NEWS: INTERNATIONAL TAX REVIEW
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   NEWS: INTERNATIONAL TAX REVIEW
International Tax Review
Aug 28, 2019

US-France digital tax compromise curbs wider economic instability
Taxpayers across various sectors are relieved that the US and France have come to an agreement on digital service taxes that avoids trade tensions.

International Tax Review
Aug 28, 2019

US-France digital tax compromise reduces economic instability
Taxpayers across various sectors are relieved that the US and France have come to an agreement on digital service taxes that avoids trade tensions.

International Tax Review
Aug 22, 2019

Indian tax heads frustrated by slow tax reform with no timeline
Tax heads at India's largest companies are disappointed about the long wait for tax reform, especially the move to a 25% corporate tax rate, as the country tries to balance its tax base and stimulate its economy.

International Tax Review
Aug 22, 2019

Brazil aims to reform complex tax system
Ana Carolina Carpinetti and Luiz Roberto Peroba Barbosa of Pinheiro Neto evaluate the proposed reforms to tax in Brazil and evaluate concerns raised by digital economy companies.

International Tax Review
Aug 22, 2019

Meet ITR at the IFA 2019 Congress
ITR and World Tax representatives will be at the IFA 2019 Congress from September 8 to September 12, where you can meet the team at booth #16.

International Tax Review
Aug 22, 2019

California's retroactive sales tax ‘devastating' for third-party sellers
California's pursuit of back-taxes from third-party sellers on Amazon and other online marketplace sites risks potentially bankrupting small businesses. Sellers claim Amazon's failure to accept responsibility to collect the tax is a worldwide problem.

International Tax Review
Aug 21, 2019

Expanding UK property tax rules could stifle property investment
Property companies and funds may face lower returns on investments in UK property owing to expanding tax rules that may discourage investment because of a rise in tax liability.

International Tax Review
Aug 19, 2019

Tax crackdown on cryptocurrencies open audit and dispute risks
Taxpayers in the cryptocurrency space worry about audits and possible disputes under limited compliance guidelines as tax authorities rush to reinforce rules and collect back taxes on cryptocurrencies.

International Tax Review
Aug 16, 2019

US digital giants worried about domino effect from French DST
Tax heads at Amazon and Facebook said France's digital services tax (DST) adds uncertainty to an already ambiguous international tax environment because other countries can opt to undermine a multilateral solution too.

International Tax Review
Aug 14, 2019

California's VAT back tax ‘devastating' for third-party sellers
California's pursuit of back-taxes from third-party sellers on Amazon and other online marketplace sites risks bankrupting small businesses. Amazon is failing to accept responsibility, sellers claim, and it's a worldwide problem.

International Tax Review
Aug 09, 2019

US companies gain benefits under tailored carbon taxes
Multinational companies, including ExxonMobil and Microsoft, are supporting a corporate-friendly US carbon tax with trade-offs where they pay more tax in exchange for tax certainty, including protection from emission disputes.

International Tax Review
Aug 09, 2019

What to expect at the IFA 2019 Congress
International Tax Review speaks to IFA President Murray Clayson about the prospects for "radical change" on digital tax and why the London Congress will focus on BEPS Action 4 and the challenges facing investment funds.

International Tax Review
Aug 07, 2019

Disclosures show whistleblowing standards benefit tax departments
Data from internal corporate disclosures show that internal procedures and systems for whistleblowing are improving corporate governance and inter-departmental trust within companies, but tax heads are hesitant about the results that create a paper trail.

International Tax Review
Aug 05, 2019

Blockchain could create tax certainty in transactional taxes
In-house blockchain experts and consultants say companies and tax authorities can use distributed ledger technology to report and administer transactional taxes as real-time reporting increases.

International Tax Review
Aug 05, 2019

Euromoney Legal Media Group Americas Rising Star Awards: Shortlist announced
Euromoney Legal Media Group has announced the shortlist for its second annual Americas Rising Stars Awards.

International Tax Review
Aug 02, 2019

Investors disappointed by former Yahoo! company's tax strategy
Altaba, a former Yahoo! entity, will begin liquidating its assets in the coming months, but corporate investors say the liquidation is not the most tax efficient option, nor what they were expecting.

