Td 9887

Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

Federal Register
Volume 84, No. 242, Dec. 17, 2019
84 FR 68790
Official PDF

DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9887]
RIN 1545-BN76

Dividend Equivalents From Sources Within the United States
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Final regulations and removal of temporary regulations.
SUMMARY:
This document contains final regulations relating to certain financial products providing for payments that are
contingent upon or determined by reference to U.S. source dividend payments.
DATES:
Effective date: These regulations are effective on December 17, 2019.
Applicability dates: For dates of applicability, see § 1.871-15(r).
FOR FURTHER INFORMATION CONTACT:
D. Peter Merkel or Karen Walny at (202) 317-6938 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document contains final regulations under § 1.871-15 defining the term broker for purposes of section
871(m) of the Internal Revenue Code (the Code). In addition, the final regulations provide guidance relating to

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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

when the delta of an option that is listed on a foreign regulated exchange may be calculated based on the delta
of that option at the close of business on the business day before the date of issuance. The final regulations
also provide guidance identifying which party to a potential section 871(m) transaction is responsible for
determining whether a transaction is a section 871(m) transaction when multiple brokers or dealers are
involved in the transaction. Finally, this document withdraws temporary regulations under § 1.871-15T
regarding these matters.
I. Background on Section 871(m) Regulations
On January 23, 2012, the Federal Register published temporary regulations (TD 9572) at 77 FR 3108
(2012 temporary regulations), and a notice of proposed rulemaking by cross-reference to the temporary
regulations and notice of public hearing at 77 FR 3202 (2012 proposed regulations, and together with the 2012
temporary regulations, 2012 section 871(m) regulations) under section 871(m). The 2012 section 871(m)
regulations related to dividend equivalents from sources within the United States paid to nonresident alien
individuals and foreign corporations. Corrections to the 2012 temporary regulations were published on
February 6, 2012, March 8, 2012, and August 31, 2012, in the Federal Register at 77 FR 5700, 77 FR 13968,
and 77 FR 53141, respectively. The Department of the Treasury (Treasury Department) and the IRS received
written comments on the 2012 proposed regulations, and a public hearing was held on April 27, 2012.
On December 5, 2013, the Federal Register published final regulations and removal of temporary
regulations (TD 9648) at 78 FR 73079 (2013 final regulations), which finalized a portion of the 2012 section
871(m) regulations. On the same date, the Federal Register published a withdrawal of notice of proposed
rulemaking, a notice of proposed rulemaking, and a notice of public hearing at 78 FR 73128 (2013 proposed
regulations). In light of comments on the 2012 proposed regulations, the 2013 proposed regulations described
a new approach for determining whether a payment made pursuant to a notional principal contract (NPC) or an
equity-linked instrument (ELI) is a dividend equivalent based on the delta of the contract. In response to written
comments on the 2013 proposed regulations, the Treasury Department and the IRS released Notice 2014-14,
2014-13 IRB 881, on March 24, 2014 (see § 601.601(d)(2)(ii)(b)), stating that the Treasury Department and the
IRS anticipated limiting the application of the rules with respect to specified ELIs described in the 2013
proposed regulations to ELIs issued on or after 90 days after the date of publication of final regulations.
On September 18, 2015, the Federal Register published final regulations and temporary regulations (TD
9734), at 80 FR 56866, which finalized a portion of the 2013 proposed regulations and introduced new
temporary regulations based on comments received with respect to the 2013 proposed regulations (2015 final
regulations and 2015 temporary regulations, respectively, and together, the 2015 regulations). On the same
date, the Federal Register published a notice of proposed rulemaking by cross-reference to temporary
regulations and a notice of public hearing at 80 FR 56415 (2015 proposed regulations, and together with the
2015 final regulations, 2015 section 871(m) regulations). A correcting amendment to the 2015 final regulations
and the 2015 proposed regulations was published on December 7, 2015, in the Federal Register at 80 FR
75946 and 80 FR 75956, respectively.
The Treasury Department and the IRS received written comments on the 2015 proposed regulations. The
public hearing scheduled for January 15, 2016, was cancelled because no request to speak was received.
On July 1, 2016, the Treasury Department and the IRS released Notice 2016-42, 2016-29 IRB 67 (QI
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

