1. CONCEPT OF ATTRIBUTION



TRUSTS – COMPLEX ISSUES(TXN 4862 ONLY)Contents TOC \o "1-3" \h \z \u 1. CONCEPT OF ATTRIBUTION PAGEREF _Toc325714801 \h 22.TRUSTS AND CAPITAL GAINS PAGEREF _Toc325714802 \h 32.1 PARAGRAPH 68 – SPOUSES AND CAPITAL GAINS FROM DONATIONS RECEIVED FROM SPOUSES PAGEREF _Toc325714803 \h 32.2 PARAGRAPH 69 – MIINOR CHILDREN AND CAPITAL GAINS FROM DONATIONS FROM THEIR PARENTS PAGEREF _Toc325714807 \h 42.3 PARAGRAPH 70 – CONTINGENT RIGHTS TO CAPITAL GAINS PAGEREF _Toc325714812 \h 72.4 PARAGRAPH 71 – CAPITAL GAINS WHERE THE DONOR RETAINS THE RIGHT TO CHANGE BENEFICIARIES PAGEREF _Toc325714817 \h 82.5 PARAGRAPH 72 – NON RESIDENTS AND CAPITAL GAINS PAGEREF _Toc325714819 \h 93. DISTRIBUTIONS TO NON RESIDENTS BY TRUSTS PAGEREF _Toc325714821 \h 104. ATTRIBUTION EXAMPLES WITH INCOME AND CAPITAL GAINS INTEGRATED PAGEREF _Toc325714822 \h 115. DISTRIBUTION OF ASSETS OUT OF A TRUST PAGEREF _Toc325714824 \h 15Prior to doing this chapter, the introduction chapter on trusts should be done1. CONCEPT OF ATTRIBUTIONIn addition to reading the below, please refer to Par 73 of the Eighth Schedule.The Income Tax Act raises the concept of attribution. Attribution considers whether a limit should be placed on the amount of income and capital gain transferred from the “beneficiary” to the donor. Consider the followinga mother has a minor son of 16 years old who is a genius on the stock exchangeshe lends R1,000,000 interest free to her son on 1 April.Her son trades actively with the money and at 1 October has R2,300,000 in equity. At this date, the R1,000,000 is repaid back to his mother.Had the mother not given the money to her son, she could have invested the money in the bank earning 10% interest.The son has earned money due to 2 reasonsThe loan given by his mother andHis own ability in investing on the stock exchangeAttribution works on the following basis:If the money was placed in a bank, the mother would have earned 1,000,000 X 6/12 X 10% = R50,000This is called an attribution limit and this is the most the mother can be taxed on.R50,000 income will be taxed in the hands of the mother as per section 7(3) and the remaining R1,300,000 – R50,000 = R1,250,000 will be taxed in the hands of the son. As can be seen, attribution sets a limit as to the amount of income and capital gains can be “attributed” to the donor.However is attribution supported in law?In terms of case law derived from Woulidge vs CIR, where a donor either makes a donation, or similar gratuitous disposition (such as a low interest or interest free loan), section 7 may apply. The parent may not be taxed on deemed income which exceeds the reasonable market related interest which he could have received had he/she invested that amount. Paragraph 73 of the 8th schedule limits the amount of capital gains that may be “attributed” to a donor.Thus the concept of attribution is supported in law for:Amounts of income received by beneficiaries from donations or similar dispositions ANDAmounts of capital gains received by beneficiaries from donations or similar dispositions2.TRUSTS AND CAPITAL GAINSJust as section 7 applies to income earned as a consequence of a donation or similar gratuitous disposal, there is a similar application for capital gains tax. For capital gains tax purposes, various paragraphs of the 8th schedule deem capital gains earned by the donee to be taxed in the donors hands.Par 80 of the Eighth Schedule discusses the tax treatment of transactions which result in capital gains/losses.Par 80(1) deals with the situations where an asset in a trust vests in a beneficiary. When an asset vests in a beneficiary it is a disposal for CGT purposes and a capital gain/loss should be calculated. It notes that such capital gains should be disregarded in the hands of the trust and instead taxed in the hands of the beneficiary (must be a resident) to whom the asset was disposed to. It is important to note that the section notes that its provisions are subject to paragraphs 68, 69, 71 and 72, which will be discussed below.It is also important to note that this section requires there to be a vesting by a trust.Par80(2) deals with the situation where the gain on the disposal of an asset vests in a beneficiary but the beneficiary does not receive the asset. The asset may, for example, be sold to a third party and the proceeds will go to the beneficiary. This is different from par 80(1) where the asset is actually transferred to the beneficiary. Similar to par 80(1) this paragraph states that any capital gains must be disregarded for the trust and must be taken into account when