International tax issues July 19, 2018 Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. This presentation is 2018 Ernst & Young LLP. All rights reserved. No part of this document may be reproduced, transmitted or otherwise distributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying or using any information storage and retrieval system, without written permission from Ernst & Young LLP. Any reproduction, transmission or distribution of this form or any of the material herein is prohibited and is in violation of US and international law. Ernst & Young LLP expressly disclaims any liability in connection with use of this presentation or its contents by any third party. Views expressed in this presentation are those of the speakers and do not necessarily represent the views of Ernst & Young LLP. This presentation is provided solely for the purpose of enhancing knowledge on tax matters. It does not provide tax advice to any taxpayer because it does not take into account any specific taxpayers facts and circumstances. These slides are for educational purposes only and are not intended, and should not be relied upon, as accounting advice. Page 2
International tax issues Presenters Matthew S. Blum Executive Director, Ernst & Young LLP Boston, MA Tamara Tarazi Senior Manager, Ernst & Young LLP Chicago, IL
Page 3 International tax issues Objectives Identify the basics of filing requirements for international tax forms Recognize the International Practice Unit issued 5/31/17 Identify country-by-country reporting Recognize international tax changes as a result of tax reform Page 4 International tax issues Agenda
Overview of international tax forms Form 5471 Form 926 Form 8865 Form 8858 Form 8621 International Practice Unit (IPU) issued May 31, 2017 Country-by-country reporting (CbCR)
International tax changes under tax reform Page 5 International tax issues Overview of international tax forms Form 5471 Page 6 International tax issues Overview of international tax forms Form 5471 Form 5471: US Ownership of Foreign Corporations Category of filers
Category 1: Repealed Category 2: US officer/director of foreign corporation in which US person acquires or increases ownership by 10% Category 3: US person who acquires 10% or an additional 10% in vote or value of the outstanding stock of a foreign corporation: US person whose interest drops from >10% to <10% Any person who owns 10% in vote or value of a foreign corporation and becomes a US person Category 4: US person who had control (>50% vote or value) of a foreign corporation for an uninterrupted period of at least 30 days
Category 5: US shareholder who owns stock in a controlled foreign corporation (CFC) for an uninterrupted period of 30 days or more and who owns the stock on the last day of the year Page 7 International tax issues Overview of international tax forms Form 5471 Form 5471: US Ownership of Foreign Corporations Section 6038 requires activities of a CFC to be reported on Form 5471: Automatic monetary penalties for failure to file and/or late filing of Form 5471 under Section 6038:
Section 6046 requires that all information about acquisitions or dispositions of 10% or more of a foreign corporation be reported on Schedule O of Form 5471 $10,000 per period per entity An additional $10,000 if form not filed within 90 days of IRS notice and $10,000 for each 30 days thereafter, up to $50,000 Loss of FTC under Sections 901, 902 and 960 10% of foreign taxes capped at greater of Page 8 $10,000 or Annual income of CFC International tax issues Overview of international tax forms Form 5471
Form 5471: US Ownership of Foreign Corporations Section 6038B Penalties related to noncompliance of reporting of transfers to foreign corporations or partnerships from US persons Lose benefit of any exceptions to gain recognition Monetary penalty equal to 10% of fair-market value (FMV) of property transferred (limited to US$100,000) Section 6501 extension of statute of limitations Potential criminal penalties for failure to file or for filing false or fraudulent information Page 9
International tax issues Polling question #1 On average, how many Forms 5471 does your organization file each year? A. <10 B. 10-50 C. 50-100 D. 100 E. N/A, I am an EY employee Page 10 International tax issues Overview of international tax forms Form 8865 Page 11 International tax issues Overview of international tax forms Form 8865
Form 8865 US Interest in Foreign Partnerships Section 6038 requires that for tax years ending on or after December 31, 2000: certain US investors in a CFP file Form 8865 with US income tax return or filer. Section 6038(b) requires the reporting on Form 8865 of transfers to a foreign partnership. Section 6046(a) requires the reporting on Form 8865 of the acquisition, disposition and changes in foreign partnership interests: Page 12 Category 1: US person(s) who controlled (>50%) the foreign partnership at any time during the partnerships tax year International tax issues Overview of international tax forms Form 8865 Form 8865 US Interest in Foreign Partnerships Category 2: US person(s) who, at any time during the tax year of the foreign partnership, owned a 10% or greater interest in the partnership while the partnership was controlled by US persons owning at least 10% Category 3: US person who transfers property to a partnership in