Notice), containing a proposed amended qualified intermediary agreement. The QI Notice included the
requirements [*68791]and obligations applicable to a QI that acts as a qualified derivatives dealer (QDD). The
Treasury Department and the IRS received written comments on Notice 2016-42, which included comments on
certain aspects of section 871(m) and QDDs. On December 30, 2016, the Treasury Department and the IRS
released Revenue Procedure 2017-15, 2017-3 IRB 437 (2017 QI Agreement), which contains the final QI
withholding agreement and the requirements and obligations applicable to QDDs.
On December 2, 2016, the Treasury Department and the IRS released Notice 2016-76, 2016-51 IRB 834,
providing guidance for complying with the final and temporary regulations under sections 871(m), 1441, 1461,
and 1473 in 2017 and 2018 and explaining how the IRS intends to administer those regulations in 2017 and
2018.
On January 24, 2017, the Federal Register published final and temporary regulations (TD 9815) at 82 FR
8144 (2017 final regulations and 2017 temporary regulations, respectively, and together, the 2017 regulations),
which generally adopted the 2015 proposed regulations with certain changes. The 2017 regulations also
included several technical amendments to the 2015 final regulations in response to comments on those
regulations. Finally, the 2017 temporary regulations were based on comments received with respect to the
2015 proposed regulations. A notice of proposed rulemaking cross-referencing the 2017 temporary regulations
was published in the Federal Register on January 24, 2017 (82 FR 8172), with correcting amendments
published in the Federal Register on October 26, 2017 (82 FR 49508) (together, the 2017 proposed
regulations). No public hearing was requested or held. On August 21, 2017, the Treasury Department and the
IRS published Notice 2017-42, 2017-34 IRB 212, which extended certain transition relief with respect to certain
portions of the 2017 final regulations.
On February 5, 2018, the Treasury Department and the IRS published Notice 2018-5, 2018-6 IRB 341,
which permits withholding agents to apply the transition rules for securities loans to which section 871(m)
applies from Notice 2010-46, 2010-24 IRB 757, in 2018 and 2019.
On September 20, 2018, the Treasury Department and the IRS published Notice 2018-72, 2018-40 IRB
522, which further extended certain transition relief and permitted withholding agents to apply the transition
rules from Notice 2010-46 in 2020.
All written comments received in response to the 2012 proposed regulations, 2013 proposed regulations,
2015 proposed regulations, and 2017 proposed regulations are available at www.regulations.gov or upon
request.
This Treasury decision finalizes the 2017 proposed regulations without any substantive change.
II. Executive Order 13789
Executive Order 13789 (82 FR 19317), issued on April 21, 2017, instructs the Secretary of the Treasury
(the Secretary) to review all significant tax regulations issued on or after January 1, 2016, and to take concrete
action to alleviate the burdens of regulations that (i) impose an undue financial burden on U.S. taxpayers; (ii)
add undue complexity to the Federal tax laws; or (iii) exceed the statutory authority of the IRS. Executive Order
13789 further instructs the Secretary to submit to the President within 60 days an interim report that identifies
regulations that meet these criteria. Notice 2017-38, 2017-30 I.R.B. 147, which was published on July 24,
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

