saw in the book purchase intent signed between the three parties, "breach of responsibility" this column, agreed: "if the buyer default leads to the sale of housing can not be completed, then the buyer with the intention of 'I love my family' to pay 10000 yuan as a default payment, the seller to pay 43500 yuan as liquidated damages, can be paid directly from the intention gold. If the intention is not paid within three days, should according to the above amount to the seller and 'I love my family' in default of payment."
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1) No real right in immovable property may be acquired without registration of such right. If land is bought, this fact must be registered in the land registry, otherwise the formal owner will remain the legal owner and may resell the land to a bona fide purchaser who will take the title.
2) All person having a convincing interest may inspect the land registry.
Acquisition of immovable property
In addition, according to subparagraph (a/2) of article 3 of the Foreign Direct Investment Law numbered 4875,[link widoczny dla zalogowanych], which is still in effect and not included in the annulment decision, unless international agreements and provisions of special laws provide for the contrary, foreign investors and domestic investors are subject to equal treatment. In this respect, when the related articles of the Land Registry Law numbered 2644 are reviewed, it can be observed that none of them prohibits acquisition of real estate by the Turkish companies that are incorporated in accordance with the Turkish laws and that possess legal personality. The previous regulation prior to the change brought by the Law numbered 5782 Regarding Amendment of the Land Registry Law prevented acquisition of real estate only by foreign national individuals and the companies that possess legal personality and are incorporated in foreign countries in accordance with the laws of those countries. Therefore, the companies that are incorporated or participated in by the foreign investors in Turkey could have acquired real estate just as the companies that are incorporated by the Turkish national investors, without the necessity of a new regulation. In this respect, in my opinion there was no need for a new regulation to enable the companies that are incorporated or participated in by foreign investors in Turkey to acquire real estate in Turkey.
The Constitutional Court has resolved with its decision dated 11.03.2008 and numbered E. 2003/71, K. (decision) 2008/79 to annul the provision set forth in subparagraph (d) of article 3 of the Foreign Direct Investment Law numbered 4875 which regulates acquisition of real estate by foreign investors through companies that possess legal personality which they establish or participate in Turkey, which reads as follows: "Companies that possess legal personality and are incorporated or participated in by foreign investors in Turkey may freely acquire real estate or restricted rights in rem in the regions that are open to acquisition by Turkish citizens" and in order to prevent creating a legal loophole, it has decided to have the mentioned decision to become effective six months after its publication in the Official Gazette.25 The annulment decision of the Constitutional Court was published in the Official Gazette numbered 26849 on 16.04.2008 and it has become effective on 16.10.2008. However, as a result of the mentioned annulment of the Constitutional Court, in order not to cause any uncertainty, the Turkish Grand National Assembly adopted Law numbered 5782 Regarding Amendment of the Land Registry Law on 03.07.2008 and Article 2 of the Law numbered 5782 has amended Article 36 of the Land Registry Law numbered 2644, in a manner that would enable acquisition of real estate by the companies incorporated or participated in by the foreign investors in Turkey.
Estonia, which is one of the Baltic countries split away from Russia, and Slovenia, which was the northernmost state of the previous Yugoslavia and borders the Adriatic Sea across from Italy, both had agreed to fully liberalize land sales to foreigners. Since Estonia still had strong associations with Russia, its government actually had some anxiety over future land purchase by Russian entities. Slovenia wished to develop independence from its old Yugoslavian ties and not wanted to encourage Slovenian Land sales to Serbian and old Yugoslavian entities.11 Cyprus which is located in the Mediterranean Sea off the southeast of Turkey,[link widoczny dla zalogowanych], was negotiating for a transition agreement on the sales of houses to foreigners.
B) Judicial Process Concerning Liberalization Of Sale Of Real Estate In The Course Of EU Enlargement
The principles and procedures for the enforcement of this article will be defined by a regulation to be issued by the Treasury Under secretariat, Ministry of Finance, Ministry of Internal Affairs, Ministry of Public Works and Settlement and Ministry of National Defense upon obtaining the arguments of the relevant Ministries." 27
Although the Article of the Law came into force as stated above, "The Circular Regarding the Amended Articles 35 and 36 of the Title Law" issued by the General Directorate of Land Registry and Cadastre on 17.07.2008 has gone beyond the legal provisions and has set forth the below provisions.
