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Convergence of IFRS and U.S. GAAP. (International Accounting).

Things are moving so quickly in the evolving world of global accounting standards that IFRS may be unfamiliar. International Financial Reporting Standards (IFRS) is the new name for pronouncements of the International Accounting Standards Board (IASB). From 1973 to 2000, the IASB's predecessor, the International Accounting Standards Committee, issued pronouncements known as International Accounting Standards (IAS). The movement toward IFRS (which now encompass IASs) as the worldwide accounting benchmark affects the environment in which all companies operate, including those in the United States.

For example, virtually all of the 7,000 publicly listed companies domiciled within the European Union are required by law to prepare their consolidated financial statements in accordance with IFRS by 2005. This requirement will affect the subsidiaries, associates, and joint ventures of those 7,000 entities, many of which are located in the United States. If the EU expands to include Cyprus, the Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, and Slovenia in May 2004 as proposed, listed companies in those 10 countries will also have to adopt IFRS in 2005. And some European countries will permit or require IFRS for non-listed companies, of which there are 5 million.

Proposals to require IFRS have been made by Australia (all companies, starting 2005) and New Zealand (listed companies, starting in 2007). When you add these new adopters, by 2005 IFRS will be required for reporting by some or all domestic listed companies in at least 60 countries, and permitted in another 21. An even larger number of countries will allow IFRS for foreign issuers.

In the United States, a foreign company registered with the SEC may submit IFRS or local GAAP financial statements, but a reconciliation of earnings and net assets to U.S. GAAP figures is required. In effect, companies are forced to keep two sets of books. In February 2000, the SEC issued a Concept Release, International Accounting Standards, inviting views on whether and how IAS might be permitted for foreign registrants, and possibly domestic registrants. The matter continues to be under study.

The movement to IFRS around the world will have a significant impact on the SEC, especially with regard to the Sarbanes-Oxley Act's requirement for a review of all registrant filings at least once every three years. Roughly 1,400 foreign companies are listed with the SEC, approximately 40% of them from Europe. By 2005 there will be an additional 500 to 600 registrants filing IFRS statements as their primary financial statements. Currently, only about 50 foreign companies file IFRS financial statements with the SEC and reconcile to U.S. GAAP.

The Sarbanes-Oxley Act permits the SEC to look to a private-sector accounting standards setter, such as FASB, provided that the standards setter "considers, in adopting accounting principles ... the extent to which international convergence on high-quality accounting standards is necessary or appropriate in the public interest and for the protection of investors."

In October 2002, the IASB and FASB jointly issued a memorandum of understanding, formalizing their commitment to the convergence of U.S. and international accounting standards. The two boards presented the agreement to leading national standards setters at a two-day meeting in London. The boards agreed, as a matter of high priority, to--

* undertake a short-term project aimed at removing a variety of individual differences between U.S. GAAP and IFRS,

* remove other differences by undertaking new joint projects that would be addressed concurrently,

* continue progress on the joint projects that are currently under way, and

* encourage their respective interpretative bodies to coordinate their activities (FASB's Emerging Issues Task Force and IASB's International Financial Reporting Interpretations Committee).

Shortly thereafter, both FASB and the IASB added a number of projects relating to the above agreement to their agendas, including a short-term international convergence project with a target completion date of December 31, 2003, as well as several joint standards projects.

The Sidebar sets out some of the key differences between IFRS and U.S. GAAP, with a status note on what, if anything, is being done about each difference. Of course, the significance of these differences--and others not included in this list--will vary with respect to individual companies depending on such factors as the nature of the company's operations, the industry in which it operates, and the accounting policy choices it has made. Reference to the underlying accounting standards and any relevant national regulations is essential in understanding the specific differences.

RELATED ARTICLE: SIDEBAR

IAS 1

Financial statement line items

IFRS: Specific line items required.

US.: A few standards, including SEC regulations, require specific line items.

Status: No specific IASB or FASB project.

Comparative prior year financial statements

IFRS: One year of comparative financial information is required.

U.S.: U.S. GAAP states that comparatives are "desirable." SEC regulations generally require two years of comparative financial information.

Status: No specific IASB or FASB project.

Reporting "total comprehensive income"

IFRS: Permitted, but not required.

U.S.: Required.

