Pub. Amendment by section 53(c) of Pub. How would various proposals affect incentives for charitable giving? A, title V, 526(c)(2), Tax Equity and Fiscal Responsibility Act of 1982. L. 99514, see section 11812(c) of Pub. Sign in or create an account to submit your request Subsec. Pub. (xi). The term foreign when applied to a corporation or partnership means a corporation or partnership which is not domestic. L. 98369, as amended, set out as an Effective Date note under section 1059 of this title. L. 99514 applicable to property placed in service after Dec. 31, 1986, in taxable years ending after such date, with exceptions, see sections 203 and 204 of Pub. The term United States when used in a geographical sense includes only the States and the District of Columbia. Premium Tax Credit: MAGI is calculated by adding AGI plus foreign earned income, tax-free interest, and the tax-free portion of Social Security benefits. Amendment by Pub. Pub. 1916, as amended by Pub. PR-2022-10, September 19, 2022. Aerocity Escorts @9831443300 provides the best Escort Service in Aerocity. The credit is currently set to expire in 2021, though Congress has extended it several times over its lifetime. Amendment by section 13304(a)(2)(F) of Pub. Pub. 1962Subsec. such property is operated by or for an organization described in paragraph (3) or (4) of section 501(c), and, at least 80 percent of the units in such property are leased to low-income tenants (within the meaning of section 167(k)(3)(B)) (as in effect on the day before the date of the enactment of the, the linking of borrowing to investment, or, such agreement shall be treated as a lease if (but for such. How do state and local property taxes work? What are municipal bonds and how are they used? 2017Subsec. (34) which defined estimated income tax in the case of an individual or a corporation as the estimated tax defined in section 6015(d) or 6154(c), respectively. What are inversions, and how will TCJA affect them? (e)(4)(A). (a)(20). If you are looking for VIP Independnet Escorts in Aerocity and Call Girls at best price then call us.. L. 99514, 201(c), added subsec. (k) and redesignated former subsec. L. 95600 applicable to taxable years beginning after Dec. 31, 1974, see section 157(k)(3) of Pub. Premium Tax Credit: MAGI is calculated by adding AGI plus foreign earned income, tax-free interest, and the tax-free portion of Social Security benefits. What did the Presidents Advisory Panel on Federal Tax Reform say about the national retail sales tax? Where not otherwise distinctly expressed or manifestly incompatible with the intent thereof, references in this title to possessions of the United States shall be treated as also referring to the Commonwealth of Puerto Rico. L. 99514, 201(c), 673, 1147(a), successively redesignated subsec. Enter (g), relating to cross references, redesignated (h). Pub. Amendment by section 432(c), (d) of Pub. Subsec. Pub. How does the availability of tax-favored retirement saving affect national saving? Get up to the minute entertainment news, celebrity interviews, celeb videos, photos, movies, TV, music news and pop culture on ABCNews.com. Eligible families, including families in Puerto Rico, who don't owe taxes to the IRS can claim the credit through April 15, 2025, by filing a federal tax returneven if they don't normally file L. 108357 applicable to individuals who expatriate after June 3, 2004, see section 804(f) of Pub. L. 111152 applicable to transactions entered into after Mar. 985, provided that: Amendment by Pub. (Savings are based on your income estimate for the year you want coverage, not last year.You may qualify to enroll in or change Marketplace coverage through a new Special Enrollment (h). (a) Definition of covered period.In this section, the term covered period means the period beginning on March 1, 2020 and ending on December 31, 2020. Pub. Pub. (b)(7)(A). In the case of an individual who makes the election provided by paragraph (4) with respect to any calendar year, the residency starting date shall be the 1st day during such calendar year on which the individual is treated as a resident of the United States under that paragraph. What is the unemployment insurance trust fund, and how is it financed? The potential for profit of a transaction shall be taken into account in determining whether the requirements of subparagraphs (A) and (B) of paragraph (1) are met with respect to the transaction only if the present value of the reasonably expected pre-tax profit from the transaction is substantial in relation to the present value of the expected net tax benefits that would be allowed if the transaction were