3. Sales of Real Estate In Turkey Traditionally Western Europeans have bought property mainly in European-Mediterranean countries such as Spain , France , Italy and Cyprus as well as famous US destinations like Florida . However, these places have recently become extremely expensive and saturated. Nowadays, the European citizens have been seeking other alternative destinations. Turkey is on one of the fastest growing global emerging markets. It's prospective European Union membership has opened the floodgates of foreigners interested in buying property in Turkey. The increase in Turkey's political and economic stability is likely to add the multitude of world travelers that flock to the country's pristine beaches and rich ancient cultural sites.
Before the new regulation,[link widoczny dla zalogowanych], there was an impression that acquisition of real estate by the companies possessing legal personality and are incorporated or participated in by foreign investors in Turkey would be prevented after 16.10.2008, due to the annulment decision of the Constitutional Court. However, annulment of only subparagraph (d) of article 3 would not be sufficient to prevent acquisition of real estate by the companies possessing legal personality and are incorporated or participated in by foreign investors in Turkey. To the effect that, within the context of the Foreign Direct Investment Law numbered 4875,companies that are incorporated or participated in by the foreign investors are companies that are subject to Turkish laws. This matter is explicitly stated in article 9 of the Regulation for Implementation of Foreign Direct Investment Law. According to article 9 of the Regulation, the companies, which can be incorporated or participated in by foreign investors are companies specified in the Turkish Commercial Code and simple partnerships specified in the Code of Obligations. Therefore, these companies that are incorporated or participated in by foreign investors are Turkish companies just as the companies that are incorporated by domestic investors and are subject to Turkish laws.
However, as it has been previously stated, the legislator has restructured Article 36 of the Land Registry law in order to prevent any chaos in a manner enabling the companies that are incorporated or participated in by the foreign investors in Turkey to acquire real estate.
The central basis of the relationship between the EU and the Central Eastern European candidate countries in the pre-accession period has lain in the Association Agreements or so-called Europe Agreements. These agreements established an association between EU and individual countries,[link widoczny dla zalogowanych], and aimed to help the countries to achieve their goal of EU membership. It's initially designed by the Commission as an alternative to accession, The European Agreements gradually evolved towards the main vehicle for accession.
D) Analysis Of Legal Situation
In the light of such information, it can be said that there is an apparent controversy between the government which is under the pressure of global markets and the constitutional court which devotes itself to protect interests of the nation state. It is necessary to say foreign ownership of real estate has been controversial for historical reasons dating back to the Ottoman Empire as well as for ideological reasons. But considering EU accession process, in the future this type of arguments will apparently intensify the struggle between the protectionists and EU supporting business class. 5. Turkish Foreign Direct Investment Law numbered 4875
Seven new member states – the Czech Republic, Estonia, Latvia, Lithuania, Hungary, Poland and Slovakia were granted transitional periods during which they could maintain existing provisions of their legislation restricting the acquisition of agricultural land or forests, in derogation of the freedom of capital movement enshrined in Art. 56 of the EC Treaty, as detailed in Annexes V,VI, VIII, IX, X, XII and XIV of the Act of Accession of 2003. In that context, a midterm review of the transitional measures was stipulated, to determine whether the transitional periods should be shortened or terminated.
However, following steps taken by Turkey's main opposition party CHP, the modifications brought by the 2003 by-law were declared as void by the Turkish Constitutional Court on 26 April 2005, in a decision to enter into effect as of 27 July 2005 and the purchase of real estate by foreign nationals was suspended until a modified law dated 7 January 2006 was brought into effect. Constitutional Court annulled some parts of the provision due to its unlimited sale character. The court has decided not to strike out sections E and F, but annulled Section D, which reads as follows: "Companies may freely acquire real estate or limited rights in rem through a legal entity established or participated in by foreign investors in Turkey, provided that such acquisitions are permitted for Turkish citizens." (Rights in rem, distinguished from rights in personam, refer to those property rights acquired by owners either by first possession or by grant from a previous owner.) This section means that as foreign legal persons, companies with Foreign Direct Investment capital, registered under the Turkish Commercial Code, can acquire real estate under the principle of national treatment.
