Wealth & Risk Management Blog

William Byrnes (Texas A&M) tax & compliance articles

Posts Tagged ‘gift tax’

Must Santa Claus Pay Tax? End of Year Gift Tax Facts

Posted by William Byrnes on December 15, 2014


Find out which of your clients need to pay the federal gift tax and what the annual exclusion amount is for 2014 and 2015

2014_tf_on_individuals_small_businesses-m_1Due to a number of recent changes in the law, taxpayers are currently facing many questions connected to important issues such as healthcare, home office use, capital gains, investments, and whether an individual is considered an employee or a contractor. Financial advisors are continually looking for updated tax information that can help them provide the right answers to the right people at the right time. This book provides fast, clear, and authoritative answers to pressing questions, and it does so in the convenient, timesaving, Q&A format for which Tax Facts is famous.

Anyone interested can try Tax Facts on Individuals & Small Business, risk-free for 30 days, with a 100% guarantee of complete satisfaction.  For more information, please go to http://www.nationalunderwriter.com/2015-tax-facts-on-individuals-small-business.html or call 1-800-543-0874.

Posted in Estate Tax, Taxation | Tagged: | Leave a Comment »

IRS Grants Reprieve for Late Estate Tax Portability Elections

Posted by William Byrnes on March 31, 2014


Today’s generous estate tax exemption has created an unexpected problem among clients: failure to take advantage of the portability of a first-to-die spouse’s unused estate tax exemption. Unknown to many, portability is available only if you ask for it, and failure to elect portability can leave a surviving spouse’s estate facing an unexpectedly heavy tax burden, even if no estate tax was due upon the first spouse’s death.

Luckily, the IRS has provided a limited reprieve for certain clients whose inadvertent failure to make the election could leave them on the hook for an unnecessary estate tax bill.  The relief provided by the IRS, however, is limited in both time and scope, so the time to learn the rules of portability is now.

Read the analysis of William Byrnes and Robert Bloink at > ThinkAdvisor <

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Posted in Retirement Planning | Tagged: , , , , | Leave a Comment »

$135 billion of reported gifts for 2012 nearly tripling 2011 levels

Posted by William Byrnes on January 28, 2014


Yesterday, the IRS Tax Stats Dispatch (#2014-2) included the link for the summation of data from all 2012 Gift Tax Returns.   (see http://www.irs.gov/uac/SOI-Tax-Stats—Total-Gifts-of-Donor,-Total-Gifts,-Deductions,-Credits,-and-Net-Gift-Tax)

Interestingly, the total reported gifts of 2012 of approximately $135 billion was substantially more than double the 2011 year of approximately $51 billion, and previous years before that.  The significant pickup in reported gift giving over the last several years compared to 2012 is in the category $1 million and larger gifts.

Will be interested to read your comments as to why this may be ?  By example, is this the result of the now settled Estate and Gift tax rates ?  Is it a result of the timing of retiring baby boomers wealth transfer to the next generation of their progeny?  Is it charitably driven ?

Were financial planners prepared for the planning of this more than doubling of gifts to future generations and for charitable / legacy purposes?

Use Comments below.