calculating the aggregate capital gains of the beneficiary (must be a resident). Again, the provisions in this paragraph are subject to paragraphs 68, 69, 71 and 72.It is also important to note that this section requires there to be a vesting by a trust.Note that paragraph 70 is not mentioned. This is due to the fact that this section refers to conditions and there are no beneficiaries with vested rights. Par 80(1) and 80(2) requires a vested right.It is also important to note that the above sections refer only to capital gains. Any capital losses which are calculated on these disposals are retained in the trust and will NOT be transferred to the beneficiary in whom the asset (or the proceeds) has vested.2.1 PARAGRAPH 68 – SPOUSES AND CAPITAL GAINS FROM DONATIONS RECEIVED FROM SPOUSESParagraph 68 (similar to 7(2)) deems the capital gain earned as a result of a donation or similar gratuitous disposal to a spouse to be taxed in the hands of the donor if the transaction was done to avoid taxation. Paragraph 68 will not apply when transactions are not done to avoid taxation.Paragraph 68 also notes that if a capital gain arises from a trade carried on by spouses, such as in a partnership, and the spouse is entitled to a specific share, say 60%, of the partnership but receives 70% of the capital gain on an asset, then the excessive amount (10%) will be taxed in the hands of the spouse to whom it belongs.ILLUSTRATION – SPOUSES AND CGTMr A is currently taxed at the maximum marginal rate of 40%. He also currently utilizes his full annual exclusion for CGT. His wife does not work and has no capital gains attributable to her. Mr A had bought some shares for R100,000 on 1 November 2001. The shares were now worth R530,000. Instead of selling them in his name, he donates the shares to his wife, who will in turn sell the shares for R530,000. He is of the belief that this will avoid taxation. Ignore attribution rulesDiscuss the taxation implications if:this was not done mainly to avoid taxationthis was done mainly to avoid taxationSUGGESTED SOLUTIONPart aParagraph 67 of the 8th schedule would apply and Mrs A will get the asset at the base cost to Mr A. She will sell the shares for R530,000 and her base cost will be R100,000.Mrs A will make a capital gain of R430,,00. She will claim the annual exclusion of R30,000 (2012: R2,000). 33.3% (2011: 25%) of the remaining capital gain of R400,000 will be included in her taxable income being R133,333.(400,000 X 33.3333%)The amount will not be taxed in the hands of the donor as the donation was not to avoid taxation.Part bIf the transaction was mainly for the purposes of reducing taxation, the entire R430,000 will be deemed to be a capital gain of Mr A and will be taxed in his hands in accordance with paragraph 68 of the 8th schedule.2.2 PARAGRAPH 69 – MIINOR CHILDREN AND CAPITAL GAINS FROM DONATIONS FROM THEIR PARENTSParagraph 69 (similar to 7(3) and 7(4)) deems the capital gain earned as a result of a donation or similar gratuitous disposal to a minor child of that parent or via a cross donation to a minor child of that parent to be taxed in the hands of the donor.ILLUSTRATION – MINOR CHILDMr A donates foreign shares to his 15 year old minor child on 1 November 2011. The shares had a market value of R80,000 on this date. Mr A paid the requisite donations taxation. The foreign shares paid dividends of R4,000 on 1 April 2012 and R5,000 on 1 September 2012. During the current tax year, on 1 October 2012, the shares were sold by his minor child for R91,000.Assume interest rate for the past 2 years is 10% and assume the donation was on 1 March 2011 and the shares were sold on 28 February 2013.What are the taxation implications of the above?Would the taxation implications change if the minor child was married on 1 June 2012.Would the taxation implications change if the parent died on 1 June 2012.SUGGESTED SOLUTION Part aThe R4,000 and R5,000 foreign dividend earned from March to September will be included in the taxable income of the parent per the application of section 7(3) of the Act. Mr A may utilize s10B to determine whether all or part of the foreign dividends are exempt from tax.The capital gain is R91,000 – R80,000 = R11,000. A capital gain of R7,000 (limited by attribution see working below) will also be included in the hands of the parent per the application of paragraph 69 of the 8th schedule as it arose from a donation from a parent to a minor child.Attribution workingsAttribution year 110% X 80,000 X 12/12 8,000Income taxed in donors hands year 1(4,000)Attribution carried forward 4,000Balance