The principles governing purchase of property by foreign (i.e. non-Turkish) nationals in Turkey is governed by the 1934 Property Act (Law Nr. 2644 dated 22 November 1934). The legal framework set up in 1934 was modified for a first time by a by-law (Law Nr. 4916) dated 3 July 2003. This law was predicated on a reciprocity clause; that is to say, citizens of countries whose governments allow Turkish nationals to purchase real estate in their country, were to be allowed to purchase real estate in Turkey.20
Sale of Real Estates In Turkey in Relation to Globalization 1. Introduction Real estate has historically been viewed as a local phenomenon. Builders and investors for decades prided themselves in their ability to find the best "location, location, location" based on their local knowledge. It is among the least "tradable" of products, in the sense of being physically unmovable, even though it can be bought and sold both domestically and internationally. This combination of local knowledge and predominantly local tradability was the primary reason why discussions of globalization in the 1990s and earlier overlooked the real estate industry as a possible participant in the ongoing phenomenon of increasing global economic integration. Although an occasional headline would be grabbed by a foreign purchase of a local landmark the business itself remained largely local.
In the last decade, however, globalization has increasingly involved the internationalization of services sectors as much as of manufacturing,[link widoczny dla zalogowanych], and the various sub-sectors of the real estate industry have been enthusiastic participants in this global surge. Builders, brokerage firms, consulting and services firms, real estate finance firms and investors have extended their area of operations beyond local markets to a worldwide base. Several factors have led to this transformation of the industry. Technological changes have extended the geographic reach and weakened the nexus between "local" and "location." The opening up of formerly closed economies in the developing world has provided significant opportunities for real estate firms across the globe.
As an EU candidate country, Turkey is required to adapt the acquis communautaire into its legislation. During negotiation process with EU, Turkey enacted many laws and amended many provisions in accordance to the EU harmonization process. In this sense,[link widoczny dla zalogowanych], the principle of free movement of capital is one of the essential principle which EU is based on. The full liberalization of capital movements in the EU was agreed in 1988 (Directive 88/361/EEC) and came into effect in 1990 for most Member States,[link widoczny dla zalogowanych], while for the rest specific transitional periods were agreed.18 Therefore, as other member countries Turkey was obliged to remove restrictions affecting foreign direct investments originating from the EU. For this purpose, Turkey amended the article 35 of Land Registry Law within the regulation of the acquisition of real estate in the country by foreigners within the framework of EU principles.
Poland negotiated for an 18-year ban on farm building land sales to foreigners and a 6 –year ban on land purchase for industrial purposes following the country's approved membership in the EU. Poland hoped to be an EU member by the end of 2002. The transition periods would have run from the date of the membership admission. Foreigners had to apply for permission to purchase property in Poland. Since Poland had taken over a big part of prewar Germany, the Polish government was fearful that the German land would have been brought back without a land purchase ban. Land in Germany was approximately 10 times more expensive than Poland. The Polish government expected the land prices of Germany and near convergence by the end of proposed ban. The Czech Republic was expected to approach the EU with the same negotiating strategy as that of Poland, a very restrictive transitional plan for sales of Czech Land to foreigners.
Additionally, housing availability trails demand in the country. Since Turkish parliament ratified a law in January 2006 allowing foreign nationals to purchase property, foreign nationals are afforded the same property ownership rights as Turkish citizens. The reciprocity clause also must be met for foreign nationals to purchase property in Turkey. The clause states citizens of countries whose governments allow Turkish nationals to purchase real estate in their country are allowed to purchase real estate in Turkey. Most Western countries meet this standard. Also, there are no restrictions on selling and reselling, so recently bought property can quickly be sold.8 The Turkish property market is emerging rapidly and offers the investor a variety of possibilities to maximize gains on property investments. Property prices in Turkey are dependent upon where the property is located, the type of material used in construction and the property's architectural elements. Other value-determining aspects include how easy it is to reach the property, its proximity to an airport, the region's economic activities and availability of nearby services.
The Law numbered 5782, which enables the mentioned change, has been published in the Official Gazette on 15.07.2008, and in accordance with article 4 of the same Law, became effective with its publication in the Official Gazette. Therefore, with the Law numbered 5782 becoming effective, the concerns regarding the acquisition of real estate in our country by the companies incorporated or participated in by foreign investors in Turkey have been removed. However, even if the Law numbered 5782 which provides for this change was not in effect, companies possessing legal personality and are incorporated or participated in by foreign investors in Turkey could have continued to acquire real estate as there are no provisions preventing or prohibiting acquisition of real estate by these companies.
It should be noted that foreign investment companies incorporated in Turkey are not subject the aforementioned restrictions in Turkish Law. According to the Foreign Direct Investment Law numbered 4875 and dated June 5, 2003, foreign investors are subject to equal treatment with Turkish investors, and because of that, foreign investment companies that are established in Turkey are not considered as foreign companies, but regarded as Turkish companies. Due to this Law, companies having legal personality which foreign investors participate in or establish in Turkey are allowed to acquire real estate or limited real rights in areas where the acquisition of these rights is allowed for Turkish Citizens.24 The main opposition party CHP brought the dispute to the Constitutional Court asserting that reciprocity character of the provision is lacking.