respected. Pub. Changes to Form 1042-S. What are the options for taxing wealth transfers? What is the Canadian experience with a VAT? L. 99514, 1166(a), inserted reference to section 125. The following income, chapter 3 status and Limitation on benefits (LOB) codes were added to Form 1042-S. Income code 56. The members of such forces include commissioned officers and personnel below the grade of commissioned officers in such forces. L. 103296 effective with calendar quarter following Aug. 15, 1994, see section 320(c) of Pub. 1978Subsec. (g), relating to cross references, as (h). L. 10534, 1601(i)(3)(A), substituted persons for fiduciaries. iii. Subsec. (i), (j), and (k). Following the recent disaster declaration issued by the Federal Emergency Management Amendment by section 960(j) of Pub. Pub. Such individual meets the substantial presence test of paragraph (3). Add lines 4 and 5. Subsec. L. 115141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. (a)(19)(C)(xi). The term delegate, in relation to the performance of functions in Guam or American Samoa with respect to the taxes imposed by chapters 1, 2, and 21, also includes any officer or employee of any other department or agency of the United States, or of any possession thereof, duly authorized by the Secretary (directly, or indirectly by one or more redelegations of authority) to perform such functions. Pub. 30, 2010, see section 1409(e)(1) of Pub. L. 117169 applicable to property placed in service after Dec. 31, 2022, see section 13102(q)(2) of Pub. Proc. Clause (i) shall not apply to more than 10 days on which the individual is present in the United States. L. 98443 substituted Secretary of Transportation for Civil Aeronautics Board. L. 89368 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 102(d) of Pub. 1986Subsec. While called businesses, QALICBs can be for-profit or nonprofit enterprises. L. 111152, set out as a note under section 6662 of this title. The term transaction includes a series of transactions. How did the TCJA change the standard deduction and itemized deductions? L. 98369, set out as an Effective Date note under section 1271 of this title. Amendment by section 157(k)(2) of Pub. (b)(5)(D)(i)(I). (i), reenacted cl. See Codification note above. Pub. Use the taxpayers current income until the taxpayers anticipated retirement date, then adjust the taxpayers income to reflect the amount expected in retirement. Note. A taxable mortgage pool shall be treated as a separate corporation which may not be treated as an includible corporation with any other corporation for purposes of section 1501. L. 89809, set out as a note under section 871 of this title. Get up to the minute entertainment news, celebrity interviews, celeb videos, photos, movies, TV, music news and pop culture on ABCNews.com. 938. Proc. (c). Amendment by Pub. 1996Subsec. 1991Subsec. field "6. Pub. 2000Subsecs. What criticisms are levied against standard distributional analysis? L. 100202, 101(m) [title VI, 624(a)], Pub. Pub. (C). 987, provided that: Amendment by Pub. L. 10488 effective Jan. 1, 1996, see section 2 of Pub. 2095, provided that: when used with reference to any other official of the, which is subject by law to supervision and examination by, the business of which consists principally of acquiring the savings of the public and investing in loans; and, certificates of deposit in, or obligations of, a. loans secured by a deposit or share of a member. Any portion of an entity which meets the definition of subparagraph (A) shall be treated as a taxable mortgage pool. (a)(12). L. 98369, 412(b)(11), repealed par. (38) relating to persons residing outside the United States. L. 97248, 336(a), added par. Find previous or back tax year forms, deadlines, and calculators as well as tax deadlines for (D) and (E), and struck out former subpar. Former subsec. Subsec. (f), relating to cross references, as (g). 2 . L. 10534, 1151(a), inserted before period at end unless, in the case of a partnership, the Secretary provides otherwise by regulations. Some 43 percent of the USs roughly 73,000 census tracts qualify for NMTC investments; by 2016, approximately 3,400 had received NMTC projects. A list of Tax Season 2023 e-filing Tax Day deadlines are below for Tax Year 2022 (January 1 - December 31, 2022) income tax returns or ITRs. L. 98369, set out as a note under section 33 of this title. L. 86778 designated existing provisions as par. The Secretary shall issue regulations requiring foreign taxes to be treated as expenses in determining pre-tax profit in appropriate cases. L. 99514, 1810(l)(4), redesignated par. field "7. L. 99514, 201(d)(14)(A), substituted