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Employer Losses and Deferred Compensation 雇主损失及递延赔偿
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-07-01 DOI: 10.2139/SSRN.3429803
David I. Walker
Most large public companies offer their executives the opportunity to defer the receipt and taxation of their salary or other current compensation until retirement or some other future date, and equity compensation, which also entails deferral of pay and taxation, constitutes a large fraction of the typical executive pay package. Conventional wisdom holds that employer net operating losses (NOLs) improve the joint economics of deferred and equity compensation (henceforth together "deferred compensation") for the parties. However, empirical studies provide little evidence of an association between employer NOLs and deferred compensation use. This paper focuses on two potential explanations for this apparent disconnect. First, this paper shows that the relationship between employer NOLs and the attractiveness of deferred compensation is more complex and less predictable than is generally recognized, that a large NOL position does not necessarily produce a larger driving force for use of deferred compensation, and that in some cases employer NOLs can actually result in poorer deferred compensation economics. As a result, some employers and executives may rationally choose to ignore employer NOLs when making compensation decisions. Second, even if companies are sensitive to the existence of employer NOLs when making compensation decisions, it is not clear that research methods currently in use would detect the sensitivity. The commonly used proxies and simulations of employer effective marginal tax rates that have been employed in these studies may not adequately capture the complexity of the relationship between NOLs and the economics of deferred compensation.
大多数大型上市公司为其高管提供机会,将他们的工资或其他当前薪酬的领取和纳税推迟到退休或其他未来的某个日期,而股权薪酬也需要推迟支付薪酬和纳税,这在典型的高管薪酬方案中占很大比例。传统观点认为,雇主净经营亏损(NOLs)提高了双方递延薪酬和股权薪酬(以下统称“递延薪酬”)的联合经济性。然而,实证研究提供了很少的证据,雇主nol和递延薪酬使用之间的关联。本文着重于对这种明显脱节的两种可能的解释。首先,本文表明,雇主不良资产与递延薪酬吸引力之间的关系比通常认为的更复杂,更难以预测,大量的不良资产头寸并不一定会产生使用递延薪酬的更大驱动力,在某些情况下,雇主不良资产实际上会导致较差的递延薪酬经济学。因此,一些雇主和高管在做出薪酬决策时,可能会理性地选择忽略雇主的nol。其次,即使公司在做出薪酬决策时对雇主nol的存在敏感,也不清楚目前使用的研究方法是否会检测到这种敏感性。在这些研究中使用的雇主有效边际税率的常用代理和模拟可能无法充分反映nools与递延补偿经济学之间关系的复杂性。
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引用次数: 9
China’s Surprising Silence on Digital Taxation 中国对数字税收出奇的沉默
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-06-24 DOI: 10.2139/ssrn.3428911
Yue Dai
The article demonstrates why China has been relatively absent from international debates on digital taxation and concludes that while China is likely to favor a minimum effective tax approach, it will look to other countries to direct the reform.
这篇文章说明了为什么中国相对缺席关于数字税收的国际辩论,并得出结论,尽管中国可能倾向于最低限度有效的税收方法,但它将寻求其他国家指导改革。
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引用次数: 2
Property Tax Exemptions for Nonprofit Hospitals: What are They Worth? Do They Earn Them? Evidence from New York City 非营利性医院的房产税减免:它们值多少钱?他们是自己挣来的吗?来自纽约的证据
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-06-01 DOI: 10.1111/pbaf.12216
Geoffrey Propheter
This study estimates the property tax expenditure for nonprofit hospitals (NPHs) in New York City using Medicare and IRS data from 2011 through 2013. After comparing the estimates to various definitions of community benefits, it is concluded that NPHs generally earn their property tax break. Evidence is also presented that using book values is a reasonably accurate method for estimating the property tax expenditure nationwide. Finally, econometric analyses reveals that net income is negatively associated with community benefits, suggesting justification for taxing higher net income hospitals and reallocating the funds to similarly sized but lower net income hospitals.