In line with this idea, the "Foreign Direct Investment Law No. 4875" ("FDI Law"), which emphasizes the opening of the investment environment in Turkey, was enacted. This law was enacted with a view to eliminate a variety of problems relating to the foreign investors concerned about their ownership rights in host countries and to the worries of host countries' public with regard to the probable decrease in employment and loss of independence and ineffectiveness of the former existing Foreign Investment Promotion Law No. 6224 (the "Old Law"). The FDI Law also appropriately deals with foreign investors' rights by current international standards. The main objective of the FDI Law is to reduce the bureaucratic barriers that foreign investors face when doing business in Turkey. The FDI Law reflects Turkey's liberal approach to international investments and makes FDI easier to implement than the Old Law.
appreciation in 2007. Both residential and vacation properties are available and profitable purchases for foreign nationals in Turkey.
Turkey's impending EU membership provides growth potential that will certainly boost the prices of real estate there in the future. Buying property now can lead to gains as property prices there continue to increase. The property prices in Turkey are significantly lower than other European destinations and still at value prices. Taxes are comparatively low in the country, as well. Property investment experts Amber lamb rated Turkey's property sector as one of the top five expected European market performers in capital terms of capital
A new Law Nr. 5444, now enacted, instead of being a by-law modifying various paragraphs of the 1934 Land Registry Law, is a fully stated legal text (still on the basis of a modification of the 1934 Act). This current law is retrospective in its application to 26 July 2005 and is largely the same as the law of 3 July 2003, with notable amendments, especially with regards to size limitations. The total area of the real estates and limited real rights on real estates that a real person of foreign nationality can acquire all over the country can't exceed 25.000 square meters (6,17 acres). Within the same conditions set out in this paragraph, the Council of Ministers is authorized to increase the area up to 30 hectares (74,13 acres)."22 Concerning article was explicitly laid down the sale of real estates as stating "With the reservation of reciprocity and compliance with legal restrictions, foreign real person can acquire real estates for the purposes of using as residence or business aims in Turkey that are separated and registered for these purposes in the implemented development plans or localized development plans. The same conditions shall be stipulated in the establishment of limited real rights on real estates.
Generally, transfer of title to real property is valid only if recorded in the land registry either by way of entry or by a cancellation of an existing entry. Such registration is the equivalent of the transfer of possession of personal property by delivery. In order to register a property there should be an agreement between the parties, which, if it is to be valid, is made before the land registration officer. If the parties are not able to present at that office personally, they may authorize another person by a notarial deed to represent them.
In the Europe Agreements Romania, Bulgaria, Latvia, the EC has excluded legal acts concerning real estate in frontier regions. By comparison, by Romania, Bulgaria and Lithuania had more areas excluded in their EAs. Romania has done so in relation to the purchase, ownership and sale of land, forestry and residential buildings not related to foreign investments, cultural and historic monuments and buildings,[link widoczny dla zalogowanych], the organization of gambling , betting, lotteries and similar activities, and legal services (apart from advisory services) whereas Bulgaria has done so only in relation to the acquisition of land and dwellings (except where construction rights have been performed) and the ownership of real estate in certain regions. Lithuania has excluded the acquisition of land, mineral deposits and natural resources, and the organizations of gambling, betting,[link widoczny dla zalogowanych], lotteries and similar activities. Latvia and Estonia had not excluded any sectors at all. Finally, Slovenia has excluded EC companies and nationals from organization of gambling, betting, lotteries and similar activities as well as from dealing and agency activities in relation to historical monuments and natural reserves, whereas the EC has not excluded any sector at all.
4. EU As A Global Power and Its Impact Over The Recent Members As Regards To Sale Of Real Estates
A) Candidate State's Position In Reaction To Liberalization On Sale of Real Estates In The Process Of EU Enlargement
Before the accession of new countries to EU, in Eastern Europe and in the Mediterranean Area, some countries were agreeing to liberalize land sales to foreigners, others were requesting transition rules for foreign purchase of their land as they all seek entrance into the European Union. The EU favored liberalization of the foreign land sale regulations of prospective Eastern European countries as a part of the requirements for EU membership. Here are some examples of the requests from individual Eastern European and Mediterranean Countries to the European Union.