International Tax Review
Jul 31, 2019

DSTs thrust into political limelight
As France's digital services tax takes retroactive effect and the UK releases more details, tax heads spoke of a nightmarish cocktail of uncertainty and high politics.

International Tax Review
Jul 29, 2019

Enhanced accounting standards could curb investor tax frustrations
Companies are starting to explore whether the UK Corporate Accountability Network's latest accountancy framework, which requires tax data to be included in financial accounts for investor analysis, benefits their tax and business strategies.

International Tax Review
Jul 25, 2019

Americas Tax Awards 2019: Nominees announced
The nominees for the 14th annual Americas Tax Awards have been announced.

International Tax Review
Jul 23, 2019

UK gets a new PM and no tax certainty
Following Boris Johnson's win in the Conservative leadership election British businesses have few assurances about the future of UK tax policy and the impact of Brexit.

International Tax Review
Jul 22, 2019

Tax heads: here's how to influence the OECD's digital tax rules
As countries consider the OECD's digital tax proposals, tax heads shared their experiences of trying to get their voices heard.

International Tax Review
Jul 19, 2019

G7 leaders push ahead with global minimum tax
The finance ministers of the G7 countries have agreed that a global minimum tax should be introduced to ensure companies like Facebook and Amazon pay ‘their fair share of tax'.

International Tax Review
Jul 18, 2019

IR35 rules could disrupt Uber and Deliveroo's UK operations
Companies relying on the gig economy workforce, including Uber and Deliveroo, are reviewing whether they can operate in the UK after April 2020 when they will have to treat contractors as employees and pay employment taxes.

International Tax Review
Jul 18, 2019

IR35 rules could end Uber and Deliveroo's UK operations
Companies relying on the gig economy workforce, including Uber and Deliveroo, are reviewing whether they can operate in the UK after April 2020 when they will have to treat contractors as employees and pay employment taxes.

International Tax Review
Jul 16, 2019

Brazil issues ruling on tax treatment of 3D printing
The tax ruling issued by the Brazilian Federal Revenue Service on whether 3D printing should be classified as a manufacturing process for a business could mean retailers are liable for excise taxes.

International Tax Review
Jul 15, 2019

Survey results: Untangling CFC regimes
Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share their business's operational changes.

International Tax Review
Jul 15, 2019

Survey results: Untangling CFC structures
Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share their business's operational changes.

International Tax Review
Jul 15, 2019

Cryptocurrency, cost basis and taxation
Cryptocurrencies are still capturing the attention of investors, traders and enterprises around the globe, lauded for their potential as a radically transformative force on the existing financial playing field. But legal systems are yet to catch up.

International Tax Review
Jul 12, 2019

France and the US clash over digital service tax plans
The US has ramped up its opposition to France's digital services tax (DST) by opening an investigation into it, but French senators have defiantly approved the so-called ‘GAFA' tax anyway.

International Tax Review
Jul 12, 2019

‘Absolutely shocking': Corporates shaken after Swiss Supreme Court ignores tax ruling
Taxpayers are worried about tax certainty in Switzerland after the Federal Supreme Court ignored an advanced tax ruling in June. This could set a precedent for other cases

International Tax Review
Jul 10, 2019

EU customs head: businesses should embrace, not fear, change
Philip Kermode, the EU's head of customs, says businesses must brace themselves for the modern era of customs, in which data flows are every bit as important as physical border checks.

International Tax Review
Jul 09, 2019

Action 1 and the virtual permanent establishment
Antonio Lanotte explores the BEPS Action 1 report and its influence on modern legislation including the UK's diverted profits tax and India's proposals for taxing the digital economy.

International Tax Review
Jul 08, 2019

DAC6 fixes tax loopholes but confuses taxpayers
Banks are confused about how to follow the ‘vague hallmarks' in the EU mandatory disclosure regime (DAC6).

International Tax Review
Jul 08, 2019

IR35 rules for private sector: Businesses preparing, costs unclear
The next part of the UK's IR35 regulation, which comes into force from April 2020 and is designed to align tax and national insurance (NI) contributions between employees and contractors will cover the private sector. In-house tax heads tell ITR where they are with preparing for this and where the challenges lie.