Status: IASB's performance reporting project is likely to result in a multi-column performance statement separating current income flows from remeasurements of previously recognized items. The grand total would be similar to FASB's "total comprehensive income," though the IASB is leaning toward labeling it "net income."

Departure from a standard when compliance would be misleading

IFRS: Permitted in "extremely rare" circumstances "to achieve a fair presentation."

U.S.: Covered by auditing and ethics rules.

Status: IASB has proposed modifying the "true and fair override" to not require an entity to depart, when it otherwise believes it should, if local law prohibits such departure.

Classification of liabilities on refinancing

IFRS: Noncurrent if refinancing is completed before issue date of the financial statements.

US.: Same as IFRS.

Status: The IASB has proposed classifying these liabilities as current unless refinancing is completed by balance sheet date. Both boards agreed to address this in their convergence projects.

Classification of liabilities due on demand due to violation of debt covenant

IFRS: Noncurrent if the lender has granted a 12-month waiver before issue date of the financial statements.

US.: Same as IFRS.

Status: While IFRS and U.S. GAAP are now the same, IASB has proposed to classify these as current unless lender has granted the waiver before balance sheet date. Subsequently, both boards agreed to address this in their convergence projects.

IAS 2

Including the costs of idle capacity and spoilage in inventory

IFRS.: Prohibited.

U.S.: Not prohibited.

Status: FASB and IASB are addressing this in their convergence projects.

Reversal of inventory write-downs

IFRS: Required, if certain criteria are met.

U.S.: Prohibited.

Status: No specific IASB or FASB project to address this.

Measuring inventory at net realizable value even if greater than cost

IFRS: Permitted only for producers' inventories of agricultural and forest products and mineral ores.

U.S.: Permitted only for inventories of agricultural and forest products and mineral ores regardless of whether held by producers.

Status: IASB has proposed eliminating the restriction to producers.

IAS 7

Classification of interest received and paid in the cash flow statement

IFRS: May be classified as an operating, investing, or financing activity.

U.S.: Must be classified as an operating activity.

Status: No specific IASB or FASB project.

IAS 8

Correction of errors

IFRS: Restate prior financial statements or include the cumulative effect on net profit and loss in the current financial statements.

U.S.: Restate prior financial statements.

Status: IASB has proposed requiring restatement.

Nonmandated changes in accounting policy

IFRS: Restate prior financial statements or include the cumulative effect on net profit and loss in the current financial statements.

U.S.: Generally includes the cumulative effect in net profit and loss in the current financial statements (but restate for UFO, extractive industries, long-term contracts, and IPOs)

Status: IASB has proposed requiring restatement for all accounting policy changes. This is also being addressed in the FASB and IASB short-term projects.

Change in depreciation method for existing assets

IFRS: Change in estimate (prospective).

U.S.: Change in accounting policy (cumulative effect on net profit or loss).

Status: Proposed revisions clarify that if the method is changed because the pattern of benefits changes, it is a change in estimate.

IAS 11

Construction contracts when the percentage of completion cannot be determined

IFRS: Cost recovery method.

U.S.: Completed contract method.

Status: IASB has indicated that it might provide some "interim guidance" as part of its convergence project.

IAS 12

Classification of deferred tax assets and liabilities

IFRS: Always noncurrent.

U.S.: Classification is split between current and noncurrent components.

Status: FASB and IASB are addressing the differences between LAS 12 and SFAS 109.

Recognition of a deferred tax asset after a business combination

IFRS: First reduce goodwill to zero, then credit the excess to net profit or loss.

U.S.: First reduce goodwill to zero, then reduce any other intangible assets to zero, and then credit any excess to net profit or loss.

Status: FASB and IASB are addressing the differences between IAS 12 and SFAS 109.

Reconciliation of actual and expected tax expense

IFRS: Required for all companies.

U.S.: Required for public companies. Nonpublic companies must disclose the nature of the reconciling items but not amounts.

Status: FASB and IASB are addressing the differences between IAS 12 and SFAS 109.

Recognition of tax benefits related to employee share options

IFRS: Credited to equity only to the extent that it arises from a transaction recognized in equity.

U.S.: Credited to equity.

Status: FASB and IASB are addressing the differences between IAS 12 and SFAS 109.