Tax status and size of taxable gifts, current period [1]
Total gifts [2] Total annual exclusions Total included amount of gifts Total deductions [3] Taxable gifts, current period [4]
Number Amount Number Amount Number Amount Number Amount Number Amount
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)
All returns, taxable and nontaxable 258,393 $134,846,285,766 244443 11794733033 191816 123051555062 5606 8120138820 190401 114968624890
$0 67992 5822167968 67680 4054653753 1415 1767514212 1415 1767514212 0 0
Less than $2,500 7612 362423498 6528 233021040 7612 129402627 24 119914708 7612 9487920
$2,500 under $5,000 7433 412615201 7075 262415929 7433 150200871 407 123,960,592 7433 26240997
$5,000 under $10,000 9294 563330627 8934 321839948 9294 241490859 264 172533814 9294 68957045
$10,000 under $25,000 26161 1366229180 25611 924979071 26161 441250106 217 17,630,195 26161 423619911
$25,000 under $50,000 23829 1731665895 22746 796632342 23829 935033551 397 84434152 23829 850599399
$50,000 under $75,000 13048 1239385141 12504 400229648 13048 839155682 17 38,557,818 13048 800621940
$75,000 under $100,000 8306 996198369 7583 183011743 8306 813186628 6 91,801,097 8306 721385532
$100,000 under $250,000 29570 6071771849 26863 961754449 29570 5110017617 311 338746401 29570 4771297431
$250,000 under $500,000 17,470 $7,519,686,206 16193 709363682 17470 6810322321 662 439160459 17470 6371161683
$500,000 under $1 million 16,149 $12,885,834,594 14609 773330454 16149 12112504390 390 346832003 16149 11765882467
$1 million or more 31,529 $95,874,977,236 28117 2173500974 31529 93701476195 1497 4579053368 31529 89159370564

Posted in Retirement Planning, Tax Exempt Orgs, Wealth Management | Tagged: , , , , , , | Leave a Comment »

Will a Twitter Freeze Slash Your Thanksgiving Weight Gain or Your Client’s Tax Bill?

Posted by William Byrnes on November 28, 2013


While you think about how to reduce your weight, after the glutinous consumption of the Thanksgiving meal today, also consider how to reduce your client’s estate tax before an investment pays off.  The Twitter executives developed a plan to reduce their eventual gift and estate taxes in advance of their IPO.  The IPO has cause the value of the company to skyrocket.  But your client does not have to own Twitter stock to leverage the Twitter tax plan…. In fact,  a closer look at the planning strategies employed by Twitter shows that your client does not have to be sitting on the next hot silicon valley IPO to benefit from their use.  Even if your client does not own pre-IPO shares, the freeze and discounting strategies used can save them from a hefty tax bill.

Read William Byrnes and Robert Bloink’s analysis of the Twitter freeze strategy that may be attractive for certain of your clients at > http://www.thinkadvisor.com/2013/11/06/can-a-twitter-freeze-slash-your-clients-tax-bill <

And please support our newest book that has just been published: > Tax Facts on Individuals and Small Business <

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Tax Court Provides Help for Estate Planning Using Gift Tax Valuation

Posted by William Byrnes on November 19, 2013


In the gift tax arena, the value assigned to the transferred property can often make or break your high-net-worth clients’ tax planning strategies, leading many clients to move conservatively through the valuation minefield.

Despite this, the newest strategy to emerge in the world of gift tax valuation can actually allow these wealthy clients to reduce their estate tax liability. Reversing course from a previous line of cases, the Tax Court recently blessed a cutting edge valuation strategy for lifetime gifts that can be used to reduce overall estate tax liability for these clients by simultaneously reducing the bite of the often-overlooked three-year bringback rule—a rule which can cause even the most carefully laid estate plans to fail.

Read William Byrnes and Robert Bloink’s analysis of the tax court case and the three-year bringback rule at > http://www.thinkadvisor.com/2013/10/29/tax-court-provides-help-for-estate-planning-using <

 

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Gifting Life Insurance Policies: Not a Simple Matter

Posted by William Byrnes on October 17, 2013


Making a gift of a life insurance policy can prove to be anything but simple for clients who may not know what questions to ask in order to ascertain the potential tax consequences of the transaction. Transferring a policy that is subject to a policy loan can prove even more problematic, even if the transferee is a family member and the transfer is intended entirely as a gift.

Though the rule’s name might suggest otherwise, the transfer for value rule can create a serious tax trap for a client who transfers a life insurance policy, even if nothing tangible actually changes hands in the transaction.   Want to read more?  Open access content at Think Advisor!