International Tax Review
Jul 05, 2019

Silicon Valley's leading women in tax tackle ‘world peace'
Finding a solution to taxing the digital economy and getting international agreement could win the OECD the tax equivalent of the Nobel Peace Prize, but thankfully being a female tax leader is easier to achieve, according to speakers and attendees at ITR's Leading Women in Tax Forum in Palo Alto, US.

International Tax Review
Jul 04, 2019

Portugal implements ATAD
Francisco Cabral Matos and Rita Pereira de Abreu of Vieira de Almeida & Associados explain how the EU Anti-Tax Avoidance Directive (ATAD) is being implemented in Portugal.

International Tax Review
Jul 03, 2019

Facebook ups the ante for global cryptocurrency tax framework
The launch of Facebook's Libra currency and discussions at the G20 Summit about financial fraud and tax evasion with digital assets has ‘lit a fire under policymakers' to develop better regulatory responses.

International Tax Review
Jul 01, 2019

Robots are not coming for your job
Tax executives speaking at an International Tax Review event in London say it is a challenge to convince people that technology can be helpful, not distracting.

International Tax Review
Jun 28, 2019

Authorities and taxpayers say ‘rulings have got a bad rep'
As a result of a more disclosure-focused tax environment under rules such as the EU mandatory disclosures and country-by-country reporting, tax directors are shying away from tax rulings and looking for new ways to achieve tax certainty.

International Tax Review
Jun 28, 2019

Deloitte's Philip Mills promoted to global tax and legal leader
London-based Philip Mills has been promoted to global tax and legal leader at Deloitte.

International Tax Review
Jun 28, 2019

Few expect digital tax breakthrough by 2020
Tax experts have told ITR that they do not expect the OECD to achieve consensus on new tax rules by 2020, or maybe ever.

International Tax Review
Jun 25, 2019

OECD won't rush ICAP expansion despite scheme's popularity
The OECD's Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process.

International Tax Review
Jun 24, 2019

Tax heads: DSTs are not illegal or discriminatory
A panel of tax experts surveyed by International Tax Review say digital services taxes (DSTs) are distortive and must be temporary - but few thought they were illegal or discriminatory.

International Tax Review
Jun 23, 2019

The negative aspects of ICAP
While feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems.

International Tax Review
Jun 21, 2019

Tax heads encourage more companies to use ICAP
Tax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month.

International Tax Review
Jun 21, 2019

Residence-by-investment schemes continue to create tax loopholes
A joint investigation by International Tax Review and Practice Insight has uncovered evidence of tax reporting gaps in the way the OECD's Common Reporting Standard (CRS) applies to international securities markets.

International Tax Review
Jun 21, 2019

How do companies measure the performance of their tax department?
Managing tax risk is the most important metric by which tax departments are measured, with the more traditional target of lowering the company's effective tax rate being less important to tax heads. However, CEOs seem to know little about tax KPIs and how, or why, they are chosen.

International Tax Review
Jun 19, 2019

Case study: Repsol's participation in ICAP
Rocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company's participation in the first pilot of the International Compliance Assurance Programme.

International Tax Review
Jun 18, 2019

KPMG US settles PCAOB case for $50 million
KPMG has agreed to pay out as much as $50 million to settle civil claims against former employees who allegedly leaked information from the Public Company Accounting Oversight Board (PCAOB).

International Tax Review
Jun 17, 2019

‘The hunt is on' to find aggressive structures that work
While most companies are moving away from aggressive tax planning, some in-house tax directors say they are still looking for new structures to reduce their effective tax rate (ETR).

International Tax Review
Jun 14, 2019

Brazil's challenge to becoming a member of the OECD
Brazil made a formal application to join the OECD in 2017, but the process is still mired with political uncertainty. BaseFirma's Davi Santana de Jesus outlies how the economy can expedite its application by reforming its transfer pricing framework.