2017, did not include regulations under section 871(m) in a list of eight regulations identified by the Secretary
in the interim report as meeting at least one of the first two criteria specified in E.O. 13789 (no regulations were
identified as meeting the third criterion).
E.O. 13789 further instructs the Secretary to submit to the President by September 18, 2017, a final report
that recommends specific actions to mitigate the burden imposed by regulations identified in the interim report.
On October 16, 2017, the Secretary published in the Federal Register that final report (82 FR 48013), which
indicated, among other things, that the Treasury Department continues to analyze all recently issued significant
regulations and is considering possible reforms of several recent regulations not identified in the earlier report,
including the regulations under section 871(m).
Summary of Comments and Explanation of Provisions
The Treasury Department and the IRS received one comment regarding the 2017 proposed regulations.
After consideration of the comment, the 2017 proposed regulations are adopted as final regulations without
any substantive change. In addition, the regulations under § 1.871-15T are withdrawn. Comments on the
section 871(m) regulations that were not specific to § 1.871-15T are beyond the scope of this rulemaking and
are not addressed in this preamble.
The Treasury Department and the IRS are continuing to study and consider possible reforms to the other
provisions of the section 871(m) regulations pursuant to E.O. 13789 that are not specifically addressed by this
Treasury decision, including comments received that relate to those rules. The Treasury Department and the
IRS will consider these comments in connection with any future guidance projects addressing the issues
discussed in the comments.
I. Delta Calculation for Listed Options
Generally, section 1.871-15(g)(2) provides the delta of a potential section 871(m) transaction is calculated
on the earlier of when the contract is priced and when the contract is issued. See § 1.871-15(a)(6) (providing
that a contract is issued at the inception, original issuance, or issuance as a result of a deemed exchange
pursuant to section 1001). With respect to options listed on a regulated exchange, § 1.871-15(g)(4)(i) provided
that the delta for those options is determined based on the delta of the option at the close of business on the
business day before the date of issuance. Section 1.871-15(g)(4)(ii)(A) defines a regulated exchange as any
exchange defined in § 1.871-15(l)(3)(vii). The 2017 temporary regulations and the 2017 proposed regulations
provide that the term regulated exchange also includes a foreign exchange that (A) is regulated by a
government agency in the jurisdiction in which the market is located, (B) maintains certain requirements
designed to protect investors and to prevent fraud and manipulation, (C) maintains rules to promote active
trading of listed options, and (D) had trades for which the average trading volume exceeded $10 billion per day
during the prior calendar year (the “$10 billion threshold”). See § 1.871-15T(g)(4)(ii)(B). When a foreign
securities exchange has more than one tier or market level on which listed options may be separately listed,
the 2017 temporary regulations and the 2017 proposed regulations treat each tier or market level of the
exchange as a separate exchange. See § 1.871-15T(g)(4)(ii)(B)(4).
A comment expressed concern that the $10 billion threshold would exclude from the definition of a
regulated exchange many European exchanges that are treated as regulated markets by the European
Securities and Markets Authorities (“ESMA”) for purposes of the Markets in Financial Instruments Directive
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