Impact of temporary differences related to inter-company profits

IFRS: Deferred tax effect is recognized.

U.S.: Deferred tax effect is not recognized. Status: FASB and IASB are addressing differences between IAS 12 and SFAS 109.

IAS 14

Basis of reportable segments

IFRS: Lines of business and geographical areas.

U.S.: Components for which information is reported internally to top management.

Status: IASB is soliciting the views of financial analysts.

Segment disclosures

IFRS: Required disclosures for primary and secondary segments.

U.S.: Only one basis of segmentation, although certain enterprise-wide disclosures are required, such as revenue from major customers and revenue by country.

Status: IASB is soliciting the views of financial analysts.

Accounting basis for reportable segments

IFRS: Amounts are based on IFRS GAAP measures.

U.S.: Amounts are based on measurements used for internal reporting purposes.

Status: IASB is soliciting the views of financial analysts.

Segment result

IFRS: Defined segment result.

U.S.: No definition of segment result.

Status: IASB is soliciting the views of financial analysts.

IAS 16

Major inspection or overhaul costs

IFRS: May be accounted for as a separate component of an asset.

U.S.: Generally expensed.

Status: IASB has proposed to clarify that the component approach is required.

Basis of property, plant, and equipment

IFRS: May use either fair value or historical cost.

U.S.: Generally required to use historical cost.

Status: Fair value will continue to be an allowed alternative under the IASB's proposed revisions to IAS 16.

Gains and losses on exchanges of similar assets

IFRS: Currently, IFRS is the same as U.S. GAAP. However, the IASB has proposed requiring gain or loss recognition on exchanges of similar productive assets (property, plant, equipment, and intangibles).

U.S.: Gain or loss recognition is prohibited.

Status: FASB and IASB are addressing this in their convergence projects.

Depreciation of assets held for disposal

IFRS: Depreciation continues.

U.S.: Depreciation ceases and the asset is measured at the lower of carrying amount and fair value, less the cost to sell it.

Status: IASB is leaning toward changing to the U.S. GAAP approach.

IAS 17

Minimum lease payments

IFRS: Includes guarantees of third-party debt related to the leased assets.

U.S.: Excludes guarantees of third-party debt in minimum lease payments.

Status: No specific IASB or FASB project.

Present value of minimum lease payments

IFRS: Generally uses the implicit rate in the lease to discount minimum lease payments.

U.S.: Generally uses the incremental borrowing rate to discount minimum lease payments.

Status: No specific IASB or FASB project.

Initial direct costs

IFRS: Expense or amortize over the lease term.

US: Amortize over the lease term.

Status: IASB has proposed the U.S. GAAP approach.

Recognition of a gain on a sale and operating leaseback transaction

IFRS: The gain is recognized immediately.

US: The gain is amortized over the lease term.

Status: No specific IASB or FASB project.

Disclosure of lease maturities

IFRS: Less detailed disclosure.

US: More detailed disclosure.

Status: No specific IASB or FASB project.

IAS 18

Revenue recognition guidance

IFRS: General principles are consistent with U.S. GAAP, but contain limited industry-specific guidance.

US: More specific guidance, particularly industry-specific issues. Public companies must follow more detailed guidance provided by the SEC.

Status: The FASB is taking the lead on a joint revenue recognition project with the IASB.

IAS 19

Accounting for stock options

IFRS: No guidance on recognition and measurement. Limited disclosures required (not including the fair value of options granted).

US: Share options issued from a variable plan or to nonemployees are expensed. Those issued from a fixed plan are recognized either at their intrinsic value (generally zero) or fair value. If intrinsic value is used, then certain disclosures are required, including the fair value of options granted.

Status: IASB has proposed requiring the fair value of all share-based payments to be expensed. Calculation of fair value would differ from U.S. GAAP. FASB has invited comment on IASB's exposure draft.

Termination benefits

IFRS: No distinction between "special" and other termination benefits. Termination benefits recognized when the employer is demonstrably committed to pay.

U.S.: Recognize special termination benefits when employees accept the offer and the amount can be reasonably estimated. Recognize contractual termination benefits when it is probable that employees will be entitled and the amount can be reasonably estimated.

Status: No specific IASB or FASB project.

Recognition of past service costs related to vested employees

IFRS: Recognized immediately.

