www.pwc.com Expert Access Seminar Series: Tax Accounting 101 September 14, 2011 Tax Accounting Basics Introduction to Tax Accounting Robin Caicco Darren Speake (905) 869 777-7003 (416) 2471 [email protected] [email protected] Chantal Copithorn Ernesto Basso 777-7030 (905) 949 7348 [email protected] [email protected] Sheri Gauthier (905) 949-7301 [email protected] November 25, 2008 PwC Agenda Section one: Differences in GAAP and impact on tax provision Section two: Deferred income taxes Section three: Current taxes Section four: Effective tax rate reconciliation Section five: Tax Contingencies Section six: Valuation Allowances Section seven: Accounting for Research and Development Tax Incentives Tax Accounting Basics PwC 3 Tax Accounting Basics Objective: 1. Provide refresher on basic tax accounting concepts 2. Highlight some advanced tax accounting areas 3. Highlight differences and similarities between US GAAP and IFRS and ASPE This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, an Ontario limited liability partnership, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. Tax Accounting Basics PwC 4 Accounting for Income Taxes Differences in GAAP • Approach is essentially the same across US GAAP, IFRS and ASPE • Based on balance sheet approach (deferred taxes) • - Entity recognizes a deferred tax asset or liability for the difference between accounting and tax attributes • - Deductible / Taxable Temporary Difference: essentially the same definitions • Recognition Criteria for Deferred Tax Asset: “probable” (IFRS) standard generally interpreted the same as “more likely than not” standard (US GAAP and ASPE). Tax Accounting Basics PwC 5 Accounting for Income Taxes Differences in GAAP • Deferred tax assets and liabilities are calculated using the expected tax rate when the temporary difference is expected to reverse • IAS 12 and ASPE include concept of the substantively enacted rate, whereas US GAAP requires use of enacted legislation • IASB has cited guidance in EIC 111 as an example of how to determine substantively enacted tax rate Tax Accounting Basics PwC 6 Impact on Income Tax Provision • Computation of taxable income is based on the provisions of the Income Tax Act (ITA) • Income from business or property is the taxpayer’s “profit” from that business or property • Profit is not defined in subsection 9(1) of the ITA, therefore interpretation has developed through jurisprudence. Tax Accounting Basics PwC 7 Impact on Income Tax Provision CRA Views? • They have not expressed any concerns regarding the move to IFRS with respect to the computation of taxable income/profit • “New accounting standards are not law and as such, should not change how the CRA interprets and applies the Act” • “New accounting standards will be taken into consideration when the CRA interprets and applies the Act in a given situation” • CRA has also provided confirmation that US GAAP may also be appropriate for tax purposes in certain circumstances • Understand impact on taxable income adjustments Tax Accounting Basics PwC 8 Impact on Income Taxes Consider Impact on Balance Sheet • Thin capitalization – definition of debt/equity (CRA silent to date w.r.t. balance sheet impact of IFRS adoption) • Rate of Quebec Research and Development Wage Tax Credit depends on an asset test • Enhanced SR&ED refund / Claw-back for small business deduction for CCPCs – use certain balance sheet measures • Provincial capital tax implications (becoming less relevant as few provinces now have capital tax) Tax Accounting Basics PwC 9 Questions? © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Deferred Income Taxes © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Deferred Income Taxes • Concept of Deferred Taxes • 4-Step Process 1. 2. 3. 4. • Accounting basis and tax basis Deferred Income Taxes Proof Apply the appropriate tax rate Consider valuation allowances Deferred Income Taxes: Income Statement Tax Accounting Basics PwC 12 Deferred Income Taxes Concept of Deferred Taxes • Cash taxes payable not a fair presentation of real tax burden • May be tax benefit or cost when assets or liabilities realized in future • Key: Difference between tax basis and accounting basis • Common differences: - Capital assets - Intangible assets - Pension plans - Losses Tax Accounting Basics PwC 13 Deferred Income Taxes Example: Deferred Taxes In Practice Company A owns a building that has an accounting value of $4 million and a tax basis of $3.5 million, which means there is a