Taxation financial instruments

Taxation financial instruments 7) Bill 2018 ("the Bill") was gazetted. Investments in the financial instruments of Russian issuers entail additional obligations for the investor that are set forth in the normative acts of the Russian Federation which regulate taxation of the income from the financial instruments of Russian issuers. 2 Contents The taxation of financial services is a complex and technically difficult subject; both in terms of the products themselves and the context in which financial transactions are undertaken. edu is a platform for academics to share research papers. Part II is for other types of financial assets, such as stocks, bonds, and other financial instruments. We will explore concepts related to the time value of money, the distinction between debt and non-debt instruments, and the ramification of such distinctions. The scope of the tax is restricted to equities (and assimilated instruments) and equity derivatives. *FREE* shipping on qualifying offers. Federal Income Taxation of Debt Instruments is the definitive reference for the many complicated issues involved with debt instruments. INTRODUCTION IFRS 9 Financial Instruments1 (IFRS 9) was developed by the International Accounting Standards Board (IASB) to replace IAS 39 Financial Instruments: Recognition and Measurement (IAS 39). [Organisation for Economic Co-operation and Development. We are a multi-disciplinary team with a passion for financial instrument-related issues. A financial package’s or product’s profitability is dependent on its tax treatment. 2012 · Access study documents, get answers to your study questions, and connect with real tutors for ACCOUNTING 649 : Taxation of Financial Instruments at Rutgers University. You can download handouts of Autor: Silvia M. Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the16. 2016 · FRS 102 Summary – Section 11 – Basic Financial Instruments. ThiIt has been acknowledged that the tax treatment of financial instruments for financial institutions deviate substantially from the accounting treatment, hence the decision to amend the tax rules to be more aligned with the accounting treatment under the International Financial …Taxation of financial instruments. TAXATION OF FINANCIAL INSTRUMENTS. 1. ER - Orow B, Subramaniam R. This article is the first part of a two-part discussion on this topic. The OECD in its 1994 report entitled “Taxation of New Financial Instrument” provides for a comparative analysis of the tax treatment of four kinds of financial instruments: interest rate swaps, financial futures, option to buy shares and deep-discount bonds. Subordination relief for entities in financial distress. We can also settle them. Let us look into the accounting and tax treatment of these financial instruments. Scope of the Study 1. This Guide to the taxation of financial arrangements (TOFA) rules. . [1 February 2009] - Italy - Tax treatment of derivatives embedded in hybrid financial instruments for Italian adopters of IAS/IFRS [1 February 2009] - Denmark - An introduction to the taxation of financial instruments [01 Dec 2008] - Financial products audits : understanding the process and the issues01 Jun 2000 - Discussion on the taxation of financial instruments, particularly derivatives, in Hong Kong. PY - 1999. It gives you the practical tax-planning guidance needed to understand the tax consequences of these sophisticated transactions. IFRS IN PRACTICE 2018 fi IFRS 9 FINANCIAL INSTRUMENTS 5 1. Relevant to ACCA Qualification Papers F7 and P2. INDIRECT TAX TREATMENT OF FINANCIAL SERVICES AND INSTRUMENTS Report of the OECD 22 October 1998. Organisation for Economic Co-operation and Development. Taxation of Financial Instruments. Subject 730-844 (2008) Note: This is an archived Handbook entry from 2008. com The summary of IFRS 9 Financial Instruments updated in 2017 and ready to implement as at 1 January 2018. Financial assets on revenue account; b. companies are taxed on all income accrued or derived from Singapore. Note: Citations are based on reference standards. Taxation Masters Dissertation only: View Info: FTX5005W: Taxation Masters Dissertation only: View Info: FTX5028W: Topics in Financial Management: View Info: FTX5029W: Minor-Dissertation in Financial Management (60 credits) View Info: FTX5030W: Taxation Coursework: View Info: FTX5031W: Taxation Minor Dissertation: View Info: FTX5032W: Taxation It is recognised by the G20, the OECD and the European Commission that mismatches by hybrid finance instruments are one of the most important tools for multinationals in lowering their worldwide corporate income tax liability and that therefore the use of these instruments in tax …Amendments to IAS 12: Income tax consequences of payments on financial instruments classified as equity Paper topic Analysis of feedback on the proposed amendments CONTACT(S) Kan Hara Takashi Yamagami