U.S.: Amortized over the remaining service period or life expectancy.

Status: IASB is addressing pension accounting as part of its convergence project.

Multi-employer plans

IFRS: May be considered defined benefit plans.

U.S.: Always considered defined contribution plans.

Status: IASB is addressing pension accounting as part of its convergence project.

Minimum liability recognition for benefits under defined benefit plans

IFRS: No minimum liability requirement.

U.S.: The unfunded accumulated benefit obligation is recognized at a minimum.

Status: IASB is addressing pension accounting as part of its convergence project.

Pension assets

IFRS: limitation on the amount recognized.

U.S.: No limitation on the amount recognized.

Status: IASB is addressing pension accounting as part of its convergence project.

LAS 21

Translation of fair value adjustments and goodwill

IFRS: May use either current or historic exchange rate.

US: Must use current exchange rate.

Status: IASB has proposed requiring the current exchange rate.

FX differences on monetary items resulting from a nonhedgeable severe devaluation

IFRS: Sometimes added to the cost of an asset.

U.S.: Always in net income.

Status: IASB has proposed to adopt the U.S. GAAP approach.

IAS 22

Accounting for business combinations

IFRS: Pooling of interests required if the acquirer cannot be identified. Otherwise acquisition (purchase) accounting must be used.

US: All business combinations must be accounted for as purchases.

Status: IASB has proposed prohibiting pooling.

Recognizing a restructuring liability as part of a business combination

IFRS: May be recognized in limited circumstances.

U.S.: Generally not recognized.

Status: IASB has proposed generally prohibiting an acquirer from recognizing any restructuring liability that was not previously recognized by the acquired entity.

Purchased in-process R&D

IFRS: Capitalized and amortized as an identified intangible asset or as goodwill; useful life presumed to be 20 years or less.

U.S.: Expensed.

Status: IASB's business combinations proposal states that an in-process R&D project should be recognized as an acquired asset if other recognition criteria are met.

Goodwill

IFRS: Must capitalize and amortize goodwill over its estimated useful life, which is presumed to be 20 years or less, subject to an impairment test.

US: Must capitalize, but not amortize, subject to an impairment test.

Status: IASB has proposed to adopt the U.S. GAAP approach.

Minority interest of acquired assets and liabilities in a business combination

IFRS May measure at either fair value or historical cost.

U.S.: Must measure at fair value.

Status: IASB has proposed requiring that the minority portion be measured at fair value.

Adjustment period for subsequently recognized assets and liabilities

IFRS: Through the end of the first full year after acquisition.

U.S.: One year from the acquisition date.

Status: IASB has proposed a one-year rule.

Negative goodwill

IFRS: Initially offset against any expected future losses. Any amounts not exceeding the value of acquired non-monetary assets are amortized. Any excess is included in net profit or loss.

U.S.: Initially allocate on a pro-rata basis against the carrying amounts of certain acquired nonfinancial assets, with any excess recognized as an extraordinary gain.

Status: IASB has proposed recognizing immediately as a gain.

Combinations of entities under common control

IFRS: Not addressed.

U.S.: Pooling of interests method.

Status: Included in the scope of phase II of IASB's business combinations project.

IAS 23

Borrowing costs related to assets that take a substantial time to compkte

IFRS: Capitalization is optional.

U.S.: Capitalization is mandatory.

Status: No specific IASB or FASB project.

Types of borrowing costs eligible for capitalization

IFRS: Interest, certain ancillary costs, and exchange differences that are regarded as an adjustment of interest.

U.S.: Generally only interest.

Status: No specific IASB or FASB project.

Income on temporary investment of funds borrowed to construct an asset

IFRS: Reduces borrowing cost eligible for capitalization.

U.S.: Generally does not reduce borrowing cost eligible for capitalization.

Status: No specific IASB or FASB project.

IAS 27

Basis of consolidation policy

IFRS: Look to governance, risk, and benefits for control

U.S.: Majority voting rights.

Status: IASB has a project on its agenda on consolidation.

Special purpose entities

IFRS: Consolidate if "controlled." Generally follow the same principles for commercial entities in determining whether control exists.

U.S.: Consolidate if certain criteria for "qualifying SPEs" are not met. Generally look to whether the SPE has a sufficient level of equity "at risk."