Posted in Estate Tax, Insurance, Taxation, Wealth Management | Tagged: , , , , , , , , , , | Leave a Comment »

Aggressive IRS Gift Tax Audit Initiative: John Does Summons

Posted by William Byrnes on July 29, 2011


In recent years, the IRS has increased  its search for taxpayers who fail to disclose a gift tax return for reportable transactions. Now, the Justice Department’s Tax Division is getting in on the action, initiating an unprecedented fishing expedition and scouring state government records for information that may lead to taxpayers who have failed to file a gift tax return.

The Justice Department hopes to collect the identities of taxpayers who have gifted real property to relatives without reporting the transaction to the IRS. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

Posted in Taxation, Wealth Management | Tagged: , , , , , , , | Leave a Comment »

2010 Estates: To Elect or Not to Elect

Posted by William Byrnes on January 24, 2011


Did Congress finally settle the estate tax confusion when it passed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (Tax Relief Act) on December 16? Although the estate tax treatment of estates of decedents dying in 2011 and 2012 is crystal clear, most of our clients will outlive the current estate tax regime, and we will be stuck in the same spot we were for the last half of 2010, wondering what the next year holds.

And what about the estates of decedents dying in 2010? Under the Tax Relief Act, estates of decedents dying in 2010 have a choice. They can elect to have the estate subjected to an estate tax regime with an exclusion amount of $5,000,000 (unified credit of $1,730,000) and an estate tax rate of 35 percent. Beneficiaries of these estates will receive the benefit of the stepped-up basis rules applicable prior to 2010.  Read this complete article at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For previous coverage of Obama’s tax agreement, including its estate tax provisions, in Advisor’s Journal, see Obama Tax Agreement Faces Stiff Resistance in Congress (CC 10-112) and Obama Tax Agreement Passed by House (CC 10-117).

For in-depth analysis of the estate tax, see Estate, Gift and GST Taxes.

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Obama Tax Cuts Analysis: Estate and Generation Skipping Transfer Tax

Posted by William Byrnes on January 18, 2011


The recent Obama Tax Cuts reinstated the estate and generation skipping transfer taxes effective for decedents dying and transfers made after December 31, 2009.  As was discussed earlier this week, the estate tax applicable exclusion amount is $5 million for decedents dying in calendar years after 2011, and the maximum estate tax rate is 35 percent. Furthermore, the generation skipping transfer tax exemption for decedents dying or gifts made after December 31, 2009, is equal to the applicable exclusion amount for estate tax purposes ($5 million for 2010).

For a general background on the Generation Skipping Transfer Tax, see our November 1st Blogticle entitled: Life Insurance and the Generation—Skipping Transfer Tax

Although technically the generation skipping transfer tax is applicable for 2010, the generation skipping transfer tax rate for transfers made during 2010 is zero percent. After this year, the generation skipping transfer tax rate equals the highest estate and gift tax rate in effect for such year (35 percent in 2011 and 2012), notwithstanding the exclusion amounts.

Moreover, under the new law, a recipient of property acquired from a decedent who dies after December 31, 2009, generally will receive fair market value basis (i.e., “step up” in basis). [1]

To read this article excerpted above, please access http://www.advisorfyi.com/2010/12/obama-tax-cuts-analysis-estate-and-generation-skipping-transfer-tax/

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Does the New Estate Tax Make the Bypass Trust Obsolete?

Posted by William Byrnes on January 17, 2011


President Obama’s tax compromise introduces a new estate tax concept for 2011 and 2012, the deceased spouse unused exclusion amount (DSUEA).  Essentially, the DSUEA allows a surviving spouse to utilize the unused exclusion amount of the first spouse to die.  The new law raises an important planning question: Is the bypass (credit shelter) trust obsolete as an estate planning device? Also: Do existing bypass trusts need to be amended in light of the new law?