khara@ifrs. 2019 · Most companies will have financial instruments in their portfolios. After noting thatThe bill, approved by the Italian Parliament on the 29th December 2012, sees the Italian Financial Transaction Tax (IFTT) on all transfers of ownership enter into law on 1st March 2013. The Standard includes requirements for recognition and measurement, impairment, derecognition and general hedge accounting. nla. 1. UPDATE 2018: IAS 39 is superseded for the periods starting on or after 1 January 2018 and you have to apply IFRS 9 Financial Instruments. This article follows on from Paul Martin’s ‘Mind the GAAP’ article in the May 2016 issue of Business Tax Voice about the impact of new generally accepted accounting practice (GAAP) on the quantification of taxable trading profits. IFRS IN PRACTICE 2016 fi IFRS 9 FINANCIAL INSTRUMENTS 5 1. Taxation of new financial instruments | National …Przetłumacz tę stronęhttps://catalogue. In the context of financial markets, derivative financial instruments are mainly used for hedging and speculation. Arbogast and Michael K, Yaghmour] on Amazon. 07. All are evaluating the FASB's credit losses guidance to be ready for the effective date of January 1, 2020. org +44 (0)20 7246 6968 +44 (0)20 7246 6937The current state of taxation of financial instruments is a mess. S. If you would like to know more about this process, please read our article IAS 39 vs. 01. Keyes (WG&L, 2005), is a resource that analyzes the taxation of both traditional stock and bond transactions, as well as emerging hedging strategies and instruments, including derivatives. gov. kentlaw. Although news of such instruments frequently appears in the financial press, from the Nick Leeson affair' to recent disputes involving Bankers Trust2 and Merrill Lynch,3 the features of these instruments are rarely described. 2019 · Federal Taxation of Financial Instruments and Transactions analyzes the taxation of both traditional stocks and bonds transactions as well as emerging hedging strategies and instruments, including derivatives. Our Firm provides assistance to banks, financial institutions and investment funds in relation to Italian and international financial transactions. A failure to pay, along with evasion of or resistance to taxation, is punishable by law. 2016 · SMEC International, the Managing Contractor, seeks applications for a qualified Financial Instrument Taxation Adviser. The information in this memorandum does not replace the law found in the Excise Tax Act and its Regulations. M3 - Article. Initially, it was contemplated that, for each of the below questions, and where applicable, theA few weeks ago, we published the article about How to Implement IFRS 9 to assist you with the adoption of the major forthcoming IFRS update. JF - Derivatives and Financial Instruments. Foreign income Hong Kong Tax Newsflash: Taxation of Financial Instruments under IFRS / HKFRS 9 Introduction On 2 November 2018, Inland Revenue Amendment (No. financial instruments, their basic tax treatments, as well as the tax considerations at play. 26. Areas of expertise include also the taxation of equity and debt instruments, stock options, derivatives and innovative financial products. Downloadable! the Commission has instructed PwC to provide a review of the current tax provisions directed at the Financial Sector and financial instruments. Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence ofIntroduction to U. Tax Implications of Adoption of IFRS9 on Financial Instruments in Nigeria Tax Implications of Adoption of IFRS9 Since 2001, IAS 39 Financial Instruments - Recognition and Measurement has been the accounting standard for financial instruments. Taxation of Financial …Taxation of Financial Instruments. AU - Orow, Bill. 1 This e-Tax guide sets out the income tax treatment of hybrid instruments, including the factors generally used to determine whether they are debt or equity instruments for income tax purposes. Taxation of Financial Products & Derivatives >>>>> April 27 & 28, 2015 • New York, NY • Bloomberg LP A two-day, introductory-level course with live group instruction on the basic economic and U. However, formatting rules can vary widely between applications and fields of interest or study. In recent times, this form of financial instrument is becoming increasingly popular in the Nigerian financial market; hence, the need to understand the tax implications. (of IFRSbox)Wyświetlenia: 263 tys. Illustrative disclosures: IFRS 9 Financial Instruments VALUE IFRS 9 Plc The IASB issued the final version of IFRS 9 Financial Instruments in July 2014, which replaces earlier versions of IFRS 9 issued in 2009 and 2010 (classification and measurement requirements) and …Derivative financial instruments are, for many persons, shrouded in mystery. SP - 237. These liabilities are subsequently measured at amortised cost using the effective interest