International Tax Review
Jun 14, 2019

Tax professionals: it is time to change the global corporate tax rules
Tax chiefs have used International Tax Review's survey on the taxation of the digital economy to say that international corporate tax rules are not working - but are divided on what should replace them.

International Tax Review
Jun 13, 2019

Euromoney LMG Europe Women in Business Law Awards 2019 - winners announced
The best women lawyers from across the continent gathered at The Savoy in London last night to celebrate Euromoney Legal Media Group's ninth annual Europe Women in Business Law Awards.

International Tax Review
Jun 12, 2019

Case study: Shell's participation in ICAP
Danny Houben, project lead for Shell's ICAP team, talks to International Tax Review about how his company got ready to participate in the OECD's International Compliance Assurance Programme (ICAP).

International Tax Review
Jun 12, 2019

Portugal's stamp duty implications on the liquidation of trusts
The distribution of assets due to a foreign trust liquidation is in principle liable to stamp duty in Portugal. Does such taxation occur in all cases? Diogo Ortigão Ramos and Marta Duarte Silva of Cuatrecasas Portugal discuss.

International Tax Review
Jun 11, 2019

US companies fear TCJA amendments by Democrats
Some US taxpayers are considering inversions because they fear negative tax implications if the Democrats gain control of the presidency and Congress in the 2020 elections and raise the corporate tax rate.

International Tax Review
Jun 11, 2019

Greece reduces VAT on pharmaceutical rebates
After a long-standing debate, Greece's tax authority has reduced the VAT threshold for pharmaceutical rebates. EY Greece's Nikoletta Merkouri discusses the impact for pharmaceutical companies.

International Tax Review
Jun 10, 2019

Businesses disappointed with OECD's digital tax progress
As G20 countries ratify the OECD's work on taxing the digital economy, tax executives expressed their concern to International Tax Review that the body has not moved beyond proposals that they find problematic.

International Tax Review
Jun 10, 2019

Businesses disappointed with OECD's progress on digital tax reforms
As G20 countries ratify the OECD's work on taxing the digital economy, tax executives expressed their concern to International Tax Review that the body has not moved beyond proposals that they find problematic.

International Tax Review
Jun 10, 2019

How global tax reforms apply to the extractive industries
Alexandra Readhead investigates whether IMF and OECD proposals on how to tax the digital economy, apply formulary apportionment, shift taxing rights and address profit shifting could apply to the natural resources sector. Alternatively, could source-based taxation improvements hold the answer?

International Tax Review
Jun 10, 2019

The application of global tax reforms to the extractive industries
Alexandra Readhead investigates whether IMF and OECD proposals on how to tax the digital economy, apply formulary apportionment, shift taxing rights and address profit shifting could apply to the natural resources sector. Alternatively, could source-based taxation improvements hold the answer?

International Tax Review
Jun 07, 2019

Qualified majority voting will drive ‘structural reforms', says EC's tax chief
The European Commission head of company taxation initiatives has told International Tax Review about his hopes and frustrations in EU corporate tax and why he supports qualified majority voting.

International Tax Review
Jun 07, 2019

Qualified majority voting will drive reforms, says EC's tax chief
The European Commission head of company taxation initiatives has told International Tax Review about his hopes and frustrations in EU corporate tax and why he supports qualified majority voting.

International Tax Review
Jun 07, 2019

Taxpayers confident UK will follow EU state aid rules in no-deal Brexit
Taxpayers expect the UK to remain aligned with EU state aid rules in the event of a no-deal Brexit, but many hope any potential future amendments will not stifle investments in UK businesses or negatively impact state aid disputes.

International Tax Review
Jun 06, 2019

Luxembourg's intellectual property box regime: One year later
Luxembourg's new and old IP regimes co-exist while the country gradually aligns itself with international tax standards. Taxpayers should not the criteria for the new intellectual property (IP) box regime.

International Tax Review
Jun 05, 2019

J5 cyber tax crime unit investigating global financial institution
Data scientists and criminal investigators from the Joint Chiefs of Global Tax Enforcement initiative, or the J5, are involved in more than 50 investigations concerning sophisticated international enablers of tax evasion, including one global financial institution and its intermediaries.