carried forward 4,000Attribution year 210% X 80,000 X 12/12 8,000Income taxed in donors hands(5,000)Maximum capital gains taxed in hands of the donor(7,000) Nil Part bWhen a minor child gets married, they become a major. The effect is that section 7(3) and paragraph 69 will no longer apply.The R4,000 dividend will be taxed in the hands of the parent per section 7(3). However the R5,000 foreign dividend and the R7,000 capital gain will be taxed in the hands of the child as the child is no longer a minor when such amounts are attributed to him.Part cWhen a person dies, section 7(3) and paragraph 69 no longer apply as the donor is dead. The R4,000 dividend will be taxed in the hands of the parent per section 7(3). However the R5,000 foreign dividend and the R7,000 capital gain will be taxed in the hands of the child as the donor is no longer alive and therefore normal rules will apply.2.3 PARAGRAPH 70 – CONTINGENT RIGHTS TO CAPITAL GAINSParagraph 70 (similar to 7(5)) deems capital gains earned as a result of a donation or similar gratuitous disposal that do not vest in beneficiaries to be taxed in the donor’s hands if There is a condition that causes the capital gain not to vest in a beneficiary until the happening of a future later event,A capital gain has arisen in the current year, which does not vest in a beneficiary, The person who made the donation is a SA resident who has been resident in SA throughout the whole year, andThe capital gain arose as a result of a donationILLUSTRATION – CONTINGENT RIGHTS TO THE CAPITAL GAINSMr A donates a holiday home to a trust . The trust is for the benefit of his grandson Master B. There is a condition that the proceeds of the trust will not be given to Master B if he gets married prior to his 25th birthday. In that case the proceeds of the trust will go to Mr C. Master B is currently 16 years old. The house gets sold this year and a capital gain of R200,000 is made. Will the provisions of paragraph 70 be applicable to the above?Would the solution have changed if the capital gain actually vested in the beneficiary?Would the provisions of paragraph 70 have been applied if the house was sold and a capital loss was made?Ignore attributionSUGGESTED SOLUTION Part aA capital gain has been made in the trust. The question is whether the provisions of paragraph 70 may apply to this transaction. The provisions of paragraph 70 will apply to this transaction as:There is a condition that causes the capital gain not to vest in a beneficiary until the happening of a future later event,A capital gain has arisen in the current year, which does not vest in a beneficiary, The person who made the donation is a SA resident who has been resident in SA throughout the whole year, andThe capital gain arose as a result of a donationPart bIf the capital gain actually vests in a beneficiary, the capital gain will be taxed in the hands of a beneficiary. Paragraph 70 will not be applied.Part cIf a capital loss is made, the capital loss will not be taxed in accordance with paragraph 70 in the hands of the donor. Paragraph 70 only applies to capital gains.2.4 PARAGRAPH 71 – CAPITAL GAINS WHERE THE DONOR RETAINS THE RIGHT TO CHANGE BENEFICIARIESParagraph 71 deems the capital gain earned as a result of a donation or similar gratuitous disposal to a person where the donor retains the right to change a beneficiary, to be taxed in the hands of the donor. It is important to note that the donor must be a resident throughout the entire year of assessment for this to apply. However Par72 will kick in when this happens. ILLUSTRATION – RIGHT TO CHANGE BENEFICIARYMr A gives his grandson master B a 50% share in his business subject to the condition that he can take back the 50% share at any time and confer the share upon anybody else of his choice.During the current year, the business made R100,000 profit and also realised capital gains of R60,000. The business was conducted fully in SA.What are the taxation implications for Mr A and for his grandson?Would the taxation implications change if Mr A was only a resident for part of the tax year.Ignore attributionSUGGESTED SOLUTIONPart aThe business does not seem to be incorporated and as such any profits or capital gains will be taxed in the hands of the owners of the business. Mr A and Master B own 50% of the business and as such will be entitled to R50,000 income and R30,000 capital gains each. However the terms of section 7(6) will apply to the revocation of income in that the R50,000 earned by Master B will be taxed in the hands of Mr A. In addition, the R30,000 capital gain will be taxed