method, with interest expense recognised on …Taxation of Financial Instruments. The IASB completed IFRS 9 in July 2014, by publishing aTax Implications Related to the Implementation of FRS 139 : Financial Instruments: Recognition & Measurement 3 incremental cost is one that would not have been incurred if the entity had not acquired, issued or disposed of the financial instrument. We can create, trade, or modify them. e. Purpose and Scope of this Chapter 1. Search for this in the current handbook Search for this in the current handbookIncome Tax Treatment Arising from Adoption of FRS 109 – Financial Instruments 4 4. The content of the Study is limited to the questions raised by the Commission in the questionnaires provided and is subject to certain limitations in terms of scoping as agreed by the Commission and detailed below in introduction of the Academia. IAS 32 outlines the accounting requirements for the presentation of financial instruments, particularly as to the classification of such instruments into financial assets, financial liabilities and equity instruments. They can also be seen as packages of capital that may be traded. This seminar examines the taxation of financial instruments and focuses on their economic and business substance as well as on tax policy. Financial instruments can be either cash instruments or derivative instruments: Cash instruments – instruments whose value is determined directly by the markets. 13. ;] -- Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to …Taxation of Financial Instruments. Financial liabilities are recognised and derecognised upon ‘trade date’. IFRS 9: Clarifying the Confusion. IFRS 9 Financial Instruments is the more recent Standard released on 24 July 2014 that will replace …Investments in the financial instruments of issuers registered in the United States of America (hereinafter — US issuers) entail additional obligations for the investor that are set forth in the US normative acts which regulate taxation of the income from the financial instruments of US issuers. The exam for the course is an six-hour take home examination. Effectively, therefore, changes in the fair value of both the host contract and the embedded derivative now will immediately affect profit and loss. Creatrust is a leading independent provider of corporate, fund and family office services to international clients who want to be established in LuxembourgThe lack of matching in these scenarios for taxation purposes exists because although the hedge instrument is within the financial arrangement rules, the taxation of the hedged item depends on whether the underlying item is on revenue or capital account. EP - 249. Larkins, Tyler L. The bill, approved by the Italian Parliament on the 29th December 2012, sees the Italian Financial Transaction Tax (IFTT) on all transfers of ownership enter into law on 1st March 2013. 02. Public companies have adopted the FASB's recognition and measurement guidance and private companies are adopting throughout 2018. Financial instruments are assets that can be traded. com. Financial instruments present a serious challenge to the tax system since they blur fundamental distinctions of the tax system such as the distinction between ordinary income and capital gains and create avoidance opportunities. Guide to taxation of financial arrangements (TOFA) The Taxation of Financial Arrangements (TOFA) reforms were first publicly announced as part of the 1992 federal budget in which the government identified a need for reform of the taxation treatment of financial arrangements. ‘Other financial liabilities’ are initially measured at fair value, net of transaction costs. The content of the Study is limited to the questions raised by the Commission in the questionnaires provided and is subject to certain limitations in terms of scoping as agreed by the Commission and detailed below in introduction of the TFITC - Taxation of Financial Instruments and Transactions Committee. The computational rules for loan relationships are set out in CTA09/PT5/CH3. Tax Implications Related to the Implementation of FRS 139 : Financial Instruments: Recognition & Measurement 3 incremental cost is one that would not have been incurred if the entity had not acquired, issued or disposed of the financial instrument. 