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Token issue considerations: Why Howey Test is ineffective for Blockchain and Crypto space?

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Howey Test has no place in Blockchain and Cryptocurrency space and why SEC has to change the rules before other countries take over the Blockchain space. Switzerland is already pushing the envelope to become global Blockchain Hub.
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Initial Coin Offerings (ICOs) were the craze in the world of cryptocurrencies during 2017. While it may seem like they have died down, the fact is they are still out there.

If you are a company that is looking to raise the money using ICO route, you may have wondered as to the accounting and tax implications. At least, the real businesses will have to ask the questions about legality, accounting, and tax issues before they go onto raise the money. Only companies that are trying to scam people will ignore these aspects.

In this article, we will try to talk about the accounting and tax considerations from a business perspective (not individual tax, for individual tax considerations, check out our FBAR and FATCA article and Individual FBAR and FATCA Guide here).

Because this topic is quite broad, we will break it down to the following content to understand it piece by piece.

Content:

Is it a coin or a token?

coin or tokenA coin denotes an ‘exchange value’, much like a US dollar.  You can use the coin for products and services.  For instance, if you hold a dollar bill in your pocket, it doesn’t do anything unless you use it to buy a product or service or invest.  Similarly, a coin does not offer anything on its own blockchain unless the holder exchanges it for something.

Bitcoin is an example of a coin. Litecoin and Ethereum also are native coins of their respective blockchains. Ethereum assumes additional features than a coin because of its ability to execute smart contracts and facilitating Initial Coin Offerings (ICO) and may qualify as a coin and a token (depending on who you are talking to).

Token, on the other hand, is designed to be more than mere ‘exchange of value’. For instance, a token can grant you:

  • Access to services on its blockchain platform
  • Rights to profits from the business
  • Speculative trading opportunities
  • Discounts to certain features on the platform
  • May grant voting rights
  • Master nodes, a new way of locking of the certain number of tokens to generate dividends in the form of native tokens or paid out in coins

It is important to note that although a token may have one or more of the above-listed functionalities, it is not required that a token offers all of the above functionalities to qualify as a token, it does, however, has to offer more than mere ‘exchange of value’.

In summary, a coin can be regarded as ‘cash i.e., exchange of value’ while a token can be regarded as ‘cash i.e., exchange of value + functionality’. 

In summary, a coin can be regarded as ‘cash i.e., exchange of value’ while a token can be regarded as ‘cash i.e., exchange of value + functionality’.

Why is it important to distinguish a token from a coin?

Sec RegulationsAuthorities are trying to apply regulations that are as old as landline phones to a technology landscape that deals with voice activated-face recognizing-thumb printing smartphone era. Just as many of the old era thriller plots would not work in the age of smart-phones, trying to apply regulations that are not designed for the technological revolution such as blockchain will not work.

However, within the current framework of regulations, it is important for the startups and established organizations to be vigilant and avoid triggering a regulatory nightmare.

One way to minimize tripping security regulations is to determine whether what you are offering through your ICO qualifies as a coin or utility token or security token.

One way to minimize tripping security regulations is to determine whether what you are offering through your ICO qualifies as a coin or utility token or security token.

How to structure the token sale and best strategies?

The whole ICO area is at its infancy.  Even those who claim to be ‘experts’ are in a learning phase.  This does not spare you from the need to seek professional legal counsel help before launching an ICO.

The legal counsel will look at various aspects that are specific to your offering to determine whether or not your ICO will result in issuing security tokens or utility tokens.

While the literature is exhaustive, we have put together a summary that compares a utility token with the security token and contrasts with fiat and coin.

utility token over security token

Legal counsel can help with determination of whether a token issued in the ICO leans toward a utility token or a security token based on the characteristics, some of which are referenced in the above table.