exchange for a partnership interest if, immediately after the contribution: Page 13 The US person owns directly or constrictively at least a 10% interest in the foreign partnership, or the value of the property contributed by itself or when combined with the value of other property contributed during a 12-month period ending during the tax year exceeds $100,000. International tax issues Overview of international tax forms Form 8865 Form 8865 US Interest in Foreign Partnerships Category 4: US person who acquires an interest in a foreign partnership and, as a result of the acquisition, owns a 10% or greater direct interest in the partnership, or whose direct interest has increased by at least 10% from the last reportable event: Page 14
US person who disposes of an interest in a foreign partnership, and as a result of the disposal, such person owns less than a 10% interest or whose direct interest decreases by at least 10% since the last reportable event International tax issues Overview of international tax forms Form 8858 Page 15 International tax issues Overview of international tax forms Form 8858 Who must file: US persons who are tax owners of foreign disregarded entities
Form 5471 Category 4 and 5 filers Form 8865 Category 1 and 2 filers Multiple filer rules of Forms 5471 and 8865 apply Penalties for not filing: Range from $10,000 to $50,000, could include reduction of foreign tax credit Criminal penalties Page 16 International tax issues
Overview of international tax forms Form 926 Page 17 International tax issues Overview of international tax forms Form 926 Form 926 Filing Requirements for US Transferors of Property to a Foreign Corporation Transfers of cash A US person who transfers cash to a foreign corporation must report the transfer on Form 926 if it owns directly or indirectly 10% of the total voting power or value of the foreign corporation or if the amount of cash transferred by the person to the foreign corporation during the 12-month period ending on the date of transfer exceeds $100,000.
US person US resident or citizen, domestic corporation, domestic trust or estate. If the organization invests in a partnership and the partnership invests in the foreign corporation, there may also be a filing requirement. The penalty for failure to file equals 10% of the fair market value of the property at the time of the exchange/transfer. Page 18 International tax issues Overview of international tax forms Form 926 Form 926 Filing Requirements for US Transferors of Property to a Foreign Corporation In December 2016, final regulations under Section 367 were issued affecting how information must be reported on the 6038B statement (Form 926)
Under Treas. Reg. Section 1.6038B-1(c)(4), taxpayers must provide a description of the property transferred under categories prescribed under the regulations, and they must include the estimated fair market value and adjusted basis of the property. Examples of the categories include: Active business property Stock or securities Depreciated property Certain ineligible property (e.g., inventory, installment obligations, foreign currency) Page 19 International tax issues
Overview of international tax forms Form 926 Under Treas. Reg. Section 1.6038B-1(d)(1), the 6038B statement must specifically identify all intangible property subject to the rules of Section 367(d) rather than Section 367(a). Page 20 Additionally, the 6038B statement must describe any property for which the income required to be taken into account under 367(d) and its regulations will be recognized over 20 years rather than its useful life, and estimate the anticipated income or cost reductions attributable to that intangible propertys use beyond 20 years. The changes to the reporting requirements apply retroactively to transfers occurring on or after September 14, 2015, and to transfers occurring before September 14, 2015, resulting from entity classification elections made under Treas. Reg. Section 301.7701-3 that are filed on or after September 14, 2015.
International tax issues Polling question #2 Company A made the following transfers to Foreign Corporation 1 on the following dates: $40,000 on 6/1/2016 $70,000 on 5/15/2017 In which year(s) does Company A have a 926 filing obligation and what is the reportable amount(s) respectively? D. 2017; $110,000 No filing obligation in either 2016 or 2017 2017; $70,000 2016; $40,000 Page 21 International tax issues A. B.
