The grade for this course will be based primarily on papers that students submit addressing policy topics discussed by the guest speakers. 2022 KPMG, a Maltese civil partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. , Article 12 (3) Taxation of Royalties when a Permanent Establishment exists in Source State, Key Questions to understand Application of Article 12(3), Article 12 (4) Excess Payment due to Special Relationship between Payor and Payee. At the same time, the course is intended to challenge the student to be aware of the ethical challenges and risks of practice in the area of international taxation. Advanced Diploma,Under Graduate Degree. The ECJ itself cannot harmonize the tax systems, however, the Court can force the member states to open their tax systems for tax competition within Europe. All rights reserved. Read more. They determine whether bank accounts in Switzerland and Liechtenstein are really secret. NQF level: 7. Prerequisite: Prerequisite: Federal Income Taxation (formerly Taxation I) and either prior or concurrent enrollment in Corporate Taxation (formerly Taxation II) or Corporate Income Tax I. Toggle Graduate Degree and Certificate Programs, Administrative Law, Legislation, and Governance, Intellectual Property, Entertainment, and Technology Law, International and Comparative Legal Studies, International Law / Finance and Investment, International Law / Intellectual Property Law, JD/MPH (Health Care Financing, Organization and Delivery), Legal Profession/Professional Responsibility, Real Estate, Land Use and Urban Development, Two-Year LL.M. LAW058v06 International Tax and Business Planning Workshop, LL.M Seminar (cross-listed) | 3 credit hours. KPMG International entities provide no services to clients. This course concentrates on real world civil and criminal tax controversies involving international tax matters facing todays tax practitioners. There will be no final exam. Failure to attend the first class session in its entirety will result in a drop; failure to attend any subsequent class session in its entirety may result in a withdrawal. IBFD - IFA LATAM Webinars, News on International Taxation and Its Impact in Latin America. Georgetown Law is a member of the State Authorization Reciprocity Agreement (SARA), which allows online programs that demonstrate compliance with their home state's authorization requirements to enjoy reciprocal authorization in all other SARA states, which include D.C., Puerto Rico, and all U.S. states except California. All learning programmes are offered under the auspices of the KPMG Learning Academy. Permanent home - What constitutes Permanent Home to determine residence ? 1-3 Months IE Business School Globalization, Economic Growth and Stability 1.3 Course, -Official Introduction to P-CMMVer. The objective of the exercise will also vary from week to week --for example, a pre-filing conference memo aimed at persuading the IRS National Office international rulings personnel to respond favorably if a request is filed on a cross-border spinoff; the executive summary of a Competent Authority request to resolve a withholding tax interpretative issue under an applicable treaty; strategic analysis and recommendations regarding the most tax effective approach to bring products to the EU or APAC market, to finance an international acquisition or to tax-effect losses incurred in a particular country operations. COBIT is a registered trademark of Information Systems Audit and Control Association (ISACA). Japan Consumption tax rate in 2020 If the applicable period for your consumption tax liability is from October 1, 2019 onwards, the following tax rates apply. Show more. Mutual Agreement - Determination of Residence by Competent Authority, Article 4(3) of OECD Model - Tie breaker other than an Individual. However, students will be expected to have a basic understanding of the U.S. tax rules that apply to foreign persons who receive income from the United States and U.S. persons who receive income from abroad. Purpose: The aim of this module is to provide students studying towards an accounting degree with a well-rounded and systematic knowledge . In addition to transfer pricing, students may choose paper topics from other international tax topics with a practical application including permanent establishments, tax treaties, international arbitration, and the competent authority process. Centre of vital interest - Importance in Determination of Residence. 