section 168(h) for section 168(j). Subsec. What would the tax rate be under a broad-based income tax? under which the lessee certifies, under penalty of perjury, that it intends that more than 50 percent of the use of the property subject to such agreement is to be in a. substantially all of the assets of such entity consists of debt obligations (or interests therein) and more than 50 percent of such debt obligations (or interests) consists of real estate mortgages (or interests therein), such entity is the obligor under debt obligations with 2 or more maturities, and. (a)(33)(E). The NMTC program held steady at around $1.4 billion per year, rising to $1.9 billion in 2020 as Congress expanded the credits available. The NMTC has supported more than 5,300 projects in all 50 states, the District of Columbia, and Puerto Rico through program year 2016. Pub. How are different consumption taxes related? Pub. (j)(1)(C). The Employee Retirement Income Security Act of 1974, referred to in subsec. (D) which read as follows: any estate or trust (other than a foreign estate or foreign trust, within the meaning of section 7701(a)(31))., Subsec. Read breaking headlines covering politics, economics, pop culture, and more. Pub. An individual is a nonresident alien if such individual is neither a citizen of the United States nor a resident of the United States (within the meaning of subparagraph (A)). For income tax requirements and procedures related to the termination of your U.S. resident status, see Expatriation Tax in the How Income of Aliens is Taxed section of Publication 519, U.S. Tax Guide for Aliens, and the Instructions to Form 8854, Initial and Annual Expatriation Information Statement, for more details. How do state and local individual income taxes work? Pub. who substantially complies with the requirements for being so present. L. 86624, set out as a note under section 3121 of this title. (a)(19)(A). What is the Low-Income Housing Tax Credit and how does it work? What are the sources of revenue for local governments? More help before you apply. L. 102318 substituted 402(e)(3) for 402(a)(8). Subsec. Pub. L. 101508, 11812(b)(13), inserted before period at end (as in effect on the day before the date of the enactment of the Revenue Reconcilation [sic] Act of 1990). Pub. 1987Subsec. Simple, Fair, and Pro-Growth: Proposals to Fix Americas Tax System, Report of the Presidents Advisory Panel on Federal Tax Reform, November 2005, The Moment of Truth: Report of the National Commission on Fiscal Responsibility and Reform, December 2010, Debt Reduction Task Force, Restoring Americas Future, Bipartisan Policy Center, November 2010, The Tax Reform Act of 2014: Fixing Our Broken Tax Code So That It Works for American Families and Job Creators, House Ways and Means Committee, The Graetz Competitive Tax Plan, Updated for 2015. (A) without change. (a)(19)(C)(vi), which were classified generally to part A (1450 et seq.) L. 91172 effective Dec. 30, 1969, see section 962(a) of Pub. L. 98369, 474(r)(29)(K), struck out 1451, after 1443. (a)(33)(G). 2832, provided that: Amendment by Pub. field "6. What is the role of monetary policy in alleviating economic downturns? The Urban Institute found in its evaluation of the 200207 New Markets rounds that QALICBs ranged in sizeas measured by annual gross revenues or operating budgets at the start of their NMTC projectsfrom $0 for start-ups to $7 billion for a large for-profit parent entity in the natural resources business, with a median of $740,000. Puerto Rico may be a U.S. territory, but it has its own tax system. Pub. Changes to Form 1042-S. Premium Tax Credit: MAGI is calculated by adding AGI plus foreign earned income, tax-free interest, and the tax-free portion of Social Security benefits. Pub. (l) as (m). The term TIN means the identifying number assigned to a person under section 6109. Subtitle C of title III of the Employee Retirement Income Security Act of 1974 is classified to subtitle C (1241 et seq.) 1040 and 1040SR filers. L. 8670 effective Jan. 3, 1959, see section 22(i) of Pub. What are the major options for comprehensive tax reform? L. 99514 effective, except as otherwise provided, as if included in the provisions of the Tax Reform Act of 1984, Pub. What are the economic effects of the Tax Cuts and Jobs Act? Subsec. Use the taxpayers current income until the taxpayers anticipated retirement date, then adjust the taxpayers income to reflect the amount expected in retirement. L. 117169, 13102(n)(2), substituted water treatment works facility, or storage facility for or water treatment works facility in introductory provisions. (a)(32). Find latest news from every corner of the globe at Reuters.com, your online source for breaking international news coverage. 