C. Overview of international tax forms Form 8621 Page 22 International tax issues Overview of international tax forms Form 8621 A passive foreign investment company (PFIC) is any foreign corporation in which: Direct and indirect US shareholders of a PFIC are subject to these rules and taxed under one of three methods:
75% or more of its gross income for the taxable year consists of passive income, or 50% or more of the average fair market value of its assets consists of assets that produce, or are held for the production of, passive income Qualified electing fund method (QEF) Mark-to-market method (MTM) Excess distribution method Generally, a US person who is a direct or indirect shareholder of a PFIC must file Form 8621 for each tax year in which that US person: Page 23 Recognizes gain on a direct or indirect disposition of PFIC stock Receives certain direct or indirect distributions from a PFIC Is making an election reportable in Part I of the form, or Is required to file an annual report pursuant to Section 1298(f) International tax issues
Overview of international tax forms Form 8621 A separate Form 8621 must be filed for each PFIC in which stock is held, directly or indirectly. When does this impact exempt organizations? When PFIC stock is debt-financed When Schedule K-1 reports UBTI from dividends or capital gains When Form 8621 has not already been filed on organizations behalf Page 24 International tax issues
Polling question #3 If the taxpayer does not receive a taxable dividend from a PFIC in a given year, the taxpayer will not have a Form 8621 filing related to that PFIC for that year. A. True B. False Page 25 International tax issues International Practice Unit (IPU) issued 5/31/2017 Page 26 International tax issues IPU 5/31/17 Under previous guidance, taxpayers avoided penalties and extension of normal assessment periods by taking the position with the IRS that the international information returns they filed were substantially compliant or substantially complete
Types of incompleteness Page 27 Facially incomplete Failure to identify category(ies) of filer or the amount of voting stock held by the taxpayer in the foreign corporation Partial detail of the identity and location of the foreign corporation Failure to complete any required Schedule to Form 5471 More subtle incompleteness
CCA 200645023 Failure to attached Schedule O; failure to report certain items in US dollars and in accordance with US GAAP; taxpayers strong compliance history was not a defense for their failure to file forms that were substantially complete 2002 IRS NSAR 20167 Penalties assessed for forms where nearly every schedule stated the taxpayer is willing to furnish additional information upon request FSA 33381431 Total information reported, e.g., two-thirds of required information, is timely and accurately reported, does not impact a penalty assessment when the taxpayer has omitted significant pieces of required information International tax issues IPU 5/31/17
Previously applicable to only Forms 5471 and 5472, the new IPU expands the meaning of substantially compliant/complete to forms other than Forms 5471 and 5472. A review of the new IPU leads to the conclusion that the concepts of substantial compliance/completeness will not be applied, or will be very narrowly applied. Note that the first-time-penalty abatement policy does not apply to most international information returns. Page 28 International tax issues US CbCR requirements Page 29 International tax issues US CbCR requirements
A US business entity that is the ultimate parent entity (UPE) of a US multinational enterprise (MNE) group must file where annual consolidated group revenues equal or exceed $850m Revenue in computing the $850m threshold for exempt organizations Treas. Reg. Section 1.6038-4(d)(3)(ii) provides that the term revenue includes only revenue that is included as unrelated business income as defined in Section 512 for certain exempt organizations (including taxexempt and state colleges and universities) Key considerations for measuring revenue Page 30 Revenue of tax exempt entities gross or net? Including income of taxable entities in the US MNE group International tax issues Implications for tax-exempt entities
No general exemption for tax-exempt entities under the final CbCR rules or OECD guidance. However, the final US regulations provide that, for a constituent entity (not the whole MNE group) that is a taxexempt organization under 501(a), the term revenue includes only revenue that is reflected in unrelated business taxable income as defined in Section 512 Currently, a difference of opinion exists among US tax professionals as to whether other countries will respect the carve-out for tax-exempt entities under the US regulations Even if a UPE was not subject to US CbCR due to the specific rules for tax exempt entities, most foreign jurisdictions do not have a similar attempted carve-out for tax exempt entities. As such, an MNE may still need to file CbCR in foreign jurisdictions if certain conditions are met. Page 31 International tax issues
Implications for tax-exempt entities Tax-exempt organizations with direct investment platforms will need to evaluate the accounting treatment of such investments (e.g., fair value, equity method, consolidation accounting) to identify constituent entities potentially subject to the CbCR requirements Additionally, consolidated groups within the investment structure should be separately analyzed to assess potential other non-US CbCR obligations Page 32 International tax issues US CbC IRS resources IRS CbCR website
Provides helpful background information on CbCR and links to relevant official guidance in one consolidated location Includes an up-to-date jurisdiction status table listing those which the US competent authority has entered into competent authority arrangements (CAAs) for the automatic exchange of CbCR information Includes a general explanation of the US rules and US expectations surrounding the confidentiality of company data, including instructions to report unauthorized use for suspected unauthorized disclosure or misuse of information exchanged with a treaty/tax information exchange agreement (TIEA) partner Website includes a list of frequently asked questions and a link that allows for submission of comments and questions. Page 33 International tax issues Polling question #4