in Mr A’s hands as the terms of paragraph 71 apply in that:the donation confers a right on a beneficiary who is a residentto receive a capital gain attributable to the donation,that right can be revoked or conferred upon another by the person who conferred it, andsuch capital gain vested in the beneficiary during the year of assessment which the person who conferred the right has been a resident and has retained the power to revoke that right.Thus the full R100,000 income and R60,000 capital gain will be taxed in the hands of the grandfather.Part bThe provisions of paragraph 71 do not apply unless the donor is resident throughout the year. But paragraph 72 will apply (see later in the notes)The full R100,000 income will still vest in the hands of Mr A as per part a as the income is sourced in SA.2.5 PARAGRAPH 72 – NON RESIDENTS AND CAPITAL GAINSParagraph 72 deems the capital gain earned as a result of a donation or similar gratuitous disposal to a non resident to be taxed in the hands of the donor.ILLUSTRATION – NON RESIDENTMr A donated shares to his major son who is a non resident when the value of the shares was R100,000 on 1 January 1999. The shares were valued at R300,000 on 1 October 2001 when referring to the government gazette prices for listed shares.The shares were sold by his major son in the current year for R800,000.What are the taxation implications. Neither Mr A nor his son are sharedealers.Would the taxation implications change if Mr A had donated it to his major son while his son was still an SA resident and when his son emigrated the shares were valued at R600,000.Assume that paragraph 73 of the 8th schedule will not reduce any amount of capital gain attributable to a donor.Ignore attributionSUGGESTED SOLUTIONPart aThe provisions of paragraph 72 of the 8th schedule will apply and the R500,000 capital gain will be taxed in the hands of the father.Part bWhen his son emigrates from the Republic, he will be deemed to dispose of the shares and buy them back at that date. Thus when he left the Republic, capital gain of R300,000 would have been included in the hands of Mr A’s son. The proceeds from the sale of the shares are R800,000. The base cost attributable to the shares will be R600,000. There will be a capital gain of R200,000 on the sale of the shares.The R200,000 will be included in the capital gains of the father as paragraph 72 applies to the transaction.3. DISTRIBUTIONS TO NON RESIDENTS BY TRUSTSCapital gains may be earned by non residents via the distribution of a capital gain to the non resident by a trust. SARS would like to expand the tax base and have promulgated law that where an amount of capital gains earned by a non resident is distributed through a trust, which is not taxed in the donors hands via paragraph 72 (discussed above) the amount earned through the trust is not taxed in the hands of the non resident, but in the hands of the trust.This is done to increase the amount of tax collected as the trust is taxed on a worldwide income basis, unlike the non resident who is taxed on a source basis.ILLUSTRATION – NON RESIDENTS AND TRUSTSMr Backos donated a rental property to a trust 5 years ago. In the past year, Mr Backos died. The trust decided to sell the property in the current year and made a capital gain of R600,000 on disposal of the property. In terms of the trust deed, the capital gain is distributed equally to Mr Backos’s 2 children, Stavros who is 23 years old and residing in Greece and Constantine, a 17 year old living with his mother in Johannesburg. What are the taxation implications?SUGGESTED SOLUTIONAs the donor is deceased, paragraphs 68 – 72 will not apply.Constantine is a SA resident and will be taxed on the R300,000 capital gain as per par80(2)Stavros is a non resident and as such the trust will include the full R300,000 from Stavros in its tax return. Stavros will not be taxed on the capital gain. 4. attribution examples with income and capital gains integratedILLUSTRATION – ATTRIBUTION WHERE THERE IS INCOME AND CAPITAL GAIN AS A RESULT OF A DONATIONOn 1 March of the current year, Mr A donated a rent producing property to his minor son when the market value of the property was R1,000,000. The property earned net rental income of R80,000 during the year and was sold on 28 February for R1,120,000. A fair rate of interest for the financial year was 15%.What are the taxation implications of the above.What are the taxation implications if the property was sold to the minor child and a 5% loan was paid back to the parent by the child.SUGGESTED SOLUTIONPart aHad the transaction been at