Status: in January 2003, FASB issued Interpretation 46 on consolidation of SPEs that are not qualified SPEs. IASB has begun a project on consolidation, including SPEs.

Different reporting dates of parent and subsidiaries

IFRS: Reporting date difference cannot be more than three months; must adjust for any significant intervening transactions.

U.S.: No requirement to conform dates or adjust for significant transactions.

Status: No specific IASB or FASB project.

Different accounting policies of parent and subsidiaries

IFRS: Must conform policies where practicable or disclose the proportion of items to which different accounting policies have been applied.

U.S.: No requirement to conform policies.

Status: IASB has proposed that all policies must be conformed.

Enterprises that are temporarily controlled

IFRS: Excluded from consolidation if acquired and held exclusively for disposal in the near future.

U.S.: Must be consolidated.

Status: IASB has proposed that "near future" be limited to one year.

IAS 28

Different reporting dates of investor and associate

IFRS: No requirement to conform dates, but must adjust for significant intervening transactions.

U.S.: No requirement to conform dates or to adjust for significant transactions.

Status: IASB has proposed restricting the time difference to not more than three months.

Different accounting policies of investor and associate

IFRS: Must either conform policies if practicable or disclose otherwise.

US.: No requirement to conform policies.

Status: IASB has proposed conforming policies.

Losses in excess of equity investment

IFRS: Recognized to the extent there is an obligation to fund such amounts.

US.: Used to reduce the basis of other investments, such as loans to the investee.

Status: IASB has proposed requiring that other long-term interests (preferred shares, long-term receivables, and loans) should be reduced for losses in excess of the equity investment.

IAS 29

Hyperinflation

IFRS: Would adjust the subsidiary financial statements for the general effects of inflation, with the gain or loss on net monetary position in net income.

US.: Would remeasure the subsidiary accounts using the "functional currency" of the parent.

Status: FASB and IASB are addressing this in their convergence projects.

IAS 31

Investments in joint ventures

IFRS: May use either the equity method or proportionate consolidation.

US.: Generally use the equity method, except in construction, oil, and gas industries.

Status: FASB and IASB are addressing this in their convergence projects.

IAS 32

Classification of convertible debt instruments by the issuer

IFRS: Split the instrument into liability and equity components.

US.: Classify the entire instrument as a liability.

Status: No specific IASB or FASB project.

Issuer classification of mandatory redeemable preferred shares

IFRS.: Classified as a liability.

US.: Presented between liabilities and equity.

Status: FASB is working on a limited-scope standard that would address how to classify obligations to repurchase an entity's own equity instruments, mandatory redeemable instruments, and obligations that the issuer could settle by issuing its shares or other equity instruments.

IAS 33

Disclosures of earnings per share

IFRS: Basic and diluted net profit or loss per share.

US.: Basic and diluted income from continuing operations, discontinued operations, extraordinary items, cumulative effect of a change in accounting policy, and net profit or loss per share.

Status: IASB has proposed requiring basic and diluted income from continuing operations and net profit or loss per share. Disclosure of other per-share amounts is being considered in IASB's performance reporting project.

Base for measuring anti-dilution

IFRS: Net profit or loss per share.

US.: Income from continuing operations per share.

Status: IASB has proposed adopting the U.S. GAAP approach.

IAS 34

Revenue and expense recognition

IFRS: Interim period is a discrete reporting period.

US.: Interim period is an integral part of the full year.

Status: FASB and IASB are addressing this in their convergence projects.

IAS 35

Initial disclosure trigger for discontinued operation

IFRS: Public announcement of a disposal plan. US: Internal agreement on a disposal plan.

Status: IASB has said it plans to replace IAS 35 as part of its convergence project to conform IFRS presentation requirements to those in SFAS 144.

IAS 36

Costs relating to disposal activities

IFRS: Costs associated with ongoing activities cannot be accrued.

US.: Some costs associated with ongoing activities can be accrued.

Status: FASB is addressing this in its convergence project.

Impairment

IFRS: Impairment is triggered if an asset's carrying amount exceeds the higher of the asset's value-in-use (discounted present value of expected future cash flows) and net selling price.

US.: Impairment is triggered if an asset's carrying amount exceeds the asset's undiscounted expected future cash flows.