While the above Howey test has been used extensively thus far, SEC has recently been cracking down on ICOs that issued tokens recharacterizing them as ‘security offering’. This trend will continue until a complete shakedown of ICOs. The good news, if there is any, is that SEC has not been pursuing criminal charges, rather they have been settling with penalties (although severe).

For the most part, Howey test could be easily challenged by SEC and it is an onerous process to counter SEC’s allegations and companies have to be absolutely sure that what they are offering are indeed utility tokens and not security tokens.

What structure fits your criteria will depend on what you are trying to accomplish. For instance:

  • If you are working on a project that relies heavily on the mass adoption of the technology itself, you might be better off issuing a utility token
  • If you are looking to raise capital in the traditional sense but want to avoid the complications of a traditional IPO, you might be looking to issue security tokens

It is important to note that your intentions have very little to do with how the tokens will ultimately be treated unless you structure your ICO to match your intended purpose with the required professional help.

  1. Howey test and its application to blockchain space

When it comes to following SEC guidelines, most ICOs provide a document that shows where they fall within the Howey Test in determining whether their token should be treated as a security by the SEC.

Howey Test looks at three main considerations:

  1. Investment of money;
  2. The existence of a common enterprise, and
  3. Expectations of profits.

We believe this model of determining the nature of tokens is really an outdated one.  Below you will find our opinion on whether or not Howey test applies to tokens and why it is an ineffective method of determination for the blockchain space.

Rule 1: Investment of money

Money Investment Security Tokens

Tokens:  Satisfies; Although digital currencies are regarded as ‘commodities’, the argument has been placed that those that intend to purchase tokens in a crowdsale have to first exchange fiat in order to procure digital currencies and later exchange such digital currency for tokens and accordingly this first rule will be met.

Why Howey test may limit blockchain space?

Both the Commodities Commission and IRS have regarded Bitcoin as ‘commodity’; Ethereum also resembles features of a commodity although it is a utility token in our opinion, both of which do not satisfy the definition of ‘money’.  However, for the purpose of applying the Howey test, most companies consider Fiat and Digital currency as satisfying the definition of ‘money’. While this is a conservative approach, we think there is a need for clarification;

                  Rule 2: Investment in a common enterprise

Tokens: Yes, this rule is met because, generally speaking, individuals are investing into one ‘identified’ entity; See comments below.

Why Howey test may limit blockchain space?

While in the traditional stock market, investors play a passive role and still earn a share in profits and ownership, it is not entirely so in the blockchain/crypto space.

Investors can increase the demand for tokens of a given enterprise by:

– HODLing (holding to create scarcity in the market and thus increasing the demand)

– Creating hype in the market, this market is in its infancy is very susceptible to the hype (in the form of exaggeration and/or misinformation)

– Writing articles about the project

– Creating support groups and awareness campaigns, both online and offline

As you can see, although the common enterprise controls the profitability of the project by their performance, it is not a sole determinant of the success of the platform (and thus the change in the value of the investment);

We live in a world of shared economy and this also means that millennials not only take part in investing a novel idea, they also take part in its success. Accordingly, applying draconian rules of ‘passive’ investment into an identifiable enterprise to determine whether a token is a security or utility token does more harm than good.

Rule 3: Expectation of profits from the investment

Tokens: Depends; If the expectation of profit is based only on the success of the platform and eventual utility of token in exchange of SERVICES or features on the platform, then the expectation of profits criteria falls into a gray area and such token structure may be regarded as ‘utility token’.

If the expectation of profit is based on a promise of a share in ownership and/or profits and/or equity

and/or voting rights, then token qualifies as security.

Why Howey test may limit blockchain space?

Strictly speaking, this criterion applies to all classes of assets on the blockchain: Coins, utility tokens and security tokens alike.  Those who are investing into these classes are investing in the hope of an increase in value or utility or demand, all of which represent ‘expectation of profits’, in our view.

However, when this line of thought is applied, the whole blockchain (and ICO) space can be stifled.