arms length, the property would have been sold for R1,000,000 and a market related interest rate of 15% would have been charged. The beneficiary would have had to pay R150,000 interest on the loan for the year.Per section 7(3), an amount of R80,000 will vest in the donors hands as income as the minor child derived income from a donation made by a parent. There is also a capital gain of R120,000 on the sale of the property that is made by the minor child. Paragraph 69 deems the amount of a capital gain by a minor child to be attributable to the parent. However paragraph 73 limits the amount of the attribution to the benefit that the minor child would have received. A R150,000 benefit is the amount of the benefit received in the form of no interest having been paid. This is the attribution limit.R80,000 has already vested in the parent by virtue of paragraph 7(3) being applied. Thus R70,000 benefit remains that has not been attributed to the parent.The R70,000 will be attributed to the parent in the form of a capital gain to which the provisions of paragraph 69 apply. The remaining R50,000 (120,000 capital gains less the 70,000 given to the parent) will be taxed in the hands of the minor child as a capital gain.It is important to note that the capital gain before the inclusion the rate is used. This signifies the benefit or gain that arises on the disposal. The inclusion rate only determines the portion of this gain that is taxed. Part bThe interest paid by the child to the parent totals R50,000 (5% X R1,000,000). The interest that the parent could have gotten in the marketplace is 15%. Had the parent gotten the market rate of interest, the net interest received would have been R150,000. The minor child has benefited to the amount of R150,000 – R50,000 = R100,000.Per section 7(3), an amount of R80,000 will vest in the donors hands as income as the minor child derived income from a donation made by a parent. There is also a capital gain of R120,000 on the sale of the property that is made by the minor child. Paragraph 69 deems the amount of a capital gain by a minor child to be attributable to the parent. However paragraph 73 limits the amount of the attribution to the benefit that the minor child would have received. A R100,000 benefit is the amount of the benefit received in the form of too little interest having been paid. R80,000 has already vested in the parent by virtue of paragraph 7(3) being applied. Thus R20,000 benefit remains that has not been attributed to the parent.The R20,000 will be attributed to the parent in the form of a capital gain to which the provisions of paragraph 69 apply. The remaining R100,000 will be taxed in the hands of the minor child as a capital gain.ILLUSTRATION – ATTRIBUTION OVER LESS THAN 1 YEARA parent donated a house to his minor child on 1 March when the house was worth R1,000,000. On 31 December the house was sold for R1,230,000. Rent of R40,000 was earned by the minor child from letting out the house for the year. Had the parent invested the money in the bank, he would have received interest at 8% per year. Calculate the taxable income of the child and the parent.SUGGESTED SOLUTIONRental income of R40,000 has been received. In addition, a capital gain of R230,000 has been made on disposal. The attribution calculation is 1,000,000 x 8% X 10/12 = 66,667. The R40,000 rental will be taxed in the hands of the parent in terms of section 7(3).Of the R230,000 capital gain, R66,667-R40,000 = R26,667 capital gain will be taxed in the hands of the parent The remaining R230,000 – R26,667 capital gain = 203,333 will be taxed in the hands of the minor child.ILLUSTRATION – ATTRIBUTION OVER MORE THAN 1 YEARMr Bosch sold his office block to the Jardine trust for an amount of R2,000,000 on 1 March 2011. The sale to the trust was financed by a loan at a rate of 5%. Had the trust took out a commercial loan, the trust would have paid interest at a rate of 12% for the year ended 28 February 2012, and 10% for the year ended 28 February 2013.The trust sold the office block for R2,700,000 on 30 November 2012 and the outstanding loan amount to Mr Bosch was settled.Rentals of R50,000 were earned on the building in the 2012 tax year and R38,000 in the 2013 tax year. The sole beneficiary of the trust is Mr Bosch’s 11 year old son, Marius. Calculate the taxable income of the Mr Bosch and Marius for the 2012 and 2013 tax years. SUGGESTED SOLUTION TO EXAMPLE 42012 TAX YEARR50,000 rent taxed in hands of Mr Bosch in terms of section 7(3).2013 TAX YEAR R38,000 rent taxed in the hands of Mr Bosch in terms of section 7(3).Total