2004/39/EC. The comment requested that the final regulations eliminate the $10 billion threshold. Instead, the
comment recommended [*68792]that a foreign regulated exchange be defined to include an exchange treated
as a regulated market by ESMA or a similar national authority and included in the respective ESMA register or
similar national register (the “ESMA requirement”).
The $10 billion threshold is intended to ensure that the exchange has a sufficient level of trading activity so
that the pricing cannot be manipulated. The Treasury Department and the IRS have determined that the $10
billion threshold continues to serve this purpose. In addition, the ESMA requirement requested by the comment
appears duplicative of § 1.871-15T(g)(4)(ii)(B)(1), which requires a foreign securities exchange to be regulated
or supervised by a governmental authority of the country in which the market is located, because the ESMA
register is compiled on the basis of notifications made to ESMA by the national competent authorities of
member states. Further, a foreign exchange that does not qualify under § 1.871-15T(g)(4)(ii)(B) can qualify
under § 1.871-15(g)(4)(ii)(A) if the option exchange is a qualified board or exchange as determined by the
Secretary pursuant to section 1256(g)(7)(C) or has a staff no action letter from the CFTC permitting direct
access from the United States. Therefore, the Treasury Department and the IRS have determined that it is not
appropriate to remove the requirement. However, consistent with the preamble to the 2017 regulations, the
Treasury Department and the IRS have clarified that the $10 billion threshold is determined based on the
notional amount of the options, which is the number of shares referenced by the option multiplied by the stock
price of those shares at the time of the computation. See § 1.871-15(g)(4)(ii)(B)(1)(iv).
The Treasury Department and the IRS, however, will continue to study this comment regarding the $10
billion threshold in connection with future guidance projects related to E.O. 13789. The Treasury Department
and the IRS request comments regarding whether an alternative trading threshold for U.S. equity options
would ensure that there is sufficient trading on the exchange to prevent price manipulation. For example,
instead of establishing a threshold based on the average daily trading volume for an exchange as a whole, an
alternative threshold may be based on only the average daily trading volume of equity options on the exchange
or only the average daily trading volume of equity options for a specific stock or stock index on the exchange.
Comments recommending an alternative threshold should include information supporting the suggestion,
including information regarding the average daily trading volumes for the exchange with respect to equity
options separated out by exchange (and stock or stock index, if applicable).
Special Analyses
I. Regulatory Planning and Review—Economic Analysis
Executive Orders 13563 and 12866 direct agencies to assess costs and benefits of available regulatory
alternatives and, if regulation is necessary, to select regulatory approaches that maximize net benefits,
including potential economic, environmental, public health and safety effects, distributive impacts, and equity.
Executive Order 13563 emphasizes the importance of quantifying both costs and benefits, of reducing costs, of
harmonizing rules, and of promoting flexibility.
This regulation is not subject to review under section 6(b) of Executive Order 12866 pursuant to the
Memorandum of Agreement (April 11, 2018) between the Department of the Treasury and the Office of
Management and Budget regarding review of tax regulations. Therefore, a regulatory impact assessment is not
required.
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

II. Paperwork Reduction Act
The collection of information contained in these final regulations has been reviewed and approved by the
Office of Management and Budget in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C.
3507(d)) under control numbers 1545-0096 and 1545-1597. The collection of information in these regulations
is in § 1.871-15(p). There is no change to the total annual burden in the current regulations under §§ 1.1441-1
through 1.1441-9 as a result of these final regulations. Without these final regulations, however, the total
annual burden in the current regulations under § 1.1441-1 through 1.1441-9 would increase because more
than one taxpayer could be treated as a responsible party and be required to collect information regarding
potential section 871(m) transactions.
The information is required to establish whether a payment is treated as a U.S. source dividend for
purposes of section 871(m). This information will be used for audit and examination purposes. The IRS intends
that these information collection requirements will be satisfied by persons complying with chapter 3 reporting
requirements and the requirements of the applicable qualified intermediary (QI) revenue procedure, or
alternative certification and documentation requirements set out in these regulations. An agency may not
conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a
valid control number.
The estimates for the number of impacted filers with respect to the collections of information described in
this part II of the Special Analysis section are based on the distinct U.S. withholding agents who filed a form
1042-S reporting income code 34 (substitute payments—dividends) or income code 40 (Other dividend
equivalents under IRS section 871(m) (formerly 871(l)) for calendar year 2017. The estimates for the number
of impacted filers are also based on the number of U.S. withholding agents who filed a form 1042 and checked
the box in section 3, indicating that the withholding agent made payments related to a potential section 871(m)
transaction, for calendar year 2018. The IRS estimates the number of affected filers to be the following:

Tax Forms Impacted
Collection of information

§ 1.871-15(p)(ii)

Number of Number of
respondents
filings
(estimated)
(estimated)

Forms to which the
information may be
attached

Transactions with multiple brokers

1,500

51,000 Form 1042, Form 1042-S,
and Form 1042-T.