An immediate overhaul of the regulations is required to enable the growth of blockchain technology space while providing a legal framework to curb bad players.

SEC is your friend, not a foe, a secrete route to avoid needing registering with SEC

US Securities Exchange Commission (SEC) understands that imposing unrealistic rules will not stop the innovation.  What it facilitates is the ‘migration of intellectual capital’ to more friendlier jurisdictions.  This is one of the main reasons why SEC has taken a ‘do no harm’ position.  While ‘do no harm’ is the right direction, it is not a deterministic one.

SEC has launched a helpdesk to help companies figure out whether their offering will be regarded as security or not. Advice will be provided by the help desk on ‘facts and circumstances’ basis’. Address for the help desk is: FinTech@sec.gov

SEC has a dedicated page for emerging FinTech.

SEC also has an exemption to raise capital without needing registration. Under Rule 506(c), a company can broadly solicit and generally advertise the offering and still be deemed to be in compliance with the exemption’s requirements if:

  • The investors in the offering are all accredited investors; and
  • The company takes reasonable steps to verify that the investors are accredited investors, which could include reviewing documentation, such as W-2s, tax returns, bank and brokerage statements, credit reports and the like.

Purchasers of securities offered pursuant to Rule 506 receive “restricted” securities, meaning that the securities cannot be sold for at least six months or a year without registering them.

Being security is not all that bad

While a major part of this article dealt with an ICO tripping security laws and overburdening regulations, there are many companies that are working on solutions when a company deliberately wants to go into an ICO to issue security tokens.  In other words, instead of avoiding being security, some companies may choose to issue a security token.

One such company that is working on solutions in the security tokens space is Polymath.  Their very slogan to market is “securities token platform”.  They want to help the companies with the issuance of security tokens that comply with SEC regulations without the underlying costs. They offer security token launch service to companies that have no legal knowledge as Polymath team will handle the legal side of issuing security tokens.  We anticipate many more service offerings in this space in the coming months and years.

A recent one that we reviewed is called WeOwn (CHX). Own’s Company representative explains their platform as, “We see ourselves as a service and not just an issuance platform. Whilst we do offer and manage primary issuance of financial asset backed tokens, we provide much more services after the issuance event: we manage investor and shareholder data (on our DSR), we manage the dividend disbursements, we create and generate tax and financial reports for both issuers and investors, and we support and manage corporate actions and other events.”

If Own’s vision comes to fruition – the whole complicated and unnecessarily cumbersome capital raising business could become as simple as tapping your smartphone (a bit of exaggeration but you get the point).

We at Cryptotapas believe that Security Token Offerings will storm the capital market in the coming years.  We will inevitably get guidance from the authorities and we will enter into an era of tokenization.  We will ultimately move from raising billions without guidance to raising Trillions of dollars using recognized, institutional platforms.  This will be part of Blockchain promise that will come to pass within the next 3-5 years, in our opinion.

Recently, SEC has proposed that they revisit the existing rules and regulations to facilitate the FinTech space. Switzerland has already started making progress in building a framework that facilitates FinTech space. Many other countries will follow the suite and Howey Test (and similar stock market rules) may be a thing of the past for the Blockchain space soon.

Thank you for reading this article.

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IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

CryptoTapas does not endorse or guarantee the accuracy of the information and claims made in respective publications referenced in this database.

About the author

RK Reddy holds two Masters degrees, one in Accounting and another in Business Administration with over 15 years of experience in the financial services industry.

RK Reddy is an ardent fan of Blockchain and Cryptocurrencies. You can see the excitement about this new technology in every article on Cryptotapas.com. Sometimes this excitement leads to an overly optimistic view. Guilty as charged. RK Reddy says what may seem like an ‘overly optimistic expectation’ today may become an everyday norm in 5-10 years; look at the history of cars or airplanes, Blockchain and Cryptocurrencies belong to a similar frame of reference.”  Of course, that is just his opinion.