本研究利用2011年至2013年的医疗保险和美国国税局数据估算了纽约市非营利性医院(NPHs)的财产税支出。在将估算值与各种社区福利定义进行比较后,得出的结论是,nph通常可以获得房产税减免。也有证据表明,使用账面价值是估算全国财产税支出的一种相当准确的方法。最后,计量经济学分析显示,净收入与社区福利呈负相关,这表明有理由对净收入较高的医院征税,并将资金重新分配给同样规模但净收入较低的医院。
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引用次数: 2
Behavioural Responses to the (Re)Introduction of Wealth Taxes. Evidence From Spain 对(重新)引入财富税的行为反应。来自西班牙的证据
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-05-23 DOI: 10.2139/ssrn.3393016
J. Duran-Cabré, Alejandro Esteller-Moré, Mariona Mas-Montserrat
In the throes of economic crisis, the Spanish government decided to reintroduce the Wealth Tax, appealing to redistributive motives and its need for greater revenues. This paper studies how individuals reacted to the reintroduction of this tax by drawing on the universe of wealth tax returns submitted to the Catalan Tax Agency between 2011 and 2015. Thus, we exploit the variation in treatment exposure to analyse taxpayers' responses, in terms not only of wealth accumulation, but also of the potential avoidance strategies adopted. Indeed, our results reflect avoidance rather than real responses. They show that while facing higher wealth taxes did not have a negative effect on taxpayers' savings, it did encourage them to change their asset and income composition to take advantage of wealth tax exemptions (mostly business-related) and the existence of a limit on wealth tax liability. This translates into an elasticity of taxable wealth with respect to the net-of-tax rate of return of 0.64, or, put differently, a 0.1 percentage point increase in the average wealth tax rate leads to a reduction in taxable wealth of 3.24% over 4 years. Overall, these avoidance responses are quite marked in terms of tax revenues: they represent a 4-year accumulated revenue loss of 2.6 times the 2011 estimated wealth tax revenues. The existence of such responses mostly related to the design of the wealth tax has relevant policy implications not only in terms of revenues but also insofar as it undermines the tax's redistributive role.
在经济危机的阵痛中,西班牙政府决定重新引入财富税,呼吁再分配动机和增加收入的需要。本文通过利用2011年至2015年期间提交给加泰罗尼亚税务局的财富税申报表,研究了个人对这项税收的重新引入的反应。因此,我们利用治疗暴露的变化来分析纳税人的反应,不仅在财富积累方面,而且在采取的潜在避免策略方面。事实上,我们的结果反映的是回避而不是真实的反应。他们表明,尽管面临更高的财富税对纳税人的储蓄没有负面影响,但它确实鼓励他们改变自己的资产和收入构成,以利用财富税豁免(主要与商业有关)和财富税责任限制的存在。这意味着应税财富相对于净税率回报率的弹性为0.64,或者换句话说,平均财富税率每提高0.1个百分点,4年内应税财富就会减少3.24%。总的来说,这些避税反应在税收方面相当明显:它们代表着4年累计收入损失是2011年估计财富税收收入的2.6倍。这种反应的存在主要与财富税的设计有关,不仅在收入方面,而且在破坏税收的再分配作用方面,都具有相关的政策影响。
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引用次数: 49
After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left to Live on? 在缴纳超高净值财富税后,亿万富翁还能靠多少钱生活?