Does your organization have a CbCR requirement? A. Yes, our revenues are above reporting requirement thresholds. B. No, our revenues are below the reporting requirement thresholds. C. Uncertain D. N/A, I am an EY employee Page 34 International tax issues International tax changes under tax reform Exempt organization considerations Page 35 International tax issues Subpart F income Tax-exempt organizations
A tax-exempt entity organized under US law is indeed a US person since it would be a US corporation or trust. Thus, for example, if a US tax-exempt owned more than 50% of a foreign corporation, then the foreign corporation would be a CFC. In general, income from insurance is non-exempt UBTI under Section 512(b)(17). Subpart F inclusions, other than certain self-insurance income, are not UBTI unless the CFC is debt-financed property in the hands of the tax-exempt organization, such that a dividend or gain on sale would be UBTI. Absent debt financing and self-insurance income, Subpart F income is not UBTI Page 36 International tax issues CFC ownership Tax-exempt organizations
Section 6038(a)(4) requires every United States shareholder of a CFC to file Form 5471 as a Category 5 filer. Ownership structures need to be analyzed in much greater detail now since the Section 958(b)(4) repeal may cause many unintended consequences. Tax reform has changed the definition of CFC and United States shareholder in two ways: Prior law: US person is a United States shareholder if it owns directly, indirectly or constructively at least 10% by vote of the foreign corporation. New law: Section 958(b)(4) has been deleted from the constructive ownership rules, effective for last tax year of CFC beginning before 2018. New law: The definition of United States shareholder is changed to one owning
directly, indirectly or constructively at least 10% by vote or value of the foreign corporation, effective for the first taxable year of the foreign corporation beginning after 2017. Please note that it only takes one United States shareholder to potentially create specified foreign corporation (SFC) status. Page 37 only relevant for 965 purposes one CORPORATE 10% shareholder can create SFC status relevant for 965 purposes International tax issues Section 965 Transition tax Section 965 provides that in the last taxable year of a SFC beginning before January 1, 2018 (transition year), the SFCs Subpart F income is increased by the greater of its accumulated post-1986 deferred foreign income determined as of November 2, 2017, or December 31, 2017:
An SFC is a CFC or any foreign corporation with at least one 10% domestic corporate shareholder. SFC status is determined without regard to Section 958(b)(4) (which is repealed as of a SFCs transition year) (e.g., creates downward attribution, which may be a problem). Accumulated post-1986 deferred foreign income means: Page 38 Earnings and profit (E&P) accumulated in years beginning after December 31, 1986, but only during periods in which the foreign corporation was an SFC Without diminution by reason of any dividends distributed during the transition year other than dividends distributed to another SFC
Excluding effectively connected E&P and previously taxed E&P (previously taxed income (PTI)) International tax issues Section 965 Transition tax For tax-exempt organizations, the accumulated foreign earnings subject to tax because of the transition tax will be treated as Subpart F income and are likely to be exempt, as they should not be characterized as UBTI. If a tax-exempt shareholder is investing through a US partnership that owns a CFC and there is debt financing at the partnership level, issues may arise with how the transition tax is reported to the partners through the partnership. If there is no debt financing, then the tax-exempt shareholder would not be subject to the transition tax. Page 39 International tax issues
Section 965 Transition tax Actual inclusion with respect to an SFC is reduced by an allocable amount (if any) of the US shareholders aggregate foreign E&P deficit with respect to other SFCs: Whether an SFC has a foreign E&P deficit is determined as of November 2, 2017. A net E&P deficit of one US corporate shareholder can offset a net positive amount of accumulated post-1986 deferred foreign income of another US corporate shareholder that is part of the same affiliated group. Transition tax rates: 15.5% for cash or other specified assets; 8% for the remainder: Rate of 15.5% applies to amount of mandatory inclusion equal to a US shareholders aggregate foreign cash position, which means greater of US
shareholders pro rata share of aggregate cash position of its SFCs determined on last day of SFCs year in which mandatory inclusion occurs or average of US shareholders aggregate pro rata share of cash position of its SFCs determined in two years ending immediately before November 2, 2017. US shareholder can elect to pay transition tax over eight years (8% of liability in years one through five, 15% in year six, 20% in year seven, 25% in year eight). Page 40 International tax issues Transition tax on accumulated foreign earnings Three actions to take now 1. Identify investments in SFCs CFCs 10/50s with a corporate US shareholder
2. Identify if any fund or LP is a US shareholder of the SFC Take into account any options, warrants, convertible bonds or convertible preferred stock that influence the US shareholder and CFC analysis. Also, the Tax Cuts and Jobs Act (TCJA) repeals Section 958(b)(4), which prevented downward attribution of stock owned by a non-US partner, beneficiary or shareholder to a US partnership, trust, estate, or corporation. 3. Calculate post-1986 foreign deferred earnings Determine earnings or deficits accumulated while the foreign corporation was a specified foreign corporation in the period since 1986 through November 2, 2017, or December 31, 2017. Were there changes in shareholdings during this period? If current US owner has not owned CFC for all of the period that CFC was in existence, purchase of CFC from prior owners might have affected amount of CFCs retained earnings.