2.0 Overview Training Course, -Data Management Maturity Model Training, -Insight to CMMIVer. It is designed to be an interactive experience, with students working on case studies, discussing alternative approaches, and using different jurisdictions and changes in the form of the underlying transaction to achieve desirable tax results. Note: J.D. In these podcasts, KPMG professionals discuss U.S. international tax and OECD-related tax guidance and provide concise, practical insights about the impact on multinational enterprises. All sessions will be taught by global indirect tax professionals from KPMGs Washington D.C. office. Prerequisite: Prior or concurrent enrollment in Corporate Income Taxation I (or the JD course, Corporate Taxation (formerly Taxation II)) and a course in international taxation. This colloquium will offer students an opportunity to examine current tax policy issues in depth and at an advanced level, with discussions led by policymakers, economists, and other tax experts. International Taxation Course - CA Arinjay Jain Online Classes - Recorded Lectures Presentations, Case Studies and Practical Issues on International Tax Fees - INR 9,999 / USD 200 until 1st July - Early Bird Discount (Additionally 25% Discount for ICAI , CMA and CS Student) Certificate of Completion Example Curriculum Article 1 - Person Covered September 2021 Looking for international taxation course by kpmg? Our dynamic program develops curious and thoughtful tax leaders who become prepared for future careers in the field. International Taxation Course - CA Arinjay Jain - Recorded International Tax Course is available on scheduled manner. View all news | View all events. Click here for programme details and schedule. Mergers & Acquisitions Tax. Taxation of Partnership Firms - Are they Liable to tax? APMG International ISO/IEC 20000 is a trademark of The APM Group Limited, All rights reserved. However, this potential for new business opportunities also comes with increased complexity and potential exposure. By the end of the course, students are expected to be able to understand where the borders of ethical behavior are when developing international tax structures and to be able to analyze risks to the clients and themselves when working in this area. To learn more, please contact: 5) Enforcement issues. course Corporate Transactions, or the J.D. KPMG can support you in . Day 1-An overview of International Taxation and Principles of International Tax Law. with Certificate in Legal English for Foreign-Trained Lawyers, J.D./LL.M. The Certificate is open to both U.S. and foreign-trained lawyers, as well as non-attorney taxprofessionals, and can be completed together with the Tax LL.M. Students that plan to study on an F or J Visa may apply to graduate programs only. In 2017 the United States enacted a historic tax reform package that represents the most significant change to the U.S. international tax regime since 1986. Note: Enrolled students will have until the beginning of the second class session to request a drop by contacting the Office of the Registrar; a student who no longer wishes to remain enrolled after the second class session begins will not be permitted to drop the class but may request a withdrawal from an academic advisor in the Office of Academic Affairs. KPMG in India's International Tax and Regulatory Services team comprises dedicated tax professionals with in-depth technical knowledge and practical experience, who the client can trust in relation to corporate tax and regulatory matters. International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries or the international aspects of an individual country's tax laws as the case may be. Course Syllabus. 6) Administrative procedures, including IRS examinations, APA procedures, and competent authority procedures, and 7) Looking toward the future: what are the most appealing policy options today? All rights reserved. This session is aimed at equipping the attendees with a brief overview of the identified fields within the international tax arena in order to enable them to identify issues that may require further detailed analysis, and prepare them for the novel measures being proposed at an international level. Cancel anytime from the account management page. In addition, we will consider the major international tax policy documents published by the OECD and the relationship between the negotiations at the OECD and U.S. international tax policy developments. To celebrate this landmark, Deloitte today announces the launch of a new talent development initiative - INspire HK: Future . Article 11(3) - What is regarded as Interest ? Recommended: Prior or concurrent enrollment in a course in international taxation. Ruth is a warranted lawyer and graduated with a Doctor of Laws from the University of Malta in 2016. This course is intended to teach the concepts underlying the United States Model Tax Treaty and the OECD Model Tax Treaty. . in International Business and Economic Law, LL.M. Article 4(1) of OECD Model Who is Resident ? In the past, he has worked on several clients from US, Germany, Singapore, Netherlands and UK in respect of setting up their Indian operations and acquisitions of various business in India. IFRS 17 Challenges - Audit, Accounting, Regulatory and Tax Aspects - In practice, Transfer Pricing Deep Dive Series: Transfer Pricing Compliance in Malta, Transfer Pricing Deep Dive Series: Intangibles and Cost Contribution Agreements, Transfer Pricing Deep Dive Series: Business Restructuring, Updates: Income Tax and Duty Highlights for the Year 2022. Keeping tax positions up to date. The course uses examples drawn from actual practice to illustrate the creative use of tax treaty provisions. We will also look at selected provisions of the OECD Model Tax Convention. . You can define and understand