2017 · I am busy correcting my tax returns but have a query on financial instruments listed. tax implications arising from the adoption of FRS 109. VL - 1. A tax (from the Latin taxo) is a compulsory financial charge or some other type of levy imposed upon a taxpayer (an individual or legal entity) by a governmental organization in order to fund various public expenditures. BCF’s experts in the taxation of financial products understand this and are proud to be among the first in Canada to offer monetisation to our clients. Bloomberg Tax and Accounting Portfolio 5185, Financial Instruments: IFRS 9—Classification and Measurement, explores how an entity classifies and measures nonderivative financial instruments under International Financial Reporting Standards (IFRSs), with a focus on the requirements of IFRS 9, Financial Instruments (as of July 2014). Introduction to Accounting for Financial Instruments IFRS 9 and IAS 39 are two most important accounting standards for corporate treasurers because they address how to account for financial instruments, or how they are measured on an ongoing basis. It is provided The aim of the "Taxation papers" is twofold: to facilitate the spreading of the analysis of the Commission's Taxation and Customs Union DG and to contribute to the debate on taxation in the European Union. Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This publication will consist of a series of working papers written by Commission staff or by experts working in association with them. This 06. IS - 5. I shall look in more depth at corporation tax and income tax adjustments for financial instruments, focussing mainly on loans to shareholders, but also treatment of derivative financial instruments in South Africa. The IASB completed IFRS 9 in July 2014, by publishing a finalDecide whether to elect to set aside the tax charge on profit and loss movements on financial instrument. 18. We do not assume prior knowledge of financial instruments or financialIf you recall, RR 14-2012 was issued by the BIR (1) to properly implement the income taxation of interest income earnings on financial instruments and similar transactions based on existing laws and regulations, and (2) to rationalize the tax exemptions of interest income derived from such instruments. IAS 39 is a standard fully replaced by the new standard on financial instruments IFRS 9 applicable from 1 January 2018. Australian/Harvard Citation. The income tax treatment of gains or losses of financial instruments recognised under FRS 109 under section 34AA of the ITA and the e-Tax guide (known as the FRS 109 tax treatment), largely aligns the tax treatment of financial instruments on revenue account to the accounting treatment 04. There is a whole array of instruments called derivatives, but the majority constitutes variations on three basic instruments: forwards/futures, swaps and options. Basic financial instruments coming within the scope of section 11 are: consider the tax impact as a result of The current state of taxation of financial instruments is a mess. au/Record/1911119Taxation of new financial instruments Organisation for Economic Co-operation and Development ; OECD Publications and Information Centre [distributor] Paris : Washington, D. Many accountants and CFOs are worried about IFRS 9, there are numerous discussions going on about it, but not everybody has the clear vision about WHAT is a financial instrument. Master of Commerce, Taxation An analysis of the South African tax policy on hybrid debt instruments with reference to international developments A research report submitted to the Faculty of Commerce, Law and Management in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation)Federal Income Taxation of Debt Instruments - 2019 Edition [David C. 2017 · http://www. The dissertation considers whether the current South African Income Tax Act deals with the income taxation of derivatives with respect to gains and losses and theFederal Taxation of Financial Instruments and Transactions analyzes the taxation of both traditional stocks and bonds transactions as well as emerging hedging strategies and instruments, including derivatives. Y1 - 1999. The standard also provide guidance on the classification of related interest, dividends and gains/losses, and when financial assets and financial liabilities can be offset. 2019 · Part I is for financial accounts, such as a deposit or custodial account with a financial institution. The role is based in Jakarta for up to 60 working days until June 2017. 08. Section 11 – Basic Financial Instruments Summary. tax aspects of typical fi nancial products and derivative instruments used in fi nancial markets today. The hybrid debt rules pertaining to subordinated instruments were found to give rise to adverse tax implications (such as the non-deduction of interest and potential liability for dividends tax) for companies already in financial distress. 