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-05-15 DOI: 10.2139/SSRN.3340925
M. Simkovic
Part I: Billionaire Taxes, https://ssrn.com/abstract=3326615. Part II: Taxes Spending and Innovation, https://ssrn.com/abstract=3335386. How much can a passive investor with a high-risk tolerance earn on his or her capital? If history since the end of World War 2 is any guide, between 11 and 14 percent per year before taxes and inflation. After inflation, this comes to around 7 to 10 percent. With good tax planning, the rate of return net of income taxes, inflation, and fees could average around 6.5 to 9.5 percent per year. A family with $100,000,000 ($100 million) in wealth would pay an additional $1 million in taxes per year under Senator Elizabeth Warren’s ultra-high-net-worth tax proposal. That would reduce their after-tax disposable income to $5.5 million to $8.5 million per year. To put this into context, according to the Survey of Consumer Expenditures, households in the top 10 percent of income earned an average of $189,000 after taxes and spent on average $143,000 in 2017. Even after paying Warren’s wealth tax, a household with $100 million in assets could spend 38 to 59 times as much as a relatively high-income household. A household with a $100 million net-worth that lived modestly and spent only as much as the average household in the top 10 percent of income could reinvest $5.36 million to $8.36 million per year, growing their net-worth by 5.36% to 8.36% per year, on average. This is $5.32 million to $8.32 million more in annual savings than the average top-10 percent household. The analysis above implies that Warren’s proposed 2% to 3% ultra-high net-worth wealth tax would only slightly slow the increase in high-end wealth inequality but would not halt or reverse it. At a 5.36% return after taxes, inflation, and personal consumption, a fortune would quadruple in value every 27 years, and would therefore not be dissipated by typical family growth rates. (At 8.36%, it would quadruple in value every 18 years). Under Warren’s proposal, a household with $1 billion in wealth would pay an additional $19 million in taxes per year. After paying the wealth tax, other taxes, and reinvesting to stay ahead of inflation, our billionaire family would be still be able to spend approximately $46 million to $76 million per year, forever, without anyone in the family having to work a job. Every extra billion in wealth (above $1 billion) would translate into an additional $35 million to $65 million in disposable income per year, after taxes and fees and reinvesting to stay ahead of inflation. If policy makers wanted to cap personal wealth from purely passive investing at $1 billion, but did not want to tax the first $50 million in wealth, they would have to annually tax wealth above $50 million at around 12%. Assuming effective enforcement, this would potentially generate somewhere in the vicinity of $1 trillion in revenue per year. This is about enough to replace most payroll tax revenue and thereby give every worker in the co
第一部分:亿万富翁税,https://ssrn.com/abstract=3326615。第二部分:税收、支出和创新,https://ssrn.com/abstract=3335386。一个具有高风险容忍度的被动投资者可以从他或她的资本中赚多少钱?如果二战结束以来的历史可以作为参考的话,扣除税收和通货膨胀,每年的增长率在11%到14%之间。在通货膨胀之后,这个数字大约是7%到10%。如果有良好的税务规划,扣除所得税、通货膨胀和费用后的净回报率平均每年约为6.5%至9.5%。根据参议员伊丽莎白·沃伦的超高净值税收提案,一个拥有1亿美元财富的家庭每年将额外支付100万美元的税款。这将使他们的税后可支配收入减少到每年550万至850万美元。根据消费者支出调查,2017年,收入最高的10%的家庭平均税后收入为18.9万美元,平均支出为14.3万美元。即使在缴纳了沃伦的财富税之后,一个拥有1亿美元资产的家庭的支出也可能是一个相对高收入家庭的38到59倍。一个拥有1亿美元净资产的家庭,如果生活简朴,消费水平只相当于收入前10%的普通家庭,每年可以再投资536万至836万美元,平均每年将使他们的净资产增长5.36%至8.36%。这比收入最高的10%的家庭平均每年多节省532万到832万美元。上述分析表明,沃伦提出的2%至3%的超高净值财富税只会略微减缓高端财富不平等的加剧,但不会阻止或扭转这一趋势。扣除税收、通货膨胀和个人消费后的回报率为5.36%,一笔财富的价值每27年就会翻两番,因此不会被典型的家庭增长率所消耗。(8.36%,相当于每18年翻四倍)。根据沃伦的提议,一个拥有10亿美元财富的家庭每年将额外支付1900万美元的税款。在支付了财富税和其他税,并进行再投资以应对通货膨胀之后,我们的亿万富翁家族每年仍然可以花费大约4600万到7600万美元,而且永远不会有任何家庭成员需要工作。每增加10亿美元(超过10亿美元)的财富,扣除税费和再投资(以避免通胀)后,每年将增加3,500万至6,500万美元的可支配收入。如果政策制定者希望将个人财富从纯粹的被动投资中限制在10亿美元,但又不想对财富的前5000万美元征税,那么他们就必须每年对5000万美元以上的财富征收12%左右的税。假设有效的执法,这可能每年产生大约1万亿美元的收入。这笔钱足以取代大部分的工资税收入,从而使全国每个工人的收入达到第一个13万美元时,工资都有两位数的百分比增长,或者为每个雇主节省等额的劳动力成本。每年5%至10%的财富税与对冲基金和私募股权基金经理奖励性薪酬的门槛税率类似,只有当财富经理创造的回报超过了他们以最低技能和很少努力所能实现的回报时,他们才会得到奖励。类似的超高净值财富税率,可能有助于区分长期有才能的投资者、领导者或企业家,以及那些财富增长是过去成功和好运的结果的人。与这种明显的精英政策形成鲜明对比的是,沃伦对5000万美元以上人群征收2%的财富税,对10亿美元以上人群征收3%的财富税,这一相对温和的税率将使被动投资的超级富豪家庭每年获得数百万或数千万美元的财富,从而保持家庭财富带来的自由和安全。
