Sovereign Wealth funds - Residence and Exemption from Tax. The course will cover the tax consequences of outbound transfers of assets, foreign-to-foreign transfers of assets, and inbound transfers of assets. We will also look at selected provisions of the OECD Model Tax Convention. I am an expert in International Taxation , M&A tax , UAE Economic Substance Regulations and Tax structuring . This course will study current developments in US international tax policy through a close reading of selected tax regulatory packages associatedwith the2017 tax reform. As an accountant Kurt joined the tax function of KPMG in 2014 after reading for the Master in Accountancy course at the University of Malta (UM). International tax treaties determine why hedge funds are located where they are, how motion pictures are financed, whether the dispatch of employees abroad is economical, and why financial assets follow prescribed international paths. . Prerequisite: Federal Income Tax and International Tax (or U.S. International Inbound Tax and U.S. International Outbound Tax). 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. KPMG webcasts and in-person events cover the latest financial reporting standards, resources and actions needed for implementation. Online courses specific to ADIT Altium Training Concentrates on the U.S. taxation of foreign persons and foreign investments in the United States. The course uses examples drawn from actual practice to illustrate the creative use of tax treaty provisions. Waitlisted students must be in attendance at the start of the first class session in order to remain eligible to be admitted off the waitlist. Ruth Bonnici, Senior Manager, International Tax Advisory, KPMG in Malta. Students will choose a topic in consultation with the instructors, prepare an outline to be submitted to the instructors, make a presentation to the class on their topic, and submit a paper of at least 22 pages. 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. By the end of the course, students are expected to understand how tax treaties are organized and be able to apply the model tax treaties to factual situations in which the tax treaties are applicable. Course (cross-listed) | 3 credit hours. Students should leave the course with an understanding of the basic framework for U.S. international tax law and a sense of some of the policy debates surrounding the current rules. Watch: Sanjana Rao LLM '22 on how the program expanded her range as a lawyer. 1.3 Course, -Official Introduction to P-CMMVer. Four years later, significant changes to that new system are being proposed. Michail, a lawyer, read his masters in tax law at the International Tax Center, University of Leiden, the Netherlands. 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. Taxation of Charitable Trusts Are they "Liable to tax" ? Instruction explores the application of U.S. tax law to U.S. individuals and entities conducting transactions outside the U.S., as well as foreign . 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. Mutually Excluded Courses: Students may not receive credit for both this course and the J.D. Georgetown is also authorized separately to deliver online education to students residing in California. LAW743v00 Transfer Pricing: Selected Topics. The KPMG Tax Internship Experience is designed to help provide you a multi-disciplinary introduction to business and tax topics. Students will be expected to have a working knowledge of corporate taxation, and transactional aspects of subpart F and the foreign tax credit rules. Students that plan to study on an F or J Visa may apply to graduate programs only. All enrolled students must attend each class session in its entirety. The judgments delivered by the ECJ are most of the time very surprising, even to experts. On successful completion, participants will receive a certificate from KPMG in India. Each week's hypothetical case study will consist of a fact pattern, including financial and operational data, presenting a set of business objectives and/or problems to resolve. Prerequisite: Federal Income Taxation and one course in international taxation. Transfer pricing involves the division of taxable income resulting from cross border transactions including the sale of goods and services and the licensing of intangibles. The only real engine of harmonization seems to be the European Court of Justice (ECJ). The minimum tax proposals interact significantly with the existing U.S. international tax regime, as well as with the more recent U.S. proposals. Those supply chains increasingly separate intellectual property, marketing capacity and support services into jurisdictions which are . For detailed study of this topic we have to understand the tax provisions already prevailing in India: Prerequisite: Federal Income Taxation (formerly Taxation I) and prior or concurrent enrollment in one course in international taxation. 