temporary difference of $0.5 million. The company’s tax rate is 40%. Implications if the building was sold tomorrow for its accounting value: • Accounting gain ? • Gain/recapture for tax purposes ? • Taxes payable ? Therefore, there is a deferred tax ? Tax Accounting Basics PwC 14 Deferred Income Taxes Example: Deferred Taxes In Practice Company A owns a movie theatre that has an accounting value of $4 million and a tax basis of $3.5 million, which means there is a temporary difference of $0.5 million. The company’s tax rate is 40%. Implications if the building was sold tomorrow for its accounting value: • Accounting gain nil • Gain/recapture for tax purposes $500,000 • Taxes payable $200,000 Therefore, there is a deferred tax liability of $200,000. Tax Accounting Basics PwC 15 Deferred Income Taxes Quiz: Asset or Liability 1. Development costs are capitalized for accounting purposes, but deducted for tax purposes when incurred. 2. Revenue is received in advance and deferred for accounting, but is included in taxable income on a cash basis. 3. A liability for pension costs is recognized for accounting when the service is provided, but is only deductible for tax when the contributions are funded. 4. The net book value of certain assets is higher than the UCC of those assets. Tax Accounting Basics PwC 16 Deferred Income Taxes Quiz: Asset or Liability 1. Development costs are capitalized for accounting purposes, but deducted for tax purposes when incurred. DT Liability 2. Revenue is received in advance and deferred for accounting, but is included in taxable income on a cash basis. DT Asset 3. A liability for pension costs is recognized for accounting when the service is provided, but is only deductible for tax when the contributions are funded. DT Asset 4. The net book value of certain assets is higher than the UCC of those assets. DT Liability Tax Accounting Basics PwC 17 Deferred Income Taxes 4 -step Approach 1. Accounting basis and tax basis 2. Deferred Income Taxes Proof 3. Apply the appropriate tax rate 4. Consider valuation allowances Tax Accounting Basics PwC 18 Deferred Income Taxes Step 1: Accounting Basis and Tax Basis Accounting values - Financial statements - Trial balance Tax values - Tax returns - Other calculations Tax Accounting Basics PwC 19 Deferred Income Taxes Example: Tax Basis Item Tax basis Accrued liabilities of $1,000 relating to bonuses which will not be paid within 180 days of year-end. ? Accrued liability of $1,000, which relates to a fine payable. ? Loss carryforwards of $1,000. ? Loss carryback of $500. ? On acquisition, an asset was restated from its carrying value of $500 to its fair value of $1,000. ? Tax Accounting Basics 20 Deferred Income Taxes Example: Tax Basis Item Accrued liabilities of $1,000 relating to bonuses which will not be paid within 180 days of year-end. Tax basis $0 Accrued liability of $1,000, which relates to a fine payable. $1,000 Loss carryforwards of $1,000. $1,000 Loss carryback of $500. On acquisition, an asset was restated from its carrying value of $500 to its fair value of $1,000. $0 $500 Tax Accounting Basics 21 Deferred Income Taxes Step 2: Deferred Income Taxes Proof Reconcile change in temporary differences from prior year to temporary differences in 3-column schedule. Tax Accounting Basics PwC 22 3 Column Approach – Revisited Accounting NIBT per f/s Tax $100 $100 25 25 Temporary +/- Reconciling items: 50% of meals & entertainment Depreciation 30 (30) CCA (40) 40 Total $125 $115 $10 Tax expense (30% tax rate) $37 $34 $3 Tax Accounting Basics PwC 23 Example: Fixed Assets Future Income Taxes Proof Accounting Tax Temporary Future Tax at 30% Capital assets – prior year Depreciation/CCA Capital assets – current year Tax Accounting Basics PwC $250 $220 $30 $9 (30) (40) $10 $3 220 180 $40 $12 24 Deferred Income Taxes Step 3: Apply the appropriate tax rate Rate(s) expected to be in effect when the differences reverse Consider: • Changing tax rates • “Substantively enacted” vs. “enacted” • Subject to tax in more than one province Tax Accounting Basics PwC 25 Deferred Income Taxes Step 4: Consider valuation of DTA Must consider whether deferred tax assets can be realized, and amount that should be recognized for accounting purposes. Factors to consider include: • “More likely than not”/ “probable” • Evidence of potential realization • Tax planning strategies Tax Accounting Basics PwC 26 Deferred Income Taxes Deferred Income Taxes: Income Statement Future tax expense generally