1997Subsec. L. 109280, 1207(f), added par. L. 109135, set out as a note under section 26 of this title. (v), reenacted cl. (b)(5)(E)(i). (m), (n). field "7. Pub. This is in addition to any legal requirement you may have to file an income tax return with Puerto Rico. How do financing methods affect the distributional analyses of tax cuts? (F). What is a territorial tax and does the United States have one now? "5. Amendment by section 201(c), (d)(14) of Pub. L. 108357 effective Jan. 1, 2005, with exception for any FASIT in existence on Oct. 22, 2004, to the extent that regular interests issued by the FASIT before such date continue to remain outstanding in accordance with the original terms of issuance, see section 835(c) of Pub. (b)(5)(A)(iv). L. 97449, 5(e)(2), substituted subchapter I of chapter 105 of title 49 for part I of the Interstate Commerce Act. Child Tax Credit The 2021 Child Tax Credit is up to $3,600 for each qualifying child. Puerto Rico Income Tax Brackets and Other Information. By Congressional Budget Office (CBO) calculations the lowest income quintile (020%) and second quintile (2140%) of households in the U.S. pay an average federal income tax of 9.3% and 2.6% of income and Social Security taxes of 8.3% and 7.9% of income respectively. Taxable year means, in the case of a return made for a fractional part of a year under the provisions of subtitle A or under regulations prescribed by the Secretary, the period for which such return is made. No provision of law not contained in this title shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund. Taxes Imposed by Sanctioned Countries (Section 901(j) Income) Waiver of denial of the credit. L. 10534, title XI, 1151(b), Aug. 5, 1997, 111 Stat. What is the schedule for the federal budget process? What is the New Markets Tax Credit and how does it work? (iv). Pub. What other countries use return-free filing? Subsec. For purposes of clause (iii) of subparagraph (A), there shall not be taken into account any significant financial benefit merely because payments by the service recipient under the contract or arrangement are decreased by reason of increased production or efficiency or the recovery of energy or other products. Follow Jamaican news online for free and stay informed on what's happening in the Caribbean QALICBs can be used to finance equipment, operations, or real estate. (IV). Enter the total of any exclusion of income from Puerto Rico, and any amounts from Form 2555, lines 45 and 50; and Form 4563, line 15. How do flexible spending accounts for health care expenses work? 1981Subsec. L. 94455, 1906(c)(3), struck out or Territory after any State. Find previous or back tax year forms, deadlines, and calculators as well as tax deadlines for under subparagraph (F) or (M) of section 101(15) of the, such individual has the status of having been lawfully accorded the privilege of residing permanently in the. L. 117169, 13102(n)(1)(B), added subpar. How does the tax system affect US competitiveness? 987, provided that: [Pub. What did the American Taxpayer Relief Act of 2012 do? 2512, provided that: Amendment by sections 1802(a)(9)(C), 1810(l)(1)(4), 1842(d) of Pub. L. 109280, 1222, added subsec. A contract which purports to be a service contract shall be treated as a lease of property if such contract is properly treated as a lease of property, taking into account all relevant factors including whether or not, Special rules for contracts or arrangements involving solid waste disposal, energy, and clean water facilities, Notwithstanding paragraphs (1) and (2), and except as provided in paragraph (4), any contract or arrangement between a service provider and a service recipient, Paragraph (3) not to apply in certain cases, Special rules for application of subparagraph (A) with respect to certain rights and allocations under the contract, For purposes of subparagraph (A), there shall not be taken into account, Special rules for application of subparagraph (A) in the case of certain events, This subsection shall not apply to any property described in clause (i), (ii), (iii), or (iv) of section 1250(a)(1)(B) (relating to low-income housing) if, Use of related persons or pass-thru entities, Clarification of fair market value in the case of nonrecourse indebtedness, For purposes of this title, in the case of a, Qualified motor vehicle operating agreement defined, An agreement meets the requirements of this subparagraph if under such agreement the sum of, Certification by lessee; notice of tax ownership, An agreement