CryptoSpace

5 questions we want XRP army to answer!

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xrp investing news

What follows is our opinion.  

Let’s not be hostile.  

Top 5 Cryptocurrencies 2020

We are simply posing some questions based on the information we came across and our own limited interpretation. 

It is quite possible that the sources we are referring to are at fault or our interpretation is. Either way, just answer these questions for us so that we can learn new things about XRP that we did not know.

Our readers know that we have been anti-XRP for a long time. We got trolled, mocked and called ignorant. Well, to each their own.

Our questions to the entire XRP army are simple, here they are:

Question 1: If crypto was to replace (or at least reshape) the entire banking business then what does a token whose sole business model is based on ‘accommodating’ banks have any future?

To put differently, when the world starts conducting commerce via text messages why do we need banks and Ripple which wants to serve banks?

Our basis for this question: 

In the future when we will start doing business with each other over text messages, wallets and email signatures, why do we need a payment gateway from Ripple?

We know that WeChat payment enables users to transact over chat.  Other companies are trying to catch up with this (primarily why Facebook was looking at creating its own currency, Libra).

However, once we have a digital dollar, we do not even need an outside stablecoin since one could, in theory, use the digital dollar directly.                  

Question 2: Why do you have to pay businesses to use XRP if it is so superior?

Our basis for this question: 

Financial Times reported that Ripple paid Moneygram to use Ripple technology.

Here is a direct quote:

It turns out Ripple has been paying a significant amount of subsidies cash to MoneyGram’s business since buying into the company in June. In the third and fourth quarter alone the Ripple benefits amounted to $11.3m.

What’s more, until a consultation with the SEC**, MoneyGram had been more than happy to book these cash flows as revenues. Due to the SEC guidance, however, it has now had to restate fourth-quarter guidance to account for Ripple payments as “contra expenses”.

XRP Twitter

Question 3: What is Ripple’s revenue worth without the ‘selling’ XRP?

Our basis for this question: 

The question seems to be answered by the XRP’s CEO himself. Here is an excerpt:

Asked if XRP was keeping everything cash flow positive at Ripple Labs, Mr Garlinghouse answered: “Well XRP is one source. I don’t know how to answer that because if you took away our software revenues, that would make us less profitable. If you took away all our XRP, that makes us less profitable. So I don’t think about it as one thing.” 

He clarified later: “We would not be profitable or cash flow positive [without selling XRP], I think I’ve said that. We have now.”

In our opinion, we think that the only reason Ripple (XRP) is even operational is because of the billions upon billions of XRP tokens that they keep dumping on the unassuming investors.  

Is this a wrong assumption?

Question 4: If Ripple does not need XRP, why is XRP needed?

Our basis for this question: 

This is based on our understanding that Ripple’s technology can be used by the businesses without having to use XRP.  It is recommended but not ‘required’.

Is this accurate?

Ripple’s solutions can work without XRP (its native token).  So, if XRP is not a utility token in strict sense, how are its creators able to mint and sell them at will without tripping any security laws?

Question 5: If Ripple [XRP] is to act as the ‘stable’ value while the transactions take place on Ripple network, why should anyone trust XRP which is backed by nothing instead of stablecoins like USDC that are backed by real world assets?

Our basis for this question: 

We would personally trust USDC more or even Facebook’s Libra rather than XRP which is backed by nada.

This is what Demelza’s opinion was during our interview:

“The main point is that if XRP were able to back their currency with financial assets and stabilize the purchasing power of the currency, then that would mean XRP coins should have no price appreciation. In fact, only the equity shares of Ripple Labs would profit from XRP’s adoption as a global reserve currency. But Ripple Labs is a privately held company. After fully understanding what XRP is, one realizes that XRP’s investment pitch does not make sense at all.”