equals change in net balance sheet position of future assets and liabilities for the year Exceptions: • Business acquisitions • Capital transactions • Certain financing expenses - 20(1)(e) Tax Accounting Basics PwC 27 Deferred Income Taxes Example: Deferred Income Tax Expense At Dec 31, total deferred tax assets are $420,000 and total deferred tax liabilities are $100,000. At the end of the prior year, total deferred tax assets were $250,000 and total deferred tax liabilities were $50,000. During the year, on June 1, the company acquired deferred tax assets of $100,000. Future tax rate is 40%. What is the future tax expense or recovery for the year? Tax Accounting Basics PwC 28 Deferred Income Taxes Example: Deferred Income Tax Expense At Dec 31, total deferred assets are $420,000 and total deferred tax liabilities are $100,000. At the end of the prior year, total deferred tax assets were $250,000 and total deferred tax liabilities were $50,000. During the year, on June 1, the company acquired deferred tax assets of $100,000. Future tax rate is 40%. What is the deferred tax expense or recovery for the year? Deferred tax recovery of $20,000. Tax Accounting Basics PwC 29 Questions? © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Current Taxes © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Current Tax Expense Taxable Income Temporary and Non-Temporary Differences 3 Column Approach Statutory Tax Rate Tax Accounting Basics PwC 32 Current Tax Expense Taxable Income Accounting income +/- Tax Adjustments - Permanent differences - Temporary differences = Net income for tax purposes - Other adjustments (non capital losses utilized) = Taxable income - Apply income tax rate - Less any applicable credits (e.g., ITC, FTC) = Current Income Tax Payable Tax Accounting Basics PwC 33 Current Tax Expense Temporary and Non-Temporary Differences Temporary difference • Generally, items not included in accounting/taxable income in current period, but will be deducted or included in accounting/taxable income • Is the difference between accounting basis and tax basis of an asset or liability Non-temporary difference • Items that will never be allowable deductions or additions to taxable income or items that aren’t included in accounting income Tax Accounting Basics PwC 34 Current Tax Expense Quiz: Temporary or Not 1. Capital cost allowance 2. Depreciation 3. Meals and entertainment 4. Provincial capital taxes paid 5. Membership fees to golf club 6. Pension expense Tax Accounting Basics PwC 35 Current Tax Expense Quiz: Temporary or Not 1. Capital cost allowance Temporary 2. Depreciation Temporary 3. Meals and entertainment Non - temporary 4. Provincial capital taxes paid Non - temporary 5. Non - temporary Membership fees to golf club 6. Pension expense Tax Accounting Basics PwC Temporary 36 Current Tax Expense Three-Column Approach Accounting NIBT per f/s Tax $100 $100 25 25 Temporary +/- Reconciling items: 50% of meals & entertainment Depreciation 30 (30) CCA (40) 40 Total $125 $115 $10 Tax expense (30% tax rate) $37 $34 $3 Tax Accounting Basics 37 Current Tax Expense Statutory Tax Rate Determined based on: • Type of company • What province the company operates in See PwC publication: Tax Facts and Figures: Canada 2011 Also find updates on Tax News Network Tax Accounting Basics PwC 38 Current Taxes Payable Current Taxes Payable Continuity Typically organized by year and tax jurisdiction Prior year activity • Tax return to provision true up • Final payments / refunds • Interest paid / received • Reassessments paid • Penalties paid Current year activity • Current tax expense • Installments Tax Reserves Tax Accounting Basics PwC 39 Effective Tax Rate Reconciliation Rate Reconciliation Purpose of Rate Reconciliation Common Reconciling Items Calculating the Rate of Reconciling Items Tax Accounting Basics PwC 40 Effective Tax Rate Reconciliation Purpose of Rate Reconciliation Total tax expense divided by NIBT = effective tax rate (ETR) Rate reconciliation: • Demonstrates reasonableness of ETR • Compares ETR to statutory rate Tax Accounting Basics PwC 41 Effective Tax Rate Reconciliation Common Reconciling Items Non-deductible expenses (Permanent Differences) Rate adjustments Change in valuation allowance Difference in future income tax rates Tax rate changes Adjustments to tax reserves Adjustments to prior year amounts (Permanent book to filing) Tax Accounting Basics PwC 42 Effective Tax Rate Reconciliation Calculating the Rate of Reconciling Items • Can express each item on a $ basis, or as % of NIBT • Should provide comparatives to prior years so watch groupings • If company has a full valuation allowance (i.e. no DTA has been recognized) benefit of current year losses not recognized or change in valuation allowance may be a significant component Tax Accounting Basics PwC 43 Effective Tax Rate Reconciliation Exercise: Rate Reconciliation Net income before taxes is $125,000. Tax expense is $52,700. Statutory rate is 36%. Tax reserves were increased by $5,000. Non-temporary add-backs were estimated at $10,000. Total temporary differences at the beginning of the year were $45,000, resulting in future tax liabilities of $16,000. Tax rates used for future taxes decreased by 2% during the year. Net Income ? Statutory rate ? ? Tax rate changes ? ? Change in tax reserves ? ? Non-deductible expenses ? ? Effective rate ? ? Tax Accounting Basics PwC 44 Effective Tax Rate Reconciliation Exercise: Rate Reconciliation Net income before taxes is $125,000. Tax expense is $52,700. Statutory rate is 36%. Tax reserves were increased by $5,000. Non-temporary add-backs were estimated at $10,000. Total temporary differences at the beginning of the year were $45,000, resulting in future tax liabilities of $16,000. Tax rates used for future taxes decreased by 2% during the year. Net Income 125,000 Statutory rate 45,000 36.00% Tax rate changes (900) (0.72%) Change in tax reserves 5,000 4.00% Non-deductible expenses 3,600 2.88% Effective rate 52,700 42.16% Tax Accounting Basics PwC 45 Questions? © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Tax Contingencies & Uncertain Tax Positions © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Tax Contingencies IFRS Treatment • IAS 12 does not specifically address • IAS 37 is not considered to apply to income taxes • Acceptable approaches include: - Single best estimate approach - Weighted average probability • May consider uncertain tax position on issue by issue basis or on combined basis • Approach must be applied consistently PwC Page 48 Tax Contingencies ASPE Treatment • ASPE different practices considered acceptable: • Contingency approach (ASPE 3290) • Best estimate approach • Probable asset approach • More likely than not approach • Approach should be consistently applied PwC Page 49 Tax Contingencies US GAAP Treatment Prescribed approach to assessment of Uncertain Tax Positions (UTP’s) under ASC 740-10-25 (Formerly FIN 48) • Evaluation of a “tax position” is a two-step process 1. Recognition – is it more likely than not that a tax position will be sustained, based on technical merits? 2. Measurement – largest amount of benefit that is greater than 50% likely of being realized upon settlement • Detection by a tax authority is assumed PwC Page 50 Tax Contingencies US GAAP – Measurement probability table Possible Estimated Outcome Probability of Occurring Cumulative Probability of Occurring $100 5% 5% 80 30 35 60 20 55 50 20 75 0 25 100 Page 51 Tax Contingencies Measurement probability table: multi-GAAP Possible Estimated Outcome Probability of Occurring Cumulative Probability of Occurring Weightedprobability method $100 5% 5% $5 80 30 35 $24 60 20 55 $12 50 20 75 $10 0 25 100 $0 US GAAP : $60 = cumulative probability greater than 50% (i.e. 55% in example) Best estimate: $80 = highest probability of single estimate Weighted-average: $51 = sum of estimates multiplied by probabilities Page 52 Questions? © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Valuation Allowance © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Valuation of Deferred Tax Assets IFRS – Recognition of Deferred Tax Asset • Recognize a Deferred Tax Asset in the balance sheet when it is “probable” that the future economic benefits will flow to the entity; • “Probable” is not defined in IAS 12, but generally interpreted to mean the same as “more likely than not” (i.e. +50%) • No concept of Valuation Allowance under IFRS • Valuation Allowance remains relevant under US GAAP and ASPE PwC Page 55 Valuation of Deferred Tax Assets What affects the valuation of deferred tax asset? • Changes in business environment (i.e. are we out of the woods?) • Changes in tax law or tax rates • Sources of taxable income include - Carry backs - Reversals of existing taxable temporary differences - Tax planning strategies - Future taxable income PwC Page 56 Valuation of Deferred Tax Assets Available approaches GAAP Approach Probability of Realization Valuation Allowance Required IFRS