International Tax Review
Jun 03, 2019

Tax modelling failing to determine global tax risks effectively
Tax chiefs at Repsol and Baker Hughes said modelling the tax risks across their CFC networks has increased in importance since the BEPS measures were finalised, but a lack of trust in the results and rising compliance costs impede enhancements to tax modelling.

International Tax Review
May 31, 2019

European Commission seeks to end Spanish capital gains tax discrimination
Carlos Durán and Oriol Oliva of Uría Menéndez discuss the implications on Spanish tax regulations of the European Commission's decision that Spain was wrongly taxed the capital gains of companies resident in EFTA states.

International Tax Review
May 31, 2019

OECD to consider worldwide fractional apportionment
The OECD's Inclusive Framework countries have agreed to a 40-page report that outlines potential ways to tax the digital economy. The document suggests, among other measures, introducing worldwide fractional apportionment for corporate profits.

International Tax Review
May 30, 2019

South-East Asian countries get increasingly aggressive
The tax authorities of Indonesia, South Korea, Vietnam, the Philippines and Thailand are causing numerous problems for taxpayers as they get increasingly aggressive in their audits and focus more on transfer pricing, but companies can strategically determine which battles to fight if they choose.

International Tax Review
May 29, 2019

Survey results: Effective IP management
Multinational companies told ITR how they dealt with the challenge of restructuring their intellectual property in a world of tax disputes, greater transparency and new rules.

International Tax Review
May 29, 2019

EU changes VAT liability for transactions facilitated by digital platforms
Digital platforms have until December 2020 to prepare for changes introduced by the EU, which will require digital platforms to pay VAT on behalf of their non-EU sellers and on import of goods into the EU.

International Tax Review
May 28, 2019

Tax heads struggling to monitor all global activities for tax risks
Tax chiefs working at multinational companies that were not designed with a global overview in mind are finding it tough to manage the tax and reputational risks each country poses with limited resources.

International Tax Review
May 24, 2019

A new chapter in Brazil's tax reform
A new Brazilian proposal for tax reform, which is extremely important for the country's development, is under discussion.

International Tax Review
May 24, 2019

Andersen Global's collaborator firm expands UK presence
Birmingham-based firm Claritas Tax has opened an office in Manchester in a move that extends the reach of Andersen Global in the UK.

International Tax Review
May 23, 2019

Jesse Norman becomes financial secretary to UK Treasury
The UK's Transport Minister Jesse Norman will replace Mel Stride as financial secretary to the Treasury and paymaster general.

International Tax Review
May 23, 2019

SEC filings show US MNE uncertainty over long-term impact of TCJA
Financial reports show businesses such as Target and JPMorgan Chase lowering their effective tax rates, but they remain uncertain about the long-term impact of US tax reform, which has limited corporate planning and restructuring.

International Tax Review
May 22, 2019

Conflicts rise over which OECD pillar should come first
Businesses and tax experts involved in the digital tax debate cannot agree over which of the OECD's proposed pillars ought to be implemented first, and whether there is a real need for either.

International Tax Review
May 21, 2019

What taxpayers want from India's GST 2.0
India is undergoing a general election and the future success of the country's goods and services tax (GST) depends heavily on its outcome and how the new government delivers on the industry's wishlist for a better GST, say taxpayers at ITR's Asia Tax Forum.

International Tax Review
May 20, 2019

Companies examining long-term benefits of Swiss tax residence after vote
Taxpayers are relieved the public accepted the government's tax reform proposal, but some are considering whether staying in Switzerland is worth it as the tax system becomes more rigid and costs rise.

International Tax Review
May 20, 2019

US tax experts: Platforms must expect to collect sales tax
Although federal legal precedent is yet to be established, a liability on platform providers to collect sales tax is rapidly becoming the de facto law of the land, experts told International Tax Review.

International Tax Review
May 16, 2019

European Tax Awards 2019: The winners
The winners of International Tax Review's 15th European Tax Awards have been announced.

International Tax Review
May 16, 2019

Reorganisations slow amid vague indirect transfer tax regimes
Uncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganisations.