11. Part III is a summary showing where income from the foreign financial assets is reported elsewhere on the tax return. This section explains the components of the definition of "financial instrument" as it relates to the provision of financial services under the Goods and Services Tax (GST). The specific requirements or preferences of your reviewing publisher, classroom teacher, institution or organization should be applied. Our professional activities in this sector include a wide array of consultancy services, both in relation to the drafting and negotiation of multilateral financial Tax attributes of financial instruments in Singapore. Blum, Richard G. SN - 1389-1863. Historically, manyTaxation and accounting treatment of financial instruments and transactions - essential news and topical coverage for accountants, lawyers & tax advisers. The …equity instruments vest on the earlier of Restricted any of the following events: (a) All the relevant restrictions on an equity instrument cease to have effect. The Bill contains draft rules covering a number of areas, including: the taxation of financial instruments under new International and Hong Kong Financialtaxation of financial instruments. The key principles outlined in section 307 and 308 of CTA09 are that the amounts to be brought into the corporation tax computation are the 'credits and debits' which:IFRS 9 Financial Instruments issued on 24 July 2014 is the IASB's replacement of IAS 39 Financial Instruments: Recognition and Measurement. AU - Subramaniam, Rama. In Unit 1 we will discuss the tax treatment of debt instruments. Decide whether, in certain circumstances, hedge accounting is appropriate for the financial instruments to protect the volatility of the profit and loss account and therefore the tax charge. The rules are complicated, unfair, inconsistent, and patchwork; because Congress creates rules for new instruments in reaction to perceived abuses, there is no underlying policy or vision guiding the development of the rules. Search for this in the current handbook Search for this in the current handbookA financial instrument is a monetary contract between parties. C 1994. Search for this in the current handbook Search for this in the current handbookEditorial Note This standard supersedes IAS 39 Financial Instruments: Recognition and Measurement and IFRIC 9 Reassessment of Embedded Derivatives with effect for accounting periods beginning on or after 1 January 2018. (b) Immediately after termination of – (i) an option to acquire a restricted equity instrument; or (ii) a financial instrument which is convertible into a restricted equity instrument. iit. 1 Where the FRS 39 tax treatment applies, the tax treatment is aligned with the accounting treatment under FRS 39 for the following: a. Bonds, which are contractual rights to receive cash, are financial instruments. Most types of financial instruments provide an efficient flow and transfer of Review of current practices for taxation of financial instruments, profits and remuneration of the Financial Sector 11/09/12 3 of 72 CHAPTER 1: Corporate Taxation of the Financial Sector 1. As financial instruments are a vast area, this is the first in a series of articles looking at financial A financial instrument is a contract that gives rise to a financial asset in one entity and a financial liability or equity instrument of another entity. Grades will be based largely on the final examination, but one or more short quizzes may be given during the course, and up to …KPMG's Financial Instruments Group is committed to providing KPMG clients and staff with cutting edge financial instrument accounting guidance that will aim to provide you with clear, practical solutions. 09. Basic financial instruments coming within the scope of section 11 are: consider the tax impact as a result of The OECD in its 1994 report entitled “Taxation of New Financial Instrument” provides for a comparative analysis of the tax treatment of four kinds of financial instruments: interest rate swaps, financial futures, option to buy shares and deep-discount bonds. Tax issues for financial instruments under new UK GAAP – Part 1 Business Edge bulletin from BDO, published in March 2014, examining fair value movements. Section 11 defines basic financial instruments for all companies with the exception of public benefit entities. ifrsbox. ;] -- Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to …30. A financial instrument may be evidence of ownership of part of something, as in stocks and shares. This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems. INTRODUCTION IFRS 9 (2014) Financial Instruments1 has been developed by the International Accounting Standards Board (IASB) to replace IAS 39 Financial Instruments: Recognition and Measurement. 