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引用次数: 0
How Do Place-Based Investment Tax Incentives Target Low-Income Communities? A Multi-State Survey of Enterprise Zone Tax Incentives 基于地的投资税收优惠如何针对低收入社区?多州企业园区税收优惠调查
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-05-01 DOI: 10.2139/SSRN.3381243
Michelle D. Layser
Place-based investment tax incentives known as enterprise zone laws have historically been used as a method for subsidizing investment in low-income communities. Scholarly and policy treatments of enterprise zone laws commonly discuss them as if there is a unified approach to designing these programs. This report finds, however, that although most (33/50) states have enterprise zone laws, these programs vary significantly in important respects — including zone eligibility requirements; eligible investment types; incentives to invest in human capital or affordable housing; and taxpayer eligibility. Understanding these variations is particularly important to understanding how past experience with enterprise zones can inform new place-based incentives, such as those that have been introduced in the federal Opportunity Zones program.
以地方为基础的投资税收优惠,即企业区法律,历来被用作补贴低收入社区投资的一种方法。学术和政策对企业园区法律的处理通常讨论它们,好像有一个统一的方法来设计这些程序。然而,本报告发现,尽管大多数州(33/50)都有企业园区法律,但这些计划在重要方面差异很大——包括园区资格要求;符合条件的投资类型;鼓励投资人力资本或经济适用房;以及纳税人的资格。了解这些变化对于理解过去的企业区经验如何为新的基于地点的激励机制提供信息,例如那些已经在联邦机会区计划中引入的激励机制,尤为重要。
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引用次数: 0
Global Corporate Tax Rate Competition - Who Pays the Bill? 全球企业税率竞争——谁买单?
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-04-25 DOI: 10.2139/SSRN.3387544
G. Almeida
Countries heavily rely on tax revenue for their welfare programs, which aim to reduce inequalities. Taxes are countries’ main sources of revenue and provide funding for governmental expenditures. A country’s spending is usually divided into categories: mandatory, discretionary, and interest on debt expenditures. These include assistance programs, such as the United States’ Medicaid program, the Supplemental Nutrition Program (so-called foods stamps), and the Temporary Assistance for Needy Families program. The United States lowered its U.S. corporate income tax rate from 35% to 21% in 2018, after the enactment of the United States Tax Cuts and Jobs Act. Similarly, members of the Organization for Economic and Co-operation and Development (OECD) lowered their corporate statutory tax from their 2000 average rate of 28.6% to 21.4% in 2018. In the international context, state-to-state tax arbitration is implemented by OECD members to provide multinationals with double tax relief. In contrast, individuals do not benefit from a similar tax reduction. The United States’ highest marginal income tax rate was reduced from 39.60% to 37% in 2018, whereas 0.5% was the average reduction implemented for individuals by OECD members from 2000 to 2017. This paper analyzes whether states expect private corporations to undertake more social responsibility when considering tax benefits. States’ examination of corporates’ social responsibility includes whether private social accountabilities align with corporations’ profit-oriented natures as well as state interest in public welfare. Furthermore, this paper examines states’ alternative sources of revenues that could balance out the effects of the reduction of corporations’ tax rates and other granted benefits, including tax arbitration for multinationals’ double tax relief.