attribution (see working 1 below) R215,000Less: Taxed in Mr Bosch’s hands in 2010 tax year(R50,000)Less: Taxed in Mr Bosch’s hands 2011 tax year(R38,000)Attribution not yet taxedR127,000Thus R127,000 of the capital gain is taxed in Mr Bosch’s hands. The remaining R700,000 – 127,000 = R573,000 is taxed in his son’s hands.Working 1 - Attribution calculationAttribution for 2010 tax year = 12% X 2,000,000 = R240,000Less: Interest paid 5% X 2,000,000(R100,000) R140,000Attribution for 2011 tax year = 10% X 2,000,000 X 9/12 = R150,000Less: Interest paid 5% X 2,000,000 X 9/12(R 75,000) R 75,000 Total attribution (140,000 + 75,000) R215,000ATTRIBUTION SPREAD OVER MORE THAN ONE ASSETMr B donated an office block worth R2,600,000, undeveloped land worth R400,000 and shares worth R2,000,000 to a trust on 1 March 2010. On 31 December, the undeveloped property was sold for R460,000 and the office block for R3,060,000.. The trust received rentals of R200,000 from the property and dividends of R70,000 were received from the shares. Had the trust taken out a loan to finance the acquisition of the property and shares, they would paid interest at 8%. The sole beneficiary of the trust is Mr B’s non resident 23 year old son and all the amounts earned by the trust were distributed to him.Calculate the taxable income of the father and the son for the current tax year.SUGGESTED SOLUTION TO EXAMPLE 5 ATTRIBUTION = 5,000,000 X 8% = 400,000. Taxed in hands of the donor is R200,000 rental and R70,000 dividends as section 7(8) applies. Attribution remaining is R400,000 – R270,000 = R130,000Capital gain on office block is R3,060,000 – R2,600,000 = R460,000Capital gain on undeveloped land is R460,000 – 60,000 = R60,000.Thus total capital gain is R520,000. Remaining attribution = R130,000. Thus attribution percentage is 130,000 / R520,000 = 25%Thus 25%(or 130/520) X 460,000 = 115,000 capital gain on the office block will be taxed in Mr B’s hands and the remaining R460,000 – 115,000 = R345,000 will be taxed in the hands of the trust.Thus 25%(or 130/520) X 60,000 = 15,000 capital gain on the undeveloped land will be taxed in Mr B’s hands and the remaining R60,000 – 15,000 = R45,000 will be taxed in the hands of the trust.Note that the taxable gain is taxed is taxed in the hands of the trust not the non resident even though it is due to the non resident.5. distribution of assets out of a trust378142531115If the beneficiary did not have a vested right to the asset given to the beneficiary, the trust is deemed to have disposed of the asset to the beneficiary at current market value and the trust will have a capital gain.00If the beneficiary did not have a vested right to the asset given to the beneficiary, the trust is deemed to have disposed of the asset to the beneficiary at current market value and the trust will have a capital gain.-6667531115If the beneficiary has a vested right to the asset, there is no disposal for CGT purposes. Capital gains will only be calculated when the beneficiary disposes of the asset.00If the beneficiary has a vested right to the asset, there is no disposal for CGT purposes. Capital gains will only be calculated when the beneficiary disposes of the asset.209550031115An asset in a trust is given to a beneficiary00An asset in a trust is given to a beneficiary3524250361950018192753619500ILLUSTRATION – VESTING OF AN ASSET IN A BENEFICIARYThe Butcher Trust received a residential property from the deceased estate of Terry Butcher in 2005 when the asset was worth R800,000. Mary Butcher has a vested right to the all the income and proceeds from the residential property.In the current year, the property was given to Mary Butcher when it was worth R1,900,000. She sold the property later on in the year for R2,100,000.What are the taxation implications of the above?How would the tax implications change if Mary Butcher did not have a vested right?SUGGESTED SOLUTIONPart aThe trust would have no capital gain. The beneficiary would assume the base cost of the trust i.e. R800,000.When the beneficiary disposes of the asset, a capital gain of R2,100,000 – R800,000 = R1,300,000 would be made by the beneficiary.Part bThe trust would be assumed to dispose of the asset at market value of R1,900,000 and a capital gain of R1,100,000 would be made. This may be taxed in the trust or the beneficiary’s hands depending on who the gain is vested or not vested in.The base cost for the beneficiary would be R1,900,000.The beneficiary would have a capital gain of R2,100,000 – 1,900,000 on disposal. ................
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