2005 · * Federal Taxation of Financial Instruments & Transactions, by Kevin M. IFRS 9 financial instruments— Understanding the basics . T1 - Taxation of Financial Assets. WHAT IS A FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland splits the issue of financial instruments into two sections: Section 11 Basic Financial Instruments and Section 12 Other Financial Instruments Issues. The fact that the model is simpler than IAS 39 doesn’t necessarily mean that it is simple. Hybrid Financial Instruments in International Tax Law examines the tax issues affecting the use of hybrid financial instruments (HFIs). This section explains the components of the definition of 'financial instrument' as it relates to the provision of financial services under the Goods and Services Tax (GST)Tax issues for financial instruments under new UK GAAP – Part 2 Business Edge bulletin from BDO, published in April 2014, looking at first-time adoption adjustments and disregard regulations. Course outline: This course forms part of the BCom Honours in Taxation and Master of Commerce in Taxation streams (see CH001FTX11 and …FRS 102 overview paper - Corporation Tax implications Updated 21 July 2017 Where a financial instrument is measured on a different basis under FRS 102 compared with Old UK GAAP it’s likely Financial Accounting Notes Accounting Standards for Private Entities (ASPE) International Financial Reporting Standards (IFRS) Accounting Standards for Not-For-Profit Organizations (ASNPO)It has been acknowledged that the tax treatment of financial instruments for financial institutions deviate substantially from the accounting treatment, hence the decision to amend the tax rules to be more aligned with the accounting treatment under the International Financial …Taxation of Financial Instruments. edu/courses/law-722-taxation-of-financial-instrumentsA study of the federal income tax aspects of financial instruments, including stocks, bonds, options, forward contracts, convertible and contingent payment debt instruments, and transactions involving financial instruments, including wash sales, short sales, straddles and notional principal contracts. Explore PwC's latest thinking on not just these projects, but all financial instruments. They can be securities, which are readily transferable, and instruments such as loans and deposits, where both borrower and lender have to agree on a transfer. 06. However, the Standard was affected by several shortcomings, such as complex and rules-based The dissertation deals with the taxation treatment of derivative financial instruments in terms of the Income Tax Act 58 of 1962 (“the Act”), and seeks to answer the question as to whether the Act contains adequate provisions for the taxation of such derivatives. After noting thatThe course purpose is to equip students with advanced taxation technical knowledge on the taxation of financial instruments. You must take the exam on either Saturday, 24 February, or Sunday, 25 February. FRS 102 classifies financial instruments as either basic financial instruments or other financial Get this from a library! Taxation of new financial instruments. Looking for abbreviations of TFITC? It is Taxation of Financial Instruments and Transactions Committee. 4 Effective dateTax Implications of Adoption of International Financial Reporting Standard (IFRS) 9 on Financial Instruments in Nigeria It is, therefore, important for DMBs particularly, and other companies within the financial services space, to assess the tax impact of the adoption of IFRS 9 in order to take advantage of available tax planningGet this from a library! Taxation of new financial instruments. Autor: David C. 4 Effective dateIFRS 9 Financial Instruments. Does my retirement annuity(s) value also need to be submitted as part of this value at the value it was on the 28th of February? The same questions goes for my TFSA which consists of stocks? This entry was posted in Tax Q&A and tagged Retirement, Dividends. The firm advises on securitizations, domestic and international financing, debt restructuring, leasing transactions and project finance. Garlock, Matthew S. JO - Derivatives and Financial Instruments. GarlockLAW 722: Taxation of Financial Instruments | …Przetłumacz tę stronęhttps://www. Common financial instruments would include cash, trade debtors and interest rate swaps. Let us start by looking at the definition of a financial instrument, which is that a financial instrument is a contract that gives rise to a financial asset of one entity and a financial liability or equity instrument of an other entity. General tax policy and financial principles relevant to the income tax treatment of financial instruments; Australian tax law applicable to financial instruments including TOFA, Div 16E and other securities provisions, debt/equity rules, finance leases and Div 250Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. org tyamagami@ifrs. For tax purposes, the general principle is that the tax treatment follows the accounting treatment because for most companies, most financial instruments will fall to be classed as loan relationships (under Part 5 CTA 2009), non-lending money debts (treated as loan relationships under Chapter 2 of Part 6 CTA 2009 01. Current Tax Treatment 4. The taxation of financial instruments is, to a large extent, covered by the loan relationship rules. Singapore taxes income on a quasi-territorial basis, i. Their purpose is solely for capital appreciation and income Taxation financial instruments
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