各国的福利计划严重依赖税收收入,旨在减少不平等现象。税收是国家收入的主要来源,为政府支出提供资金。一个国家的支出通常分为三类:强制性支出、可自由支配支出和债务利息支出。这些包括援助项目,如美国的医疗补助计划、补充营养计划(所谓的食品券)和贫困家庭临时援助计划。美国在《美国减税与就业法案》颁布后,于2018年将美国企业所得税税率从35%降至21%。同样,经济与合作与发展组织(OECD)成员国将企业法定税率从2000年的平均28.6%降至2018年的21.4%。在国际背景下,经合组织成员国实施国与国之间的税收仲裁,为跨国公司提供双重税收减免。相比之下,个人无法从类似的减税中受益。2018年,美国最高边际所得税率从39.60%降至37%,而经合组织成员国在2000年至2017年期间对个人实施的平均减税为0.5%。本文分析了国家在考虑税收优惠时是否期望私营企业承担更多的社会责任。国家对企业社会责任的审查包括私人社会责任是否与企业的利润导向性质以及国家的公共福利利益相一致。此外,本文还考察了各州的其他收入来源,这些收入来源可以平衡公司税率降低和其他授予福利的影响,包括跨国公司双重税收减免的税收仲裁。
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引用次数: 0
Policy Forum: International Effects of the 2017 US Tax Reform -- A View from the Front Line 政策论坛:2017年美国税改的国际效应——来自前线的观点
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-04-23 DOI: 10.32721/CTJ.2019.67.1.PF.HARRIS
P. Harris, M. Keen, L. Liu
Proximity and close economic links put Canada on the front line in thinking through the effects of the US Tax Cuts and Jobs Act (TCJA). This article reviews the main channels by which the business tax provisions of the TCJA might affect Canada, and possible responses.
邻近和密切的经济联系使加拿大在考虑美国减税和就业法案(TCJA)的影响时处于第一线。本文回顾了营业税条款可能影响加拿大的主要渠道,以及可能的应对措施。
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引用次数: 1
Zero Economic Value Humans? 零经济价值人类?
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-04-19 DOI: 10.2139/ssrn.3356677
Hilary G. Escajeda
The decades ahead will bring forth a convergence of increasingly capable technologies, such as artificial intelligence and robotics, that will fundamentally reshape and transform work environments by replacing average humans with ordinary job skills. Klaus Schwab, Founder of the World Economic Forum and author of The Fourth Industrial Revolution, perceptively identifies this impending paradigm shift and argues these technologies will challenge policymakers to “think strategically about the forces of disruption and innovation shaping our future.” This challenge, however, extends beyond the political realm, as emerging technologies will change our human existence. For example, Pope Francis’ 2015 Laudato Si’: On Care for Our Common Home echoed similar concerns to Schwab. His Holiness warns that technological progress that replaces the need for human-performed work would be “detrimental to humanity” because work provides dignity through the development of talents and community relationships. As technology disintermediates humans from market transactions, tax policies should rethink the purpose of paid work and focus on furthering vocational opportunities outside the traditional employment context. While innovators, such as Bill Gates, have suggested imposing a “robot tax” to fund displaced-worker retraining programs, the implementation of new tax policies alone will not foster and protect worker dignity. A solution must be crafted to provide humans with meaningful work opportunities. Policymakers will need to think strategically and balance individual economic interests with community concerns about income inequality. To mitigate the disruptive nature of the fourth industrial revolution, forward-focused tax policies should be designed and then refined to promote meaningful work and protect human dignity.