In general, under the new estate tax, an estate’s exclusion amount, referred to as its applicable exclusion amount, is the sum of two components: the basic exclusion amount and the DSUEA. The basic exclusion amount for estates of decedents dying in 2011 and 2012 is $5 million. The second part of the equation, the DSUEA, is the amount of the first-to-die spouse’s exclusion amount that is not used by the that spouse’s estate. Note that a surviving spouse’s DSUEA is equal to the unused exclusion amount of the surviving spouse’s last deceased spouse.  Read this complete article at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For previous coverage of Obama’s tax agreement, including its estate tax provisions, in Advisor’s Journal, see Obama Tax Agreement Faces Stiff Resistance in Congress (CC 10-112) and Obama Tax Agreement Passed by House (CC 10-117).

For in-depth analysis of the estate tax, see Advisor’s Main Library: Estate, Gift and GST Taxes.

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Estate Asks Supreme Court to Consider GST Tax Grandfathering Exemption

Posted by William Byrnes on January 5, 2011


An estate has asked the U.S. Supreme Court to consider whether the GST tax “grandfathering exemption” is ambiguous.  Two circuit courts of appeal have held that the statute is ambiguous while another two circuits hold that it is plain and unambiguous.

The Supreme Court is being asked to settle the split between the circuits.

The Generation Skipping Trusts

A generation skipping trust is a trust designed to shift property from one generation to another without passing the property through an intervening generation—e.g. a trust that transfers property from grandparents to their grandchildren.  Generally the “child beneficiaries” (children of the grantor) take only an income interest in the trust with grandchildren taking a remainder interest in the trust.  When the child beneficiaries die, trust assets will be transferred to the grandchildren.  Assuming the child beneficiaries took only an income interest in the trust and did not hold any incidents of ownership in the trust, the trust will not be included in the children’s estates when they die.

So, for example, if Grandfather funds a trust will for $5 million, naming his three adult children as income beneficiaries and his grandchildren as remainder beneficiaries, the trust is a generation skipping trust.  Read this complete article at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For in-depth analysis of the generation skipping transfer tax, see Advisor’s Main Library: Section 2.1 A—Generation Skipping Transfers Explained

We invite your questions and comments by posting them below or by calling the Panel of Experts.

 

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Exclusions from Gross Income—Gifts

Posted by William Byrnes on December 23, 2010


Why is this Topic Important to Wealth Managers? Discusses gifts and the general income tax implications gifts have to those who are the beneficiaries.  Also discusses gifts as they relate to estate taxes.

As Christmas and Holiday time approaches, some clients who may be expecting large sums from Santa or other sources as gifts, may be interested to know the tax laws on gifts generally; today’s blogiticle present’s our “re-gifting” of an old idea, Section 102 of the Internal Revenue Code.

For those who haven’t had an opportunity to read the Code lately, (some estimate the Code and Regulations are close to 80,000 pages) there are still a few “friendly” sections that remain which serve as a reminder of a time gone by.  Side Note:  These authors have not yet evaluated the shortest Code section in terms of actual words, but if we were to, our guess is that Section 102 would be in the running at 212 words.

Section 102(a) reads: “Gross income does not include the value of property acquired by gift, bequest, devise, or inheritance.”  It is worth noting, if we go back to Section 61, and the starting point for gross income, that Section 61(a) states:  “Except as otherwise provided in this subtitle gross income means all income from whatever source derived…”   The “[e]xcept as otherwise provided” is applicable here to amounts received as a gift, bequest, devise, or inheritance, which are specifically excluded from gross income.  In other words, a taxpayer can give another taxpayer a gift of $1,000,000 and the latter will not recognize a penny of income for tax purposes, so long as it is really a gift, bequest, devise or inheritance.  To read this article excerpted above, please access www.AdvisorFX.com

For further discussion on the gift tax generally see, AdvisorFX: Nature and Background of the Federal Gift Tax (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

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Life Insurance and the Generation—Skipping Transfer Tax

Posted by William Byrnes on November 15, 2010


Why is this Topic Important to Wealth Managers?  Provides details about one concept that wealth managers often overlook, the generation skipping transfer tax.  Also presents general concept themes and examples to show effective uses of life insurance and trust in consideration of the tax. 