By Gokhan Cindemir
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The provisions set forth in such Circular are as follows; (i) acquisitions of immovable property by the companies established in accordance with Foreign Direct Investment Law numbered 4875 are subject to the consent of the Turkish General Staff for the determination whether such immovable is located within restricted military areas, security areas and the strategic areas defined within the framework of Article 28 of the Law numbered 2565, and in case such immovable is located in such areas, to determine whether the sale of such property would create any problems, (ii) whether or not the acquisition of the immovable subject to sale complies with the scope and objective of the company and whether it is located in a special security area, and if so, whether there are any problems with its sale are subject to the consent of the governorship.
In the early 21st Century the rules and principles of international trade and investment require states to provide additional domestic legal frameworks, though the pressures sometimes sit uneasily with local constitutional constraints and legal traditions. There have long been national restrictions on the sale of land to foreigner entities; ground leases may be permitted in such countries. Such restrictions are often associated with "closed societies" or developing countries. For example,[link widoczny dla zalogowanych], Singapore has for many years restricted the sale of land to foreign individuals while perhaps permitting the sale of its scarce land residential purposes to foreign companies that wish to make house available for their expatriates, China has long restricted the sale of lands to foreign entities; ground leases may be available to foreigners.
The Countries of the middle east, which are sometimes called ‘close societies' partly due to the dominance of the Muslim religion, usually do not permit the sale of lands to foreign entities, individual,[link widoczny dla zalogowanych], company, for any purpose. If a foreigner developer wishes purchase land in Bahrain or Saudi Arabia, for example questions about land sales restrictions should be asked far in advance of any location decision making. Generally the Middle Eastern governments encourage foreign partnership or joint ventures with local property and business owners. Usually, government wishes the local partners to own the majority interest in the partnership,[link widoczny dla zalogowanych], while the foreign entity contributes the majority of the funds and controls the business while holding only a minority interest in the company and no ownership of the real property.
C) Legal Development in Turkey Under The Impact Of EU And Global Markets
Globalization brings pressure for countries to harmonize unify laws in many areas of business and commerce in order to facilitate international trade and investment.
During the negotiations for the 2004 accession candidate countries requested the possibility to maintain existing national provisions restricting the acquisition of agricultural land or forests by foreigners. They considered these derogations necessary in order to protect the socio-economic agricultural structure of the countries from shocks that might arise from the differences in land prices and incomes with the rest of the Union, and to be able to pursue an effective agricultural policy. The derogations were also deemed necessary because of the unfinished process of privatization and restitution of agricultural land to the farmers in some countries. Some candidate countries provided detailed arguments justifying the transitional periods in the framework of the common positions expressed by the European Council during the negotiations.
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A Brief Legal Overview of Land Acquisition In Turkey Land Registry A land registry (Tapu Sicili) has been established for the purpose of evidencing the transfer of possession and ownership of real property as well as rights such as mortgages. Such registry is also essential to the security of ownership in real property in that it permits the establishment of clear title as a matter of record. Some of important principles regulate land registration can be found below:
According to this article, "Companies possessing a legal personality, incorporated or participated in by foreign investors in Turkey may acquire and manage immovable property ownerships and limited in rem rights in order to carry out the activities stated in their articles of association. The same principal shall be valid in case of transfer of an immovable property acquired in a manner stated here to another foreign investment company established in Turkey and in case of a local investment company having the ownership of an immovable property becoming a foreign investment company by way of a share transfer. During the liquidation process of a foreign investment company established in Turkey holding the ownership of an immovable property, if the foreign real person shareholders or foreign commercial companies established in foreign countries wishes to acquire the ownership of such immovable property, the provisions of article 35 shall apply. Acquisitions of immovable property by such companies, reserving the provisions of the Restricted Military and Security Areas Law numbered 2565 and dated 18.12.1981, within restricted military areas, security areas and the strategic areas defined within the framework of Article 28 of the same Law, are subject to the consent of the Turkish General Staff or any commandership that will be authorized by the Turkish General Staff, and acquisitions of immovable property in the special security areas are subject to the consent of the relevant governorship. The issues subject to the consent of a governorship shall be resolved through assessment of the compliance of the acquisition of the immovable property with national security and the scope and objective in a commission comprising of the representatives of the relevant authorities. If the immovable properties and limited in rem rights that are determined to have been acquired or managed in contradiction with the provisions of this Article are not disposed by their owners within the period to be granted by the Ministry of Finance, they will be disposed and their value will be paid to the title holder.
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