Page 41 International tax issues Polling question #5 How far along is your organization in actions to address Section 965 law changes? A. We have identified direct interests in SFCs. B. We have identified indirect interests in SFCs through LP or other passthrough fund. C. We have calculated post-1986 foreign deferred earnings of the SFC. D. Both A and B E. All of the above F. None of the above G. N/A, I am an EY employee Page 42 International tax issues Global intangible low-taxed income (GILTI) overview
A US shareholder of any CFC for any taxable year must include in gross income its GILTI for such taxable year. A US shareholders GILTI for any taxable year equals the excess (if any) of: GILTI Such US shareholders net CFC tested income for such taxable year over Such US shareholders net deemed tangible income return for such taxable year Net CFC tested income Net deemed tangible income return The inclusion of GILTI is generally similar to inclusion of Subpart F income. GILTI is effective for tax years of foreign corporations beginning after December 31, 2017, and for tax years of US shareholders in which or
with which such tax years of foreign corporations end. Page 43 International tax issues GILTI Tax-exempt organizations GILTI income is not classified as Subpart F income under Section 952, so the question of whether this income is taxable to a taxexempt organization requires further analysis/clarification. Section 512 defines UBTI but doesnt taken into account the new rules. While GILTI income is not Subpart F income, it is similar to Subpart F income (i.e., taxation of certain types of CFC income), so we are hoping that future Notices or Treasury Regulations will consider whether GILTI income will be excluded from the definition of UBTI. Page 44
International tax issues GILTI definitions Net CFC tested income with respect to any US shareholder is the excess (if any) of: The aggregate of such shareholders pro rata share of the tested income of each CFC with respect to which such shareholder is a US shareholder for such taxable year of such US shareholder over The aggregate of such shareholders pro rata share of the tested loss of each CFC with respect to which such shareholder is a US shareholder for such taxable year of such US shareholder Net deemed tangible income return with respect to any US shareholder is the excess (if any) of: 10% of the aggregate of such shareholders pro rata share of the qualified business asset
investment (QBAI) of each CFC over The amount of interest expense allocable to net CFC tested income for the taxable year to the extent the interest income attributable to such expense is not taken into account in determining net CFC tested income GILTI Net CFC tested income Tested income Page 45 Tested loss International tax issues Net deemed tangible income return 10% of QBAI Certain interest
expense Polling question #6 What does GILTI stand for? A. Good intangible long term income B. Global international long-term income C. Global intangible low-taxed income D. None of the above Page 46 International tax issues Section 59A Base erosion and anti-abuse tax (BEAT) Imposed on a corporation (other than registered investment company (RIC), real estate investment trust (REIT) or S corporation) that (applicable taxpayer) has: Average annual gross receipts of at least $500m for three-year period ending with preceding taxable year
A base erosion percentage of at least 3% (or 2% in the case of a bank or registered securities dealer): Page 47 Base erosion percentage is generally the aggregate amount of base erosion tax benefits divided by aggregate amount of all allowable deductions. International tax issues Section 59A BEAT Tax-exempt organizations If a tax-exempt organization makes a deductible payment to a foreign affiliate (defined as 25% common ownership),
such payment may be subject to the incremental minimum tax. No exception to this tax exists for tax-exempt organizations. However, from a pure policy perspective, if the deduction is not giving rise to a tax benefit, then you can argue that the tax does not apply unless it was to business line that generates UBTI. Page 48 International tax issues Section 59A BEAT Base erosion payment includes: Any amount that is paid or accrued by a corporation to a foreign related party and with respect to which a deduction is allowable, including amounts paid or accrued to acquire depreciable or amortizable property
Any premium or other consideration that is paid or accrued by taxpayer to foreign related party for any reinsurance payments taken into account under Sections 803(a)(1)(B) or 832(b)(4)(A) Any amount that constitutes reductions in gross receipts of the taxpayer that is paid or accrued by taxpayer with respect to (1) a surrogate foreign corporation, as defined in Section 7874(a)(2), which is a related party (but only if such person first became a surrogate foreign corporation after November 9, 2017) and (2) a foreign person who is a member of same expanded affiliated group as surrogate foreign corporation Page 49 International tax issues You should now be able to
Identify the basics of filing requirements for international tax forms Recognize the International Practice Unit issued 5/31/17 Identify country-by-country reporting Recognize international tax changes as a result of tax reform Page 50 International tax issues EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our
organization, please visit ey.com. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. 2018 Ernst & Young LLP. All Rights Reserved. 1806-2794003 US SCORE no. 03949-181US ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice. ey.com
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