Conclusion

We are trying to convince ourselves as to why we need Ripple in the crypto space if:

  • Future of payments is going to be ‘self-bank’ & over the chat
  • There are better stablecoins in the market 
  • Ripple itself as a technology doesn’t need its own native token, XRP

For this very reason, our opinion is that the money will flow out of XRP and the creators will keep dumping their bags into the market until the market can no longer absorb it and then it will be ‘lights out’.

We await for the XRP army to provide us insights that we did not know and our opinion changes…

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

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IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

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DeFi is Not the Holy Grail of Crypto, Here is Why

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Defi Yfi

DeFi has been making millionaires overnight and turning millionaires broke at the same speed.

Those who are on the bandwagon are rejoicing and those who either missed out or got burned by one of the fake projects are yelling ‘Scam’ at DeFi.

Top 5 Cryptocurrencies 2020

Our views are a bit different on the subject.

We do think DeFi is going to be a successful vertical among the blockchain (and crypto) solutions.

It will not be THE holy grail for the redemption of crypto status though.

Supply Chain, Crypto Lending, Insurance, Financial Services, Accounting, Identity, and many more verticals will collectively take blockchain and crypto to the masses.

Shifting our focus back on DeFi, here are some of our thoughts on the current state of DeFi. We do appreciate you dropping any insights you have that we might have missed.

DeFi is not a ponzi, here is why

If the DeFi project you are eyeing meets the following conditions, it is not a ponzi:

  • Audited code: Is the code on which DeFi runs is audited by reputable blockchain auditors? 
  • Reliable team: Who is behind the project? Do they have the know-how? Do they have a history of running scams or leading successful projects? 
  • Actual (sustainable) revenue model: What is the revenue model?  Is it too ‘scammy’ sounding or is it based on sound mathematical (and algorithmic) models?
  • No lock-in periods: Is it easy to get in and out of the platform without any restrictions or lock-in periods?

If you answered yes to ALL of these questions then there is a 100% certainty that the DeFi you are dealing with is not a ponzi (or scam).

However, a caveat is due here.  

Just because the project is not a ponzi doesn’t guarantee its success. Lot of well intentioned companies fail, that’s just the nature of business.

So, do not be one of those guys who sells their home to invest in crypto or DeFi (and that itself is not advice, just an opinion).

If you don’t want to hear it from us, listen to what Yearn Finance creator has to say about DeFi tokens (not all, obviously) having ZERO value.

Source: Crypto Culture

DeFi on Ethereum is not sustainable, here is why

Ethereum DefiMost, if not all, DeFi projects that are making the news today are on Ethereum. 

Ethereum is not a reliable blockchain when it is overloaded.  It gets choked and crashes.  

People are already complaining about exorbitant fees on the network due to the DeFi craze.  

DeFi itself as a crypto vertical is quite new and we are sure there are going to be a lot of ‘killer apps’ that will show up on the scene.

We are currently looking at the DeFi solutions that are being built on other blockchain networks (subscribe for free to know when we post that article).

PolkaDOT is not the end all be all, here is why

Polkadot Defi EcosystemMany are turning to the DOT as the next big thing after Ethereum.

It may very well be.

However, it has not had the chance to prove itself, not yet.

Ethereum’s resilience (or lack thereof) was revealed only during the ICO craze (and then later during CryptoKitties debacle).

What monsters lie in the DOT’s belly?  We don’t know and we would be weary of anyone who claims to know with certainty.

Other things to consider

Entire DeFi space is pretty new and we do not know what we do not know about potential vulnerabilities.

While this is true of Bitcoin itself, Bitcoin has withstood assault for over a decade and still stands stronger.  

Same cannot be said about DeFi.  

Can you imagine someone investing their life-savings into DeFi only to have funds taken because of a bug in the code?

Needless to say, many folks are exploiting the looping system in the DeFi where they take loan against their deposit then lend it back to the platform to take another loan against their deposit, and ad infinitum.

This is causing the DeFi systems to show more liquidity than what truly is.