§ 1.871-15(p)(iii) Responsible party for transactions
traded on an exchange and cleared by a clearing
organization

1,500

51,000 Form 1042, Form 1042-S,
and Form 1042-T.

§ 1.871-15(p)(iv) Responsible party for certain structured
notes, warrants, and convertible instruments

1,500

51,000 Form 1042, Form 1042-s,
and Form 1042-T.

[*68793]

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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

The IRS does not have a reliable way of estimating the number of filings that will not need to be made as a
result of these final regulations.
III. Regulatory Flexibility Act
It is hereby certified that these regulations will not have a significant economic impact on a substantial
number of small entities within the meaning of section 601(6) of the Regulatory Flexibility Act(5 U.S.C. chapter
6). This certification is based on the fact that these regulations primarily will affect multinational financial
institutions, which tend to be larger businesses, and foreign persons. Accordingly, a regulatory flexibility
analysis under the Regulatory Flexibility Actis not required.
Pursuant to section 7805(f), the notice of proposed rulemaking preceding this regulation was submitted to
the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small
businesses. No comments were received.
IV. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates Reform Act of 1995 requires that agencies assess anticipated costs
and benefits and take certain other actions before issuing a final rule that includes any Federal mandate that
may result in expenditures in any one year by a state, local, or tribal government, in the aggregate, or by the
private sector, of $100 million in 1995 dollars, updated annually for inflation. In 2019, that threshold is
approximately $154 million. This rule does not include any Federal mandate that may result in expenditures by
state, local, or tribal governments, or by the private sector in excess of that threshold.
V. Executive Order 13132: Federalism
Executive Order 13132 (entitled “Federalism”) prohibits an agency from publishing any rule that has
federalism implications if the rule either imposes substantial, direct compliance costs on state and local
governments, and is not required by statute, or preempts state law, unless the agency meets the consultation
and funding requirements of section 6 of the Executive Order. This final rule does not have federalism
implications and does not impose substantial direct compliance costs on state and local governments or
preempt state law within the meaning of the Executive Order.
Statement of Availability of IRS Documents
IRS Notices and other guidance cited in this preamble are published in the Internal Revenue Bulletin and
are available from the Superintendent of Documents, U.S. Government Publishing Office, Washington, DC
20402, or by visiting the IRS website at http://www/irs.gov.
Drafting Information
The principal authors of these final regulations are D. Peter Merkel and Karen Walny of the Office of
Associate Chief Counsel (International). However, other personnel from the IRS and the Treasury Department
participated in their development.

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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended as follows:
PART 1—INCOME TAXES
•Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§ 1.871-15T [Removed]
•Par. 2. Section 1.871-15T is removed.
•Par. 3. Section 1.871-15 is amended by:
•1. Revising paragraphs (a)(1), (g)(4)(ii)(B), (p)(1)(ii) through (iv), and (p)(5);
•2. Removing the language “(r)(2), (3), and (4)” from paragraph (r)(1) and adding “(r)(2) and (3)” in its
place; and
•3. Removing paragraph (r)(4).
The revisions read as follows:
§ 1.871-15 Treatment of dividend equivalents.
(a) * * *
(1) Broker. A broker is a broker within the meaning provided in section 6045(c), except that the term does
not include any corporation that is a broker solely because it regularly redeems its own shares.
*****
(g) * * *
(4) * * *
(ii) * * *
(B) Foreign securities exchange—(1) In general. A foreign securities exchange that:
(i) Is regulated or supervised by a governmental authority of the country in which the market is located;
(ii) Has trading volume, listing, financial disclosure, surveillance, and other requirements designed to
prevent fraudulent and manipulative acts and practices, to remove impediments to and perfect the mechanism
of a free and open, fair and orderly market, and to protect investors, and the laws of the country in which the
exchange is located and the rules of the exchange ensure that those requirements are actually enforced;
(iii) Has rules that effectively promote active trading of listed options on the exchange; and
(iv) Has an average daily trading volume on the exchange exceeding $10 billion notional amount during the
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