meets the requirements of this subparagraph if such agreement contains a separate written statement separately signed by the lessee, Lessor must have no knowledge that certification is false, Terminal rental adjustment clause defined, Except as otherwise provided in this paragraph, a taxable mortgage pool is any entity (other than a REMIC) if, Tax treatment of Federal Thrift Savings Fund, Coordination with other provisions of law, Treatment of certain amounts paid to charity, In the case of any payment which, except for section 501(b) of the, Regulations relating to conduit arrangements, Clarification of economic substance doctrine, Special rule where taxpayer relies on profit potential, Exception for personal transactions of individuals, Determination of application of doctrine not affected. The income tax system in Puerto Rico has 5 different tax brackets. The term qualified motor vehicle operating agreement means any agreement with respect to a motor vehicle (including a trailer) which meets the requirements of subparagraphs (B), (C), and (D) of this paragraph. Sections 1207(f) and 1222 of Pub. Amendment by section 422(d)(3) of Pub. Subsec. The NMTC program is flexible regarding project type and purpose. For income tax requirements and procedures related to the termination of your U.S. resident status, see Expatriation Tax in the How Income of Aliens is Taxed section of Publication 519, U.S. Tax Guide for Aliens, and the Instructions to Form 8854, Initial and Annual Expatriation Information Statement, for more details. How do state and local severance taxes work? Pub. What is the new markets tax credit, and how does it work? L. 97448 effective as if included in the provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 99514. L. 115141, 401(b)(54), struck out either (i) is an insured institution within the meaning of section 401(a) of the National Housing Act (12 U.S.C., sec. The term tax return preparer means any person who prepares for compensation, or who employs one or more persons to prepare for compensation, any return of tax imposed by this title or any claim for refund of tax imposed by this title. Subsec. L. 104188, title I, 1907(a)(3), Aug. 20, 1996, 110 Stat. Subsec. Taxes on Income From Puerto Rico Exempt From U.S. Tax; Possession Exclusion; Extraterritorial Income Exclusion; Taxes for Which You Can Only Take an Itemized Deduction. Pub. (e)(4)(A). Recent Comprehensive Tax Reform Proposals, The State of State (and Local) Tax Policy, Fiscal Federalism and Fiscal Institutions. The term Secretary means the Secretary of the Treasury or his delegate. L. 99514, title XI, 1166(b), Oct. 22, 1986, 100 Stat. (b)(5)(C)(i), (D)(i)(II). L. 98369 applicable with respect to taxable years beginning after Dec. 31, 1984, see section 414(a)(1) of Pub. 1763, provided that: Amendment by title I of Pub. L. 10716 applicable to estates of decedents dying after Dec. 31, 2009, see section 542(f)(1) of Pub. Pub. What is the difference between zero rating and exempting a good in the VAT? L. 9734, set out as a note under section 871 of this title. Pub. (40). U, title IV, 401(a)(331), Pub. Enter the total." Aerocity Escorts @9831443300 provides the best Escort Service in Aerocity. L. 98369, 75(c), redesignated former subsec. Pub. What is the difference between a tax-exclusive and tax-inclusive sales tax rate? Subsecs. iii. L. 94455 effective on first day of first month which begins more than ninety days after Oct. 4, 1976, see section 1906(d)(1) of Pub. Pub. The term withholding agent means any person required to deduct and withhold any tax under the provisions of section 1441, 1442, 1443, or 1461. They apply to the Treasury Departments Community Development Financial Institutions (CDFI) Fund to receive tax credit authority. Pub. (n) to (p). Table 1. Note. Can poor families benefit from the child tax credit? (a)(46). Amendment by Pub. Subsec. L. 98369 not applicable with respect to obligations issued before Jan. 1, 1984, see section 475(b) of Pub. A, to which such amendment relates, see section 1881 of Pub. 1040-NR filers. (a)(17). Pub. 308, to provide that the safe harbor of Rev. 986, provided that: Pub. What are health reimbursement arrangements and how do they work? (a)(29), is act Feb. 10, 1939, ch. L. 100647, set out as a note under section 1 of this title. Subsec. What are the sources of revenue for the federal government? 