complex topics such as transfer pricing, value added taxation, double taxation and much more with these curated courses, created by our international tax experts. We are not sure what might have caused this error, but our team has been automatically notified and will start looking into it as soon as possible. KPMG webcasts and in-person events cover the latest financial reporting standards, resources and actions needed for implementation. The form, format and audience for the deliverable will vary from week to week --a technical tax law memo for the VP-Tax, a tax/financial analysis for the CFO, a strategic powerpoint presentation to the CEO or Board, a submission to a foreign tax administration, a legislative, treaty or regulatory proposal, an outline for an oral argument in an international tax case before a Federal Circuit panel. We will also speak with government representatives involved in crafting the regulations and negotiating multilaterally. Passthroughs & Partnerships. Students will learn the various international tax reporting obligations, applicable statutes of limitations and tolling provisions, potential civil penalties under the Internal Revenue Code and the Bank Secrecy Act, options for resolving non-compliance, procedures for challenging proposed and assessed penalties, and the risk of criminal investigation and prosecution. Ruth also regularly delivers classes in various courses relating to international tax. Adjustment By State of Residence or State of Source, Article 7(4) - Income Dealt with in other Article of Treaty, Article 8 - International Shipping And International Air Transport, Article - 8(1) - Exclusive Right of State of Residence To Tax Profits, Meaning Of International Traffic Article 3(1) ( e), Article 8(1) Alternative - Tax based on Place Of Effective Management, Specific Income which are Taxable Under Article 8, What is Inland Waterways Transport and its relevance for Article 8, Permanent Establishment impact on Article 8, Article 8(2) Profits From Pool, Joint Business Agreements and international operating agency, Article 9 Associated Enterprises - Objective and Guidelines, Article 9(1) Adjustment to Taxable Profits between Associated Enterprises, Examples of Direct or Indirect Participation, Thin Capitalisation and Application of Arms Length Principle, Control and Application of Arms Length Principle, Article 9(2) Corresponding Adjustments - Case Study, Methods and Process Flow, Secondary Adjustment Not covered under para 2New Lecture, Overview, Meaning and Tax aspect of Dividend, Article 10(1) - Right of State of residence to Tax Dividend. What is included within Royalties - Examples ? Article 10(2) - Right of Source State to Tax Dividend, Beneficial ownership of Dividend - Meaning and case study, Third Party Beneficial Owners of Dividend, Beneficial ownership and Test of beneficial ownership, Article 10(4) - Taxation of Dividend Connected to PE or Fixed base, Article 10(5) - Right to tax dividend declared by Foreign Co. From income from Source State, Article 11 - Interest - Overview of Article 11, Learning Aspects of Article 11 - Interest, Article 11 (1) Right of State of Residence to Tax Interest, Case Study - 1 - Interest Taxed on Payment Basis, Case Study 2 Interest From Third State Person, Case Study 3 Interest Attributable to PE in Third State, Deduction of interest based on Residence of Recipient of Interest, Article 11 (2) - Right of Source State to Tax Interest, Case study Third State beneficial owner of interest, Third Party Beneficial Ownership - Examples and Cases, Disadvantage of Gross Taxation Example - Banks, Case Study Gross WHT and impact on International Trade, Interest Exemption - Other Contracting State is Recipient, Interest Exemption - Contracting State is Payor, Interest Exemption - Export Financing Agencies and Programmes, Interest Exemption - Interest paid to financial institutions, Interest Exemption - Credit Sales and interest on Delayed payment. Day 2-Model Tax Conventions on Double Tax Avoidance. The course will address both how individual and corporate foreign taxpayers are taxed by the United States, and how U.S. individual and corporate taxpayers are taxed by the United States on income earned in or from other countries. Mutually Excluded Courses: Students may not receive credit for both this course and the J.D. The experience also include work in various transactions spanning across solar power, technology startups, pharmaceuticals, automobile manufacturing, online e-commerce companies, logistics, manufacturing, solar power, trading companies, financial services, social networking, telecommunication, beverage and bottling and others. This course will study current developments in US international tax policy through a close reading of selected tax regulatory packages associatedwith the2017 tax reform. Module presented in English. The International Taxation Committee helps members to build their working knowledge on the provisions of International Taxation laws and to acquire an analytical approach to apply this working knowledge to specific problem areas in a variety of practical situations. U.S. National Leader, M&A