International Tax Review
May 15, 2019

Taxpayers say India's proposed move to fractional apportionment would intensify disputes
The consultation period for feedback on India's proposed changes to its profit-attribution rules has not yet ended, but the debate around the potential costs and benefits of any change is already hotting up.

International Tax Review
May 13, 2019

Taxpayers caught up in CFC state aid ruling expect UK to appeal
Companies such as the Daily Mail Group, Diageo and the London Stock Exchange are expecting the UK to appeal the EU's state aid decision against the country's CFC group financing regulation, but there is very little time to file a challenge.

International Tax Review
May 13, 2019

As EU countries get a grip on VAT fraud, companies brace for higher compliance costs
Companies in the EU are worried that their compliance costs will increase as tax authorities move to close their VAT gaps and clamp down on fraud, after a recent investigation estimated that carousel fraud is costing EU member states €50 billion ($56 billion) a year.

International Tax Review
May 09, 2019

2019 Asia Tax Awards: The winners
The winners of International Tax Review's 2018 Asia Tax Awards have been announced!

International Tax Review
May 09, 2019

India looks to overseas examples for new e-invoicing regime
After revolutionising its tax system with the introduction of GST in 2017, India will take another big step forward by introducing e-invoicing. But will it be a case of evolution, rather than revolution, this time?

International Tax Review
May 08, 2019

Companies between rock and hard place on digital tax
As details emerge of digital taxes in the Czech Republic and Malaysia, corporates told ITR they wish countries would leave it to the OECD process - but they are fearful of what might emerge from it.

International Tax Review
May 08, 2019

Companies see user participation as a nightmare
Tax professionals are worried about how to identify user participation accurately within any digital business model, particularly given how easy it is for users to hide their true location.

International Tax Review
May 08, 2019

Ashurst promotes London tax partner
Tim Gummer, who joined Ashurst in 2007, has been made partner.

International Tax Review
May 07, 2019

Gately hires tax partner in London
Gately has appointed Jim Hillan to its tax team in London to help advise on areas of corporate tax, real estate tax, share schemes, and VAT.

International Tax Review
May 06, 2019

Jeff Millington joins Withers in London
Withers has appointed Jeff Millington as a tax investigations director to help resolve client tax issues.

International Tax Review
May 03, 2019

Authorities and taxpayers agree: it's best to bare it all
Taxpayers and tax authorities found a surprising amount of common ground on a panel at an ITR conference. They agreed that ‘proactive transparency' is the surest way of avoiding messy disputes, and praised the OECD's ICAP initiative as a means of getting tax certainty.

International Tax Review
May 03, 2019

Tax authorities and companies agree: it's best to bare it all
Taxpayers and tax authorities found a surprising amount of common ground on a panel at an ITR conference. They agreed that ‘proactive transparency' is the surest way of avoiding messy disputes, and praised the OECD's ICAP initiative as a means of getting tax certainty.

International Tax Review
May 03, 2019

MNEs gain tax certainity through document standardisation
Tax directors are dealing with more audits, but standardising global tax operations can greatly ease the burden because it helps tax authorities understand corporate tax positions better.

International Tax Review
May 03, 2019

Italy to stimulate foreign investment with new tax incentives
Italy has implemented a Growth Decree designed to encourage research & development (R&D). Hager & Partners' Gian Luca Nieddu and Barbara Scampuddu discuss the key tax implications of the decrees 32 articles.

International Tax Review
May 03, 2019

India reforms real estate taxes
In April 2019, India implemented GST reform in the real estate sector, seeing rates drop to as low as 1% for some residential sectors. Dhruva Advisors' Ritesh Kanodia and Meetika Baghel discuss the implications for property buyers and developers.

International Tax Review
May 01, 2019

SARS appoints new commissioner
The South African government has appointed Edward Kieswetter as the head of its tax authority. Kieswetter faces the task of restoring public confidence in the revenue service.

International Tax Review
May 01, 2019

Africa leaps into automation for VAT collection on foreign suppliers
African countries are starting to amend legislation and upgrade their IT systems to allow them to charge VAT on imported services. But companies should take solace in tax administrations' willingness to embrace simplified supplier registration regimes.

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