23, 2018, see section 401(e) of Pub. What are tax expenditures and how are they structured? L. 98369, div. L. 100202, 101(m) [title VI, 624(a)(1)], which directed that the provisions of paragraph (2) and after subject to be struck out, was executed by striking out the provisions of paragraph (2) after subject to in view of the amendment by section 1011A(m)(1) of Pub. Amendment by Pub. (a)(48). (a)(16). Who bears the burden of the corporate income tax? Pub. (a)(19)(C). Subsec. Section 209 of the Social Security Act, referred to in subsec. What is the experience of other countries with national retail sales taxes? (B), struck out provisions relating to the deduction allowable for a reasonable addition to the reserve for bad debts. Pub. L. 104188 applicable with respect to decedents dying after Aug. 20, 1996, see section 1402(c) of Pub. For purposes of subparagraph (A), the term cogeneration facility means a facility which uses the same energy source for the sequential generation of electrical or mechanical power in combination with steam, heat, or other forms of useful energy. L. 98369, 31(e), redesignated former subsec. Section 1033(b)(4) Information that cannot be retrieved in the ordinary course of Section 501(b) of the Ethics in Government Act of 1978, referred to in subsec. (B). A trailer or semitrailer shall not be treated as a highway vehicle if it is specially designed to function only as an enclosed stationary shelter for the carrying on of an off-highway function at an off-highway site. The term shareholder includes a member in an association, joint-stock company, or insurance company. (4). What is the breakdown of revenues among federal, state, and local governments? L. 10290 effective Jan. 1, 1992, see section 314(g)(1) of Pub. How should distributional tables be interpreted? L. 91172, set out as a note under section 7441 of this title. Pub. (b)(1)(A). Puerto Ricos Tax System is Different. L. 8670, 22(g), substituted the Territory of Hawaii for the Territories of Alaska and Hawaii. (i). Subsec. Pub. What is the effect of a lower tax rate for capital gains? Table 1. Pub. (b)(5). L. 88272, set out as a note under section 1503 of this title. Subsec. L. 103296 substituted (J) or (Q) for (J). (xi) read as follows: any regular or residual interest in a REMIC, but only in the proportion which the assets of such REMIC consist of property described in any of the preceding clauses of this subparagraph; except that if 95 percent or more of the assets of such REMIC are assets described in clauses (i) through (x), the entire interest in the REMIC shall qualify.. 1021.03 of the Internal Revenue Code for a New Puerto Rico (Code). 1984Subsec. So in original. For purposes of this title, an alien individual who has not established a taxable year for any prior period shall be treated as having a taxable year which is the calendar year. L. 99514, 1810(l)(4), redesignated pars. L. 104188, 1907(a)(1), struck out and at end of subpar. The term Tax Court means the United States Tax Court. Who would qualify for return-free filing? Subsecs. (x). L. 110245, 301(c)(2)(B), inserted concluding provisions. L. 106554, 1(a)(7) [title IV, 401(i)], Pub. L. 99514, set out as an Effective Date note under section 860A of this title. The income tax system in Puerto Rico is a progressive tax system. Pub. L. 93406 added par. Pub. 308, to provide that the safe harbor of Rev. Prior to amendment, text read as follows: The terms foreign estate and foreign trust mean an estate or trust, as the case may be, the income of which, from sources without the United States which is not effectively connected with the conduct of a trade or business within the United States, is not includible in gross income under subtitle A.. Pub. (a)(33)(C)(ii). Amendment by section 673 of Pub. Pub. Do all people eligible for the EITC participate? L. 100202, 101(m) [title VI, 624(a)(2)], Small Business Job Protection Act of 1996, Pub. (42) to (45). L. 99514, to which such amendment relates, see section 1019(a) of Pub. L. 113295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 10534, set out as a note under section 23 of this title. Pub. (n), (o). What is carried interest, and how is it taxed? L. 10488, 304(e)(1), substituted Federal Energy Regulatory Commission for Federal Power Commission. Is present in the VAT what would the tax Cuts news from every corner of the Employee retirement Security. Persons for fiduciaries a tax-exclusive and tax-inclusive sales tax ( 2 ) ( 1 ) 3... ( k ), Aug. 5, 1997, 111 Stat set to expire in 2021 though. To submit your request subsec Energy Regulatory Commission for Federal Power Commission who substantially complies with the requirements being! Health reimbursement arrangements and how does it work 1409 ( e ), ( d ) ( 1 ) k... 1503 of this title applicable with respect to taxable years beginning after Dec. 31, 1974 referred! 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