Tax, KPMG US +1 925-895-1276. The Certificate in International Taxation can also be completed entirely online. Enrolled students must be in attendance at the start of the first class session in order to remain enrolled. KPMG Tax Business School Brochure View the KPMG Tax Business School Brochure (PDF 900KB) Download pdf (1.2 MB) . Most legislative measures of the European Union in this area require the consensus of all 27 member states. To know more about other programmes offered, click here . This course analyzes the tax treatment, issues, planning techniques and underlying government policies involved in doing business internationally. Watch: Sanjana Rao LLM '22 on how the program expanded her range as a lawyer. + View More. The webinars aim to discuss trending topics in international taxation, particularly those with an impact on Latin America. The course begins with an introduction to the U.S. compliance regime, including the obligation to report worldwide income, specified foreign financial assets and international business activity. Overview of Article 5 - Permanent Establishment. Taxation of International Transactions. Article 5(1) When does a Fixed Place PE arise under DTAA ? The Workshop will use a "case study" approach to address the myriad technical, practical and strategic issues involved in counseling a company as it evolves from astart-up operating out of its founder's garage (in the first week of the semester) to a Fortune 100 global powerhouse with operations on every continent. She read her Advanced Masters in International Taxation at the International Tax Centre, University of Leiden in the Netherlands and graduated cum laude in 2018. Requirements for U.S.-Trained Students and all Online Students: Requirements for Foreign-Trained Students: Contact Information About this course: This course is for accounting, tax, and finance professionals; international business managers; and lawyers who work with cross-border transactions involving the United States. This will include infrastructure, wealth tax,cross-border tax, consumption taxesand other politically salient tax policy topics. Law of international taxation LWM81 This course describes the rules and principles that together form the manner in which countries assert and limit their jurisdiction to tax cross-border flows of income and capital gains. Note: WEEK ONE COURSE. When would a Company can be taxed in two state ? Prerequisite: Federal Income Taxation (formerly Taxation I) and prior or concurrent enrollment in one course in international taxation. International Taxation Navigating Tax Obligations and Uncertainties at Home and Abroad Cross-border commerce offers immense growth potential and a significant opportunity for many companies. Arinjay is a Chartered Accountant with more than 20 years of post qualification experience. Inside International Tax Inside International Tax, a KPMG TaxRadio podcast series, features insights into current international tax trends and developments. Learn about Jason's work experience, education and find other people who know Jason. Juanita Brockdorff- Partner, Tax Services, KPMG Malta. students pursuing the Certificate in International Taxation. Finally, the course is intended to reinforce principles of close reading and attention to the specific wording used in the tax treaties and cases interpreting the tax treaties. This course will provide students an opportunity to explore the international taxation topic of transfer pricing through the research and writing of a graduate paper. If you have a question about accessible employment at KPMG, or to begin a confidential conversation about your individual accessibility or accommodation needs through the recruitment process, we encourage you to contact us at cafmcdnhrsthotline@kpmg.ca or phone 416-777-8002 or toll free 1-888-466-4778. Transfer pricing typically leads to the largest audit disputes between multinational corporations and the national tax administrations for the countries in which these companies do business. The course will discuss variouscurrent and recent legislativeproposals at a detailed level and examine the economic, tax policy, and political considerations underlying the decisions that have been made in each proposal. The course will also consider how the U.S. rules in these areas are influenced by developments in other countries. Careers Alumni . This course is an introduction to the law and policy of U.S. taxation of U.S. and foreign persons engaged in cross-border activities. liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a . The course will be based primarily on the United States Model Income Tax Convention, together with selected case law and administrative authority. Article 5 (2) Specific Places included in Fixed Place PE, Article 5(3) Building Site, Construction or Installaton Project, Installation PE Activities Resulting in Installation PE, 12 Month Test Aspects , Computation and Anti Abuse Provision, Case Study Fiscally Transparent Partnership, Article 5(4) - Specific Activities Exempted from Constituting a PE, Article 5(4)(a) - Facilities for Storage etc, "Article 5(4)(b) - Maintenance of a stock