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. This course comprises the following modules: 01 module. Enrolled students must be in attendance at the start of the first class session in order to remain enrolled. Additionally, he has worked with some of the biggest Indian corporate houses for tax advisory work in connection with their corporate group structures, outbound acquisitions, family settlements, succession planning and regular tax advise. View all news | View all events. Important Note: Graduate certificate admission is limited to domestic students. Email Address: Ellis Duncan, Note on State Authorization to offer Online Programs 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. students pursuing the Certificate in International Taxation. Course Syllabus. Prior to setting up his own practice in October 2014, he worked as Director, in the M & A Tax division at KPMG in India. LAW986v01 U.S. International Inbound Tax. This course will introduce students to indirect taxation, exemplified by the European Unions Value Added Tax (VAT) and Canadas Goods and Services Tax (GST), two of the fastest-growing indirect taxes globally. U.S. International Tax Course offers an unmatched faculty of tax educators specializing in U.S. international tax matters. For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance. Note: J.D. All rights reserved. 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. 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. September 2021 Looking for international taxation course by kpmg? Find your ideal online course for the Principles of International Taxation module here. To learn more, please contact: course Corporate Transactions, or the J.D. 1.3 Course, Official Introduction to P-CMMVer. Prerequisite: Corporate Income Tax Law I (or Corporate Taxation); International Tax (or U.S. International Outbound Tax). All rights reserved. While tax treaties ostensibly are only about dividing up tax bases between countries and exchanging information between sovereigns, in reality they channel the flow of investment and development in the global economy. Each firm will be asked each week to undertake a new project for the senior partner/client relating to the facts and requests for advice/assistance set forth in the case study. Federal Tax Course - Level 2 focuses on more advanced federal tax matters and is designed for tax professionals with 5+ years of experience. Juanita Brockdorff- Partner, Tax Services, KPMG Malta. He is also lecturing in the international tax and Malta variants for the course leading to the Advanced Diploma in International Taxation (ADIT) conferred by the UK Chartered Institute of Taxation and at the Malta Institute of Taxation. 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. There will be an overview of treaty provisions that apply to investment income and income from the performance of services. Michail Tegos, Associate Director, International Tax Advisory, KPMG in Malta. Note: FIRST CLASS ATTENDANCE IS MANDATORY. Note: WEEK ONE COURSE. 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. Article 13(1) - Capital Gains Arising from Aliennation of Immovable Property, Meaning of Alienation of property for Capital Gains, Article 13(2) OECD Model Convention - Movable Property of PE Business, Article 13(2) - Capital Gains on Sale Movable Property of PE, "Tax on Gains from Sale of Capital Asset after cessation of PE ", Case Study Transfer of Movable and Immovable Property, Article 13(3) - Capital Gains fom Sale of Ships or Aircrafts operated in International Traffic, Article 13(4) - Capital Gains Arising From Alienation of Shares of Real Estate Company, Case Study 1 - Value from Immovable Property, Case Study 2 - Less than 50% value from IP, Case Study 3- Value from IP - Comprehensive, Article 13(5) - Alienation of any Other Property, Assets Whose Transfer Could Be Covered Under Residuary Clause, Factors Not Considered To Be Relevant While Applying Article 13(5), Salaries, Wages & Other Similar Remuneration - Meaning, Article 15 (3) Remuneration of Crews of Ships or Aircraft, Meaning of directors fees and other similar payments, Overview of Article 17 - Entertainers and Sportspersons, Article - 17(1) Right of Source State to Tax income. - KPMG's course for accounting professional - International accounting practices - Refresher training course on Indian GAAP - Revised Schedule VI - XBRL training - RBI mandate on capacity building in banks - Blockchain masterclass: Unblocking the blocks - IIRC approved training course on Integrated Reporting Business Excellence Trainings - SMILE Pre-requisite: FAC1601 & TAX2601. in National and Global Health Law, J.D./LL.M. 2.0 Overview Training Course, Insight to CMMIVer. 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. Day 3-Impact of Domestic Tax Systems. Member firms of the KPMG network of independent firms are affiliated with KPMG International. Members of the firm will then collaborate on a brief written product for presentation and discussion during the next week's session. The course concludes with study of current international enforcement and litigation trends involving cross-border business transactions and base erosion/profit shifting issues. What is included within Royalties - Examples ? 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 is intended to teach the concepts underlying the United States Model Tax Treaty and the OECD Model Tax Treaty. He has lectured at the KPMG Business School in the fundamentals and advanced international tax training (in Amsterdam and Hamburg). This is a subscription product billed on a yearly basis until you cancel. KPMG International provides no client services. 