immediately preceding calendar year.
(2) Application to an exchange with more than one tier or market. If an exchange in a foreign country has
more than one tier or market level on which listed options may be separately listed or traded, each tier or
market level is treated as a separate exchange.
*****
(p) * * *
(1) * * *
(ii) Transactions with multiple brokers. For a potential section 871(m) transaction in which both the short
party and an agent or intermediary acting on behalf of the short party are a broker or dealer, the short party
must determine whether the potential section 871(m) transaction is a section 871(m) transaction. For a
potential section 871(m) transaction in which the short party is not a broker or dealer and more than one agent
or intermediary acting on behalf of the short party is a broker or dealer, the broker or dealer that is a party to
the transaction and closest to the short party in the payment chain must determine whether the potential
section 871(m) transaction is a section 871(m) transaction. For a potential section 871(m) transaction in which
neither the short party nor any agent or intermediary acting on behalf of the short party is a broker or dealer,
and the long party and an agent or intermediary acting on behalf of the long party are a broker or dealer, or
more than one agent or intermediary acting on behalf of the long party is a broker or dealer, the broker or
dealer that is a party to the transaction and closest to the long party in the payment chain must determine
whether the potential section 871(m) transaction is a section 871(m) transaction.
(iii) Responsible party for transactions traded on an exchange and cleared by a clearing organization.
Except as provided in paragraph (p)(1)(iv) of this section, for a potential section 871(m) transaction that is
traded on an exchange and cleared by a clearing organization, and for which more than one broker-dealer acts
as an agent or intermediary between the short party [*68794]and a foreign payee, the broker or dealer that has
an ongoing customer relationship with the foreign payee with respect to that transaction (generally the clearing
firm) must determine whether the potential section 871(m) transaction is a section 871(m) transaction.
(iv) Responsible party for certain structured notes, warrants, and convertible instruments. When a potential
section 871(m) transaction is a structured note, warrant, convertible stock, or convertible debt, the issuer is the
party responsible for determining whether a potential section 871(m) transaction is a section 871(m)
transaction.
*****
(5) Example. The following example illustrates the rules of paragraph (p) of this section.
(i) Example 1: Responsible party for a transaction with multiple broker-dealers. (A) Facts. CO is a domestic
clearing organization and is not a broker as defined in paragraph (a)(1) of this section. CO serves as a central
counterparty clearing and settlement service provider for derivatives exchanges in the United States. EB and
CB are brokers organized in the United States and members of CO. FC, a foreign corporation, instructs EB to
execute the purchase of a call option that is a specified ELI (as described in paragraph (e) of this section). EB
effects the trade for FC on the exchange and then, as instructed by FC, transfers the option to CB to be
cleared with CO. The exchange matches FC's order with an order for a written call option with the same terms
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Federal Register 2019, 84 FR 68790 Dividend Equivalents From Sources Within the United States

and then sends the matched trade to CO, which clears the trade. CB and the clearing member representing
the person who sold the call option settle the trade with CO. Upon receiving the matched trade, the option
contracts are novated and CO becomes the counterparty to CB and the counterparty to the clearing member
representing the person who sold the call option.
(B) Analysis. Both EB and CB are broker-dealers acting on behalf of FC for a potential section 871(m)
transaction. Under paragraph (p)(1)(iii) of this section, however, only CB is required to make the
determinations described in paragraph (p) of this section because CB has the ongoing customer relationship
with FC with respect to the call option.
(ii) [Reserved]
*****
Sunita Lough,
Deputy Commissioner for Services and Enforcement.
Approved: November 14, 2019.
David J. Kautter,
Assistant Secretary of the Treasury (Tax Policy).
[ FR Doc. 2019-26977 Filed 12-16-19; 8:45 am]
BILLING CODE 4830-01-P

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