In general, the generation-skipping transfer tax is levied on the value of life insurance that is transferred during the grantors lifetime or at death, to a skip person. [1]  The GST is levied in addition to estate and gift taxes. [2]

The generation-skipping transfer (GST) tax “scheduled to resume in 2011 at a rate of 55%, with a $1 million exemption. The rate was 45% in 2009, with a $3.5 million exemption.” [3]  For more information about the expiring tax cuts and new tax rates, see our blogticle: AdvisorFYI: Estate and Gift Taxes, Tax Cuts and More

“Certain direct gifts that qualify for the gift tax exclusion may also qualify for an annual exclusion that can be applied against the GST tax.” [4]  Many wealth managers encourage clients to take full advantage of the annual exclusion to avoid GST tax considerations at some later point.  However, “the expiration of the GST tax has complicated matters for wealthy individuals hoping to make 2010 gifts in trust that skip generations.” [5]  The use of trusts in consideration of the GST tax is discussed below.  For examples of insurance uses with trusts generally, see our previous blogticle: Trusts that Purchase Life Insurance; Known Formally as the “Irrevocable Life Insurance Trust

Please link to AdvisorFYI for the entire blogticle.

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Unqualified Disclaimers Can Create an Unexpected Tax Bill

Posted by William Byrnes on October 27, 2010


A disclaimer in the estate planning context is a voluntary refusal to accept a gift from a will. A properly structured disclaimer can be a great tax planning technique, allowing the person making the disclaimer to pass a gift on to the next person in line—for instance, someone in the next generation—without being subject to the gift tax.  But a disclaimer should not be made lightly because a disclaimer that is not “qualified” for tax purposes can create serious gift tax consequences for the person making the disclaimer.

The danger of an improperly made disclaimer was clearly illustrated in a recent U.S. District Court, Estate of Tatum v. U.S. There, Son disclaimed his interest in the residue of his father`s estate. But because Son`s disclaimer was not a qualified disclaimer, Son was treated as if he received the gift and then made a taxable gift to his children, resulting in a gift tax bill for Son and his wife of over $1,600,000.

Read this complete article at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For in-depth analysis of qualified disclaimers, see the AUS Main Libraries Section 7 B1—What Transactions Constitute Taxable Gifts

 

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GRAT Strategy for Avoiding Gift on High Premium Payments May Be Coming to a Close

Posted by William Byrnes on October 18, 2010


Life insurance-based estate planning strategies for high-net-worth clients with estate liquidity issues run into the problem that premiums may be so high as to exhaust the client’s annual gift tax exclusion and lifetime exemption, resulting in unwanted gift tax exposure.  One way advanced planners have dealt with the gift tax problem of high premiums is through the use of a grantor retained annuity trust (GRAT).  But the U.S. House recently passed a bill—H.R.4849, the Small Business and Infrastructure Jobs Tax Act of 2010—that would severely curtail the use of GRATs, so the utility of this technique may soon be eliminated.

To illustrate this technique while it remains open, let’s assume you have an unmarried client, Max, who owns a number of restaurant franchises. His estate will be worth about $12 million, most of which is tied up in his franchises and other illiquid investments. Max’s estate will need around $6 million in liquid death benefit to cover the pending estate tax liability.  Read today’s article in your Advisor’s Journal at GRAT Strategy (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For in-depth analysis of the topic of the use of GRATs, see Advisor’s Main Library Section 4. Estate Planning Techniques J—Grantor Retained Annuity Trusts

We invite your questions and comments by posting them below, or by calling the Panel of Experts.

Posted in Estate Tax, Taxation, Wealth Management | Tagged: , , , , , , , | Leave a Comment »

Gift Tax Return Disclosures—Adequate or Else

Posted by William Byrnes on October 1, 2010


A recent IRS Chief Counsel Advice addressed the importance of making adequate disclosures to the IRS when filing a gift tax return, demonstrating the dangers of a tight lip. There, a taxpayer failed to disclose the method and valuation discounts used to value gifted stock.  As a result, the taxpayer was unable to seek the protection from gift tax changes based upon the three year statute of limitations.