Status: No specific IASB or FASB project.

Measurement of impairment loss

IFRS: Based on the recoverable amount (the higher of the asset's value-in-use and net selling price).

US.: Based on fair value.

Status: No specific IASB or FASB project.

Subsequent reversal of an impairment loss

IFRS: Required, if certain criteria are met.

US.: Prohibited.

Status: IASB has proposed prohibiting reversal of all impairment losses on goodwill. Reversal of other impairment losses would still be permitted.

IAS 37

Measurement of provisions

IFRS: Best estimate to settle the obligation, generally using the expected value method. Discounting required. US.: Low end of the range of possible amounts. Some provisions are not discounted.

Status: No specific IASB or FASB project.

Disclosures that may seriously prejudice the position of the enterprise in a dispute

IFRS: "In extremely rare cases" amounts and details need not be disclosed, but the general nature of the dispute and reason for nondisclosure is required.

US.: Disclosure is required.

Status: No specific IASB or FASB project.

IAS 38

Development costs

IFRS: Capitalize, if certain criteria are met.

U.S.: Expense, except for certain costs associated with development of a website or internal-use software.

Status: FASB is addressing this in its convergence project.

Purchased intangibles (other than in-process R&D)

IFRS: Capitalize and amortize over the estimated useful life, which is presumed to be 20 years or less.

US.: Capitalize. Amortize if the asset has a finite life. Do not amortize if the asset has an indefinite life, but test at least annually for impairment.

Status: IASB has proposed adopting the U.S. treatment.

Revaluation of intangible assets

IFRS: Permitted only if the intangible asset trades in an active market.

US.: Generally prohibited.

Status: IASB has reaffirmed its revaluation principle in its proposed amendments to LAS 38.

IAS 39

Change in value of nontrading investment

IFRS: Recognize either in net profit or loss or in equity (with recycling).

US: Recognize in equity (with recycling).

Status: IASB has proposed adopting the U.S. treatment.

Accounting for hedges of a firm commitment

IFRS: Cash flow hedge.

US. Fair value hedge.

Status: IASB has proposed adopting the U.S. treatment.

Use of partial-term hedges

IFRS: Allowed.

US.: Prohibited.

Status: No specific IASB or FASB project.

Selling investments classified as held-to-maturity

IFRS: Prohibited from using held-to-maturity classification for the next two years.

US: Prohibited from using held-to-maturity classification.

Status: No specific IASB or FASB project.

Use of "basis adjustment"

IFRS: Gain or loss on hedging instrument that had been reported in equity becomes an adjustment of the carrying amount of the asset.

US.: Gain or loss on hedging instrument that had been reported in equity remains in equity and is amortized over the same period as the asset.

Status: IASB has proposed adopting the U.S. treatment.

Derecognition of financial assets

IFRS: No "isolation in bankruptcy" test.

US: Derecognition prohibited unless the transferred asset is beyond the reach of the transferor, even in bankruptcy.

Subsequent reversal of an impairment loss

Status: IASB has proposed a new "no continuing involvement" principle for derecognition.

IFRS: Required, if certain criteria are met.

US: Prohibited.

Status: The IASB's proposed amendments to IAS 39 would prohibit reversal of an impairment loss on a financial asset classified as available for sale.

Use of qualifying SPEs

IFRS: Prohibited.

US: Allowed.

Status: In January 2003, FASB issued Interpretation 46 on consolidation of SPEs that are not QSPEs. IASB has begun a project on consolidation, including SPEs.

IAS 40

Measurement basis of investment property

IFRS: May use either fair value or historical cost.

US: Historical cost generally required.

Status: IASB has announced it does not plan to eliminate the choice allowed by IAS 40.

IAS 41

Measurement basis of agricultural crops, livestock, orchards; or forests

IFRS: Fair value with changes recognized in net profit or loss.

US: Historical cost is generally used.

Status: No specific IASB or FASB project.

Paul Pacter is director, IAS Global Office, Deloitte Touche Tohmatsu, Hong Kong. He worked for many years for both FASB and the International Accounting Standards committee.
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Title Annotation:International Financial Reporting Standards
Author:Pacter, Paul
Publication:The CPA Journal
Geographic Code:00WOR
Date:Mar 1, 2003
Words:4439
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