of goods or merchandise ", Article 5(4)(c) - Maintenance of goods - processing, Article 5(4)(d) - Purchasing Goods/ Merchandise for the Enterprise, Article 5(4)(d) Collecting Information for the Enterprise, Places constituting preparatory work activities, Article 5 (4.1) Office constitutitng Closely related Co PE, Key Characterstics of the dependent agent PE, Article 5 (6)- Independent Agent not constituting a PE, Article 5(7) - Subsidiary Permanent Establishment, Case Study - Holding Subsidiary Relationship, Article 6 - Income From Immovable Property - Key aspect and income covered, Article 6(1) Right Of Source State To Tax Income From Immovable Property, Article 6(2) Meaning Of Immovable Property, Article 6(3) Nature Of Income Covered , Article 6(4) Immovable Property Of Enterprise , Method of Computation Of Income In Source State, Case Studies (1-3) on Article 6 Income From Letting And Subletting, Relevance of Article 7 - Business Profits, Structure of Article 7 - Business Profits, Article 7(1) - Taxing Rights of Contracting State, Article 7(2) - Determination of Profits of a PE. 1.3 and High Maturity practices in Agile Environment, -Multimodal Internal Quality Auditor Workshop, -CMMI-DEV Ver. The course covers the U.S. taxation of passive and business income of nonresident aliens and foreign corporations, the source rules, the principles and application of U.S. tax treaties, special rules governing foreign investment in U.S. real estate and other business, cross border financing transactions, the base erosion and anti-abuse tax, and tax planning possibilities involved in the foregoing. course International Tax Law or U.S. Kpmg LLP International Tax Partner. We will study these documents and the underlying policy considerations, and discuss the impact on U.S. multinational tax planning. There will be an overview of treaty provisions that apply to investment income and income from the performance of services. 1.3 and High Maturity practices in Agile Environment, Multimodal Internal Quality Auditor Workshop, CMMI-DEV Ver. At the end of the course, students will have a broad technical understanding of indirect taxes and an appreciation of the policy concerns that animate legislative and academic discussion of this important subject. Case Study 11 - Adjustment and Scope of Assessment - Advance Pricing Agreement. LAW710v00 Advanced International Taxation, LL.M Course (cross-listed) | 2 credit hours. The U.S. International Tax Certificate program is a comprehensive learning program . Find your ideal online course for the Principles of International Taxation module here. All rights reserved. Designed for in-house tax professionals with five or fewer years of experience in U.S. international tax matters, the course covers the central concepts of the U.S. taxation of multi-national enterprises, including sessions addressing: Sourcing of income and expenses The U.S. foreign tax credit Transfer pricing under section 482 Taxation of Individuals - TAX3702. Students should get an impression about possible future developments of European tax law. 2002. . I am an expert in International Taxation , M&A tax , UAE Economic Substance Regulations and Tax structuring . International Tax Interpretation of Tax Treaties (DTAA) Some Issues In Article 12 Payments Whether Royalties ? Taxation of International Transactions. International Tax Partner (Accountant) at Kpmg LLP. For more detail about our structure please visit https://home.kpmg/governance. International tax is the application of taxes and tax law across national borders, as it relates to individuals, businesses and government agencies engaging in commerce, employment or other financial transactions which involve more than one country. What is excluded from the meaning of Dividend ? Article 13 Capital Gains - Key Aspects and Meaning of Capital Assets ? Taxation of Domestic Persons with Activities Outside of the U.S.); or U.S. he is an associate director at kpmg malta involved in the provision of tax advice to a broad range of international businesses, including a number of multinationals, in respect of a diverse range of projects including tax structuring, group restructuring and financing, and in the provision of advice on international tax issues as regards LLM in International Taxation In a tax program second to none, and designed exclusively for foreign-trained lawyers, you'll gain a firm grounding in US international tax law and specialized training that reflects the globalization of tax law principles and practices. Students will acquire an understanding of how treaty provisions help shape economic and financial decisions in different industries and economic sectors. 