Conclusion

We think DeFi is an exciting development, however, we still put it alongside ICO craziness for now.

When this space matures and we see reliable solutions emerge – DeFi has the potential to drive a trillion dollar vertical on its own.  

That is just the potential, all the trials and tribulations that we have to go through to get there is going to be one hell of a ride.  

So buckle up and enjoy (and please do not lose your shirts on the ride)!

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

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IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

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These forgotten gems could resurge during this bull run

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Forgotten Crypto Gems

Forgotten Crypto Gems

Disclaimer:  We own few of these tokens and there is no guarantee that these coins will actually resurge. Everything you are about to read is an opinion.  Our intention is to put some projects that have taken the backseat in recent times.

If you are curious as to why we give away so much for free – please check this Crypto Freebies page.

Top 5 Cryptocurrencies 2020

Crypto market is quite weird.  

It deceives the onlooker as if it’s learning from its past mistakes but it’s really not.

For instance, during the 2017 ICO craze, anyone could pitch any half-assed idea and raise millions from unassuming investors.

This bull run in 2020 is all about DeFi and Data Oracles.

Just slap ‘DeFi’ to any project without an actual product or even a single line of code written and you will make a boatload of money.

Because the ‘pump and dump’ practices are not closely monitored in the crypto space, many YouTubers are dumping their bags on their viewers.

It is so blatant that the YouTuber will start out saying “I loaded my bags with this” and then go on about all the mooning stuff and throw in a small disclaimer somewhere and voila. 

They make hundreds of thousands or even millions each day. And we are not exaggerating about that.

You contrast that with what you find here.  

We are giving away all the information we are digging up for free (including our Top 5 tokens for the next decade that we hope will 100x).  If you are curious as to why we give away so much for free – please check this Crypto Freebies page.

We recently started the microcap gems series where we are looking to dig up projects with a decent team, an actual product and lower market cap (usually under $5 Million, sometimes even less).

Because of the $$ limit on the microcap gems, there are some projects that we couldn’t cover in that series.

However, we wanted to float these projects in front of the discernible audience (and newbies who may not have looked into these).

This article’s sole aim is to ‘point’ you to these projects. It will not be a deep dive and as always we encourage you DYOR before investing.

Dragon Chain

Dragon Chain price prediction“Dragonchain is an enterprise and start up ready platform to build flexible and scalable blockchain applications.”

Like most projects we pick, Dragon Chain has solutions ready for business today.  This is not a pipedream or a 15 year roadmap.  That is why we think this is a forgotten gem.

This project is still going strong in the background in terms of development and traction.  They released a video in August about how their anti-fraud and transparency proof systems are used by an exchange.

Website: https://dragonchain.com/

Ticker: DRGN

ATH: $5.27

ATL: .02

Current Price: $0.079

Cindicator

Cindicator CND price prediction

“Cindicator builds predictive analytics by merging collective intelligence and machine learning models. Cindicator’s analytical products are available exclusively to holders of CND tokens.”

Market pays top dollar for prediction data.  Cindicator is one of the first projects to build an AI based market intelligence platform on blockchain.

Cindicator boasts over 135,000 analysts from over 135 countries.

In our opinion, Cindicator is a viable project, although it has not gained traction.

Website: https://cindicator.com/

Ticker: CND

ATH: $0.347

ATL: $0.002

Current price: $0.011

FunFair

Funfair Price Prediction

“FunFair is a revolutionary blockchain technology platform that provides low cost, high quality, transparent casino experiences that are Guaranteed Fair.”

The space that FunFair is targeting is a massive one and is expected to grown even more in the coming years.

Ticker: FUN

ATH: $0.33

ATL: $0.0010

Current price: $0.0052

This page will be updated with future ‘forgotten gems’, so please consider subscribing

Acronyms used: 

ATH: All Time High

ATL: All Time Low

DYOR: Do Your Own Research

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

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IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

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