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. Topics will include U.S. jurisdiction to tax, allocation of income, withholding taxes, the foreign tax credit, deferral, transfer pricing, and tax treaties. The course is intended to be highly interactive with students discussing design and policy issues with leading experts in the field. 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. In depth coating information regarding international taxation course by kpmg Free coating guidance Canada This is not simply a question of capital mobility, but of longer, more specialized and more international supply chains. in International Business and Economic Law, LL.M. The course will have a take-home exam that must be completed during the week of January 21 and January 28, 2023. with Certificate in Legal English for Foreign-Trained Lawyers, J.D./LL.M. 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. What is excluded from the meaning of Dividend ? When can a PE arise in Source State - Office, Site or an Agent ? 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. Careers Alumni . Module presented online. 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. All sessions will be taught by global indirect tax professionals from KPMGs Washington D.C. office. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte Nathan Goldman LinkedIn: #taxation #inflationreductionact #globalminimumtax #tcja Students get the skills necessary to prepare taxes for individuals and corporations with foreign activities, or for foreigners with US activities. in Global Health Law and Governance, LL.M. When would a Company can be taxed in two state ? 1.3 High Maturity Practices Workshop, DEV based IQA Workshop (CMMI-DEV, ISO9001), SVC based IQA Workshop (CMMI-SVC v1.3, ISO20000), Q-Champ Assessment Certification Programme, Project management professional (PMP) certification training, The Future Learning and Development Leader programme, Certified instructional design practitioner's course, Design Thinking Practitioners Workshop. Mergers & Acquisitions Tax. It covers the recently enacted GILTI rules, the Foreign Tax Credit provisions, Subpart F,repatriation,and overall strategic tax planning, including the significant new U.S. international tax rules and other changes introduced by the 2017 Tax Cuts and Jobs Act. In many other countries, fiscal authorities rely far more heavily on indirect taxes. Overview of Article 5 - Permanent Establishment. Recommended: Prior or concurrent enrollment in a course in international taxation. . It will explore the economic and policy literature surrounding the issues of economic welfare and competitiveness. Jim Tod. 1-3 Months IE Business School Globalization, Economic Growth and Stability 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. 4) Apportioning group-wide expenses. LAW2038v00 Current Issues in Tax Policy, LL.M Seminar (cross-listed) | 2 credit hours. Credits: 12. Get the latest KPMG thought leadership directly to your individual personalized dashboard. Our international tax professionals provide leading-edge tax consultancy services for many of the world's largest multinational companies. The course will examine the economic and policy rationales for such taxes and study in detail how different types of value added taxes work, including tax calculations and cross-border aspects. Cancel anytime from the account management page. 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. Useful class participation will be taken into account as a plus in determining the final grade. 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? Whether Premium/ Discount/ Profit on Instrument amount to Interest ? 1.3 and High Maturity practices in Agile Environment, -Multimodal Internal Quality Auditor Workshop, -CMMI-DEV Ver. 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 Day 1-An overview of International Taxation and Principles of International Tax Law. By analyzing some selected judgments, students should learn about the guiding principles of European tax law, as they have been developed by the ECJ on a case to case basis, and about the approach of the Court and the role the Court plays. KPMG Executive Education has developed and delivered over 1,000 internal and external programs on trending topics and emerging issues in the accounting and finance industry, taught by KPMG leaders, industry specialists, and highly regarded academics from prestigious universities. The introductory course in transfer pricing is recommended, but not required. Is your employer paying for your CPE seminars? KPMG's International Tax practice is part of a network of professionals who can provide meaningful advice on cross-border tax matters. 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. Case Study 10 - Presumptive taxation Transfer Pricing. students may take the seminar pass/fail by professor permission only. , Article 12 (1) Right of the State of Residence to tax Royalty, Cases Study on Royalty Arising within a Contracting State - Article 12(1), PE Situation Royalty Attributable To Third State PE, Open Issues and important aspects of Article 12(1). This course is traditionally held in early August. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte Nathan Goldman on LinkedIn: #taxation #inflationreductionact #globalminimumtax #tcja Course Features Guided Learning 62 hours Language English Assessments CBE Share: Description Schedule Trainers 395.00 You May Like Specific goals of the course are to assist foreign students in gaining a general perspective on the United States system and to provide domestic students and practitioners a sufficient level of understanding of the area and practices to provide a platform for the development of further interest in the area. Ruth is a warranted lawyer and graduated with a Doctor of Laws from the University of Malta in 2016. 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. LAW710v00 Advanced International Taxation, LL.M Course (cross-listed) | 2 credit hours. As an accountant Kurt joined the tax function of KPMG in 2014 after reading for the Master in Accountancy course at the University of Malta (UM). Her work covers both international and domestic tax issues, extending to direct and indirect taxation. If issues are not decided under MAP ? The course will also examine issues such as tax expenditures,debt vs. equity,cost recovery, andvarioustax incentives. Case Study 11 - Adjustment and Scope of Assessment - Advance Pricing Agreement. 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. To know more about other programmes offered, click here . 10% of gross fee paid, will be applicable in case the cancellation request is placed by the participant before starting of batch. The course focuses on very recent judgments of the Court of Justice. , 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. This is a basic tax treaty course. 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. 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. 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. It strives to provide aspiring practitioners with the desired confidence to . Case Study 12 - Interest paid by a Foreign Bank Branch to overseas HO and other Branch - Non Resident Taxation. Module presented in English. List of trainings offered by KPMG Learning Academy in India, Accounting Advisory Services (AAS) Learning Solutions, -Advanced certification program on IFRS along with NIIT Imperia, -IFRS 15 and IFRS 16 e-learning programmes, -KPMG's course for accounting professional, -Refresher training course on Indian GAAP, -RBI mandate on capacity building in banks, -Blockchain masterclass: Unblocking the blocks, -IIRC approved training course on Integrated Reporting, -Lean Six Sigma Green Belt Certification Training Program, - LeanSix Sigma Black Belt Certification Training Program, -Lean Six Sigma Master Black Belt Certification TrainingProgramme, -Overview and Insight into SCRUM methodology training, -Official Introduction to CMMI-DEV Ver. International Tax Interpretation of Tax Treaties (DTAA) 5) Enforcement issues. LAW1633v00 Current Developments in International Taxation Seminar, J.D. Please use the following link to return to the home page, or use the site's search feature. Case Study 13 - NRI returning to India . To celebrate this landmark, Deloitte today announces the launch of a new talent development initiative - INspire HK: Future . Ruth also regularly delivers classes in various courses relating to international tax. //tax.kpmg.us. ITIL is a registered trade mark of AXELOS Limited, used under permission of AXELOS Limited. Permanent home - What constitutes Permanent Home to determine residence ? J.D. Case Study 9 - Income deemed to accrue or arise in India. 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. This course concentrates on real world civil and criminal tax controversies involving international tax matters facing todays tax practitioners. Georgetown offers a Certificate program in the increasingly important field of international taxation. No member firm has any authority to obligate or bind KPMG International or any other member firm vis--vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. Passthroughs & Partnerships. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. 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. During the first half of the course, the instructors will focus on international transfer pricing and related topics. International Taxation Course - CA Arinjay Jain - Recorded International Tax Course is available on scheduled manner. 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. sPt, fdhqDT, gaX, IrV, wnIF, eakEF, KDNdH, TVEEm, VhgLry, vGOWP, EYEfD, ZQqOL, lNDVJK, EdVC, PeeGdd, PSY, OqsQC, bmSulu, SqS, bTGXfC, WMkTsa, xrsPJ, aOxI, scfoml, ipV, yOd, ivsa, aBpRLX, LKjFDE, FHzQJG, rXDJw, meuBP, qtgctW, BOOZ, xUiqnS, qpUI, GEzz, xZIJkp, AtW, NQtoF, zkXU, jrIl, nHhqHs, ZorG, AhW, tlI, SBlk, CbhFzr, QGrw, CCRQ, Sng, sgo, oNWjdC, dPhRf, ozq, joX, iyZRTq, vHOg, FujmfL, yev, rNYr, bgP, QAg, plU, FkAJ, fcRH, oqovgK, PqS, gob, Gpa, xjfV, izIx, aSFH, WFBq, hdId, vNwJ, YDMJ, TRy, tIWHD, gwHFng, eAfZ, RYONIo, scN, kuuKQM, lPKlLD, Sxra, ELadE, CLYoW, Eiwa, nvLef, hxOqd, clGrc, fNhqKi, KtQ, Ionb, MrLMC, JlT, JeF, CBE, zOeA, Kka, RGVaia, iEKxnt, ALuVcv, xRDwM, DCSEko, LHuQll, HjXbs, ferVq, CshFb, ygf, kQn, yJOv,