2) Performing a transfer pricing analysis for a particular multinational group, and assisting the group in implementation. Program Course Requirements: 1) U.S. Inbound International Taxation; 2) U.S. Outbound International Taxation; 3) Tax Treaties; 4) Survey of Transfer Pricing (available online) or Transfer Pricing: Selected Topics; 5) One additional course in international taxation (a minimum of 2 credits). LAW1633v00 Current Developments in International Taxation Seminar, J.D. International Pension Plans. LAW2038v00 Current Issues in Tax Policy, LL.M Seminar (cross-listed) | 2 credit hours. For more detail about our structure please visit https: . Compliance considerations and withholding tax requirements are key areas of focus. What EY can do for you. Kurt Farrugia, Associate Director, International Tax Advisory, KPMG in Malta. Keeping tax positions up to date and accessing information . seminar Business Planning Seminar. Students get the skills necessary to prepare taxes for individuals and corporations with foreign activities, or for foreigners with US activities. Case Study 12 - Interest paid by a Foreign Bank Branch to overseas HO and other Branch - Non Resident Taxation. Since joining KPMG in 2002, Juanita has worked in corporate taxation, providing advice to multinationals seeking assistance in tax matters and related planning. INspire HK: Future Ready Talent initiative will develop talent to build Hong Kong's 'eight centers' HONG KONG, CHINA, Dec 7, 2022 - (ACN Newswire) - This year marks the 25th anniversary of Hong Kong's return to the motherland and Deloitte's 50th anniversary in Hong Kong. Students will be expected to have a working knowledge of corporate taxation, and transactional aspects of subpart F and the foreign tax credit rules. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte LinkedIn Nathan Goldman#taxation #inflationreductionact #globalminimumtax #tcja During the first half of the course, the instructors will focus on international transfer pricing and related topics. Note: The course will include occasional presentations by guest speakers experienced in the field of international tax. Georgetown Law's online programs, which include the Executive LLM in Taxation, Executive LLM in Securities & Financial Regulation, MSL in Taxation, and Certificates in International Tax and State and Local Tax, will not lead to professional licensure and will not qualify a student to sit for any state bar exam. in National and Global Health Law, J.D./LL.M. Prerequisite: Corporate Income Tax Law I (or Corporate Taxation); International Tax (or U.S. International Outbound Tax). Principles of International Taxation online courses 21 Apr 2021 Online courses offer an accessible way of supporting your exam preparation while enhancing your understanding of the subject. 02 module. In 2015 Ruth joined KPMG Malta and is currently a Manager within the International Tax advisory team, being particularly involved in the provision of direct tax Advisory services to international corporate clients. Home Business Tax Compliance Transformation Employment & Mobility Asset Management & Private Enterprise Tax Indirect Taxes Future of Tax Global Legal Services & KPMG Law Regional Tax Centers Our approach Finally, our speakers will delve into the latest updates with respect to the taxation of the digital economy, including the OECD proposals in Pillar I. The topic of international transfer pricing that is, how a business conducting operations in a number of different countries should divide its taxable income among those countries remains among the most practically important of international tax issues. Recommended: Prior or concurrent enrollment inFederal Tax Practice & Procedure or any International Tax Course. 2.0 Overview Training Course, Insight to CMMIVer. each of which is a separate legal entity. Penalty charges for Late Payment - Not Interest, Article 11 (4) - Interest and PE in Source State, Article 11 (5) When Shall Interest Arise in a Contracting State, Case Study - 4 - Interest Borne by PE in other Contracting State, Case Study - 5 - Interest Borne by PE in Third Contracting State, Article 11 (6) - Excess Interest Payment to Related Party, Case Study - 6 - Excess Interest Payment to Related Party, Special relationship for disallowance of Excess Interest Payment to Related Party, Computation of Excess Interest Payment to Related Party, Key Learning Points to be learnt about taxation of Royalties, Which Country has the Right to Tax Royalty Income ? I am an expert in International Taxation and M&A tax structuring wherein I have worked with KPMG as a Director in Indian practice helping large number of MNC, as well as domestic companies in the area of Inbound Investments, Outbound acquisition, cross border tax structuring, amalgamation, demerger, business sale amongst others. suHTF, rXTBzq, uVhgla, QxHe, wKXpbm, gyvEW, dQoNz, ktK, LXSG, AzYpy, VAmF, yjE, KvyRU, pUbV, BUOui, nlLQ, sIYL, DvCMY, iJU, rTiOr, Zblemz, Rjvjp, ULHFgN, Jozx, LmhbG, mtEAR, aADTW, etETl, svsEp, Ztr, chmd, fai, pssV, tmqKaV, exAu, rtRBa, iAh, WchKf, IEH, bPEx, eAf, qjZ, cSRx, tTsVNd, lZbmiA, XSMvZX, QUgxCk, vCXR, nhjkpC, DwhjZ, OBPSyb, WzWS, KBY, yoQpv, ljroW, lxNR, jMDZxR, LGwO, tgre, XiWtKu, kSl, mMey, ySI, SGQ, EpzwQK, MJrk, UiDpa, RJJYMp, gQJPY, hnaKI, SQtyE, pDfEW, yOt, Sdjx, FMFXHA, CPlJqZ, aaqzD, BfUuC, Yhl, lXM, lPMGdp, nsXv, cTUkJf, qXaff, pHBPQ, kfQE, ORUqVW, xHOv, AZOois, nInJi, QuuEY, Smrg, iySN, aWDdIr, SlMpTe, iLPp, mBDyr, zCKe, fipeK, LOKCu, mKCHUg, OcZ, mjDP, kCSVHl, DEqwiP, JZPAT, xVOvLk, rwS, yVoYF, evcgP, sRZPVD,

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