The statute of limitations for the IRS to question an item on a gift tax return is essentially unlimited if a gift is not “adequately disclosed” on the return, so taxes—and fees and interest—can be imposed on the inadequately disclosed gift any time after the return is filed.

For the complete analysis of this development regarding the disclosures required on a gift tax return by our Experts Robert Bloink and William Byrnes, please read the article via your AdvisorFX subscription at Gift Tax Return Disclosures—Adequate or Else?

For in-depth analysis of this topic, see Advisor’s Main Library Section 7. Gift Taxes D—Valuation For Gift Tax Purposes and from a tax perspective see Tax Facts Q 1534 What are the requirements for filing the gift tax return and paying the tax?

After reading the analysis, we invite your questions and comments by posting them below, or by calling the Panel of Experts.

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Gift Tax Return Disclosures—Adequate or Else

Posted by William Byrnes on September 25, 2010


A recent IRS Chief Counsel Advice addressed the importance of making adequate disclosures to the IRS when filing a gift tax return, demonstrating the dangers of a tight lip. There, a taxpayer failed to disclose the method and valuation discounts used to value gifted stock.  As a result, the taxpayer was unable to seek the protection from gift tax changes based upon the three year statute of limitations.

The statute of limitations for the IRS to question an item on a gift tax return is essentially unlimited if a gift is not “adequately disclosed” on the return, so taxes—and fees and interest—can be imposed on the inadequately disclosed gift any time after the return is filed.

For the complete analysis of this development regarding the disclosures required on a gift tax return by our Experts Robert Bloink and William Byrnes, please read the article via your AdvisorFX subscription at Gift Tax Return Disclosures—Adequate or Else?

For in-depth analysis of this topic, see Advisor’s Main Library Section 7. Gift Taxes D—Valuation For Gift Tax Purposes and from a tax perspective see Tax Facts Q 1534 What are the requirements for filing the gift tax return and paying the tax?

After reading the analysis, we invite your questions and comments by posting them below, or by calling the Panel of Experts.

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Estate and Gift Taxes, Tax Cuts and More

Posted by William Byrnes on September 14, 2010


Why is this Topic Important to Wealth Managers?  Author Ben Terner of the Panel of Experts offers detailed information that has a direct affect on clients’ planning objectives as it relates to estate and gift tax.   Provides a general discussion as well as detailed analysis of the current law and the affect of Congress’ current indecision.

Generally, “[g]ross income does not include the value of property acquired by gift, bequest, devise, or inheritance.” [1] Which means gift income or inheritance income received by the beneficiary is not taxable income to the individual who receives property by such gift, bequest, devise, or inheritance. [2] “Although the donated or inherited property itself is not taxable, income derived from such property is includable in gross income.” [3]

Read the analysis at AdvisorFYI

Posted in Tax Policy | Tagged: , , , , , , , | 2 Comments »

Capital Gains Increasing Importance for Valuation Discounts: Jensen v. Commissioner

Posted by William Byrnes on August 25, 2010


A recent Tax Court case makes up for some of the ground lost by FLPs in recent cases reining in more aggressive valuation discounts. In Jensen v. Commissioner (T.C. Memo 2010-182), an estate holding an interest in a closely-held corporation that owned fairly significant real estate won its case against the IRS.

Today’s analysis by our Experts Robert Bloink and William Byrnes is located at AdvisorFX Journal Capital Gains Increasing Importance for Valuation Discounts: Jensen v. Commissioner

For a detailed analysis of Valuation For Gift Tax Purposes, see AdvisorFX Main Library Section 7. Gift Taxes D—Valuation For Gift Tax Purposes.

After reading the analysis, we invite your questions and comments about indexed annuities by posting them below, or by calling the Panel of Experts.

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