未来几十年,人工智能和机器人等能力越来越强的技术将汇聚一堂,这些技术将从根本上重塑和改变工作环境,用普通的工作技能取代普通人。世界经济论坛创始人、《第四次工业革命》(the Fourth Industrial Revolution)一书的作者克劳斯·施瓦布(Klaus Schwab)敏锐地发现了这种即将发生的范式转变,并认为这些技术将挑战政策制定者“从战略上思考影响我们未来的破坏和创新力量”。然而,这一挑战超出了政治领域,因为新兴技术将改变我们人类的生存。例如,教宗方济各2015年发表的《赞美你》(Laudato Si):关于关爱我们共同的家园,呼应了施瓦布的类似担忧。尊者警告说,技术进步取代了对人类工作的需求,这将“对人类有害”,因为工作通过发展才能和社区关系提供了尊严。随着技术将人类从市场交易中剥离出来,税收政策应重新思考有偿工作的目的,并将重点放在促进传统就业环境之外的职业机会上。虽然比尔·盖茨(Bill Gates)等创新者建议征收“机器人税”,为失业工人的再培训项目提供资金,但仅靠实施新的税收政策并不能促进和保护工人的尊严。必须精心设计一个解决方案,为人类提供有意义的工作机会。政策制定者需要进行战略性思考,平衡个人经济利益和社会对收入不平等的担忧。为了减轻第四次工业革命的破坏性,应该设计并完善前瞻性的税收政策,以促进有意义的工作和保护人类尊严。
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引用次数: 0
Measuring Corporate Tax Rate and Tax Base Avoidance of U.S. Domestic and U.S. Multinational Firms 衡量美国国内公司和美国跨国公司的公司税率和税基规避
IF 0.3 Q4 Economics, Econometrics and Finance Pub Date : 2019-04-18 DOI: 10.2139/ssrn.3374548
Niklas Lampenius, T. Shevlin, Arthur Stenzel
Recent empirical evidence suggests that domestic firms avoid taxes at least to the same extent as multinational firms. We extend this finding by developing an approach to estimate the average statutory tax rate from publicly available data that implicitly weights all statutory tax rates a firm is exposed to by the corresponding taxable income. Based on this new approach we decompose tax avoidance into two separate components: tax-rate avoidance and tax-base avoidance. We find that U.S. multinational firms make substantial use of tax-rate avoidance, for instance, their foreign average statutory tax rates decrease from 1988 by 0.6 percentage points each year to around 16 percent in 2014. U.S. domestic firms by definition do not take advantage of low tax rates in non-U.S. countries, however, we find that U.S. domestic firms make substantial use of tax-base avoidance and are more effective in tax-base avoidance than U.S. multinational firms. Overall, our findings on tax-rate and tax-base avoidance of U.S. multinational and domestic firms explain the recent evidence that effective tax rates of domestic firms are at least as low as effective tax rates of multinational firms and substantiate existing doubts that multinational firms, in particular, are the most aggressive tax avoiders.
最近的经验证据表明,国内公司避税的程度至少与跨国公司相同。我们通过开发一种方法来扩展这一发现,该方法从公开可用的数据中估计平均法定税率,该数据隐含地根据相应的应税收入对公司面临的所有法定税率进行加权。基于这种新方法,我们将避税分解为两个独立的部分:税率避税和税基避税。我们发现,美国跨国公司大量利用避税手段,例如,它们的外国平均法定税率从1988年每年下降0.6个百分点,到2014年下降到16%左右。根据定义,美国国内公司不会利用美国以外国家的低税率。然而,我们发现美国国内公司大量利用避税税基,并且在避税税基方面比美国跨国公司更有效。总的来说,我们关于美国跨国公司和国内公司的税率和税基避税的研究结果解释了最近的证据,即国内公司的有效税率至少与跨国公司的有效税率一样低,并证实了现有的怀疑,特别是跨国公司是最积极的避税者。
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引用次数: 11
期刊
EJournal of Tax Research
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