Probable < 50% Record up to amt probable US More Likely Than Not < 50% Yes Canadian More Likely Than Not < 50% Yes Page 57 Questions? © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Accounting for R&D Tax Credits © 2008 PricewaterhouseCoopers LLP. All rights reserved. “PricewaterhouseCoopers” refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Accounting for R&D Tax Incentives Types of Incentives Accounting issues arise in respect of : • Treatment of R&D Costs • Treatment of Tax Credits Tax Accounting Basics PwC 60 Accounting for R&D Tax Incentives R&D Costs Accounting Alternatives under various GAAP: • Capitalize and Amortize • Recognize in income statement as incurred Tax Accounting Basics PwC 61 Accounting for R&D Tax Incentives Temporary Difference for R&D Costs Temporary Differences to consider: a. R&D costs capitalized for accounting b. R&D costs not claimed for income tax purposes (i.e. SR&ED pools) Tax Accounting Basics PwC 62 Accounting for R&D Tax Incentives Canadian Income Tax Treatment – High Level • SR&ED pool is the available tax deduction consisting of: a) Current SRED expenditures b) Capital SRED expenditures • Tax payers can choose how much they will claim for each year, therefore certain Provincial SR&ED pools may be different than Federal pools Tax Accounting Basics PwC 63 Accounting for R&D Tax Incentives R&D Tax Credits – Accrual For Accounting Purposes ASPE – Accrue when reasonable assurance that they will be realized IFRS & US GAAP – Accrue when more likely than not / probable Factors to consider: • Prior year Audit history • History of profitability • Future profitability Tax Accounting Basics PwC 64 Accounting for R&D Tax Incentives R&D Tax Credits – Accrual for Accounting Purposes Alternatives 1) Cost reduction approach: R&D Tax Credits reduce R&D costs 2) Flow Through Approach: R&D Tax Credits reduce Tax Expense Canadian GAAP – Must use 1) US GAAP and IFRS: • policy choice, therefore either 1) or 2) • If credit is fully refundable, independent of taxable income and income tax return then consider cost reduction approach Tax Accounting Basics PwC 65 Accounting for R&D Tax Incentives Investment Tax Credits – Treatment for Taxable Income Purposes Federal Taxable Income • Federal Investment Tax Credits (“ITC”) – Taxable in taxation year following the year they are utilized • Provincial Tax Credits – Generally, taxable in the year claimed Provincial Differences • Federal ITC - included income in year following year of claim • OITC - included in income in same year of claim, except portion earned on proxy amount is taxed in the year received • ORDTC - included in income in year earned • Quebec salary and wages R&D credit - included in income in year of claim Tax Accounting Basics PwC 66 Accounting for R&D Tax Incentives Accounting for R&D Tax Incentives – Example Facts: For current year, Taxpayer is planning to file a SR&ED Claim reporting the following items: SR&ED Current Expenditures: $4,000 SR&ED Capital Expenditures: $1,000 Federal ITC: $1,000 Assume: a) Company is profitable with a current tax liability well in excess of estimated federal ITCs. b) All current SR&ED costs are expensed for accounting purposes c) The company is a SEC registrant. Tax Accounting Basics PwC 67 Accounting for R&D Tax Incentives Accounting for R&D Tax Incentives – Example Steps to Address Tax Accounting Issues: 1) Prepare proposed journal entry for ITC 2) Using 3 column approach identify impact on temporary differences 3) Compute Future Income Tax Asset or Liability Tax Accounting Basics PwC 68 Accounting for R&D Tax Incentives Accounting for R&D Tax Incentives – Example Step One: 1) ITC earned Debit Credit Current Tax Payable Current Tax Expense $1,000* $1,000 * Calculated as 20% of total current and capital SR&ED expenditures In this example, • Reasonable assurance exists regarding Company’s ability to use Tax Credits Tax Accounting Basics PwC 69 Accounting for R&D Tax Incentives Accounting for R&D Tax Incentives – Example Step Two – Taxable Income Adjustments: Accounting Income Statement $10,000 Tax Deferred $10,000 Addback Accounting Expense: SR&ED Current Exp. $4,000 ($4,000) SR&ED Capital Exp. $0 ($0) SR&ED Current Exp. ($4,000) $4,000 SR&ED Capital Exp. ($1,000) $1,000 ($ $ Deduct Qualifying SR&ED Exp: ITC in Accounting Income $ Total Adjusted $10,000 Tax Accounting Basics PwC 0 0) $9,000 0 $1,000 70 Accounting for R&D Tax Incentives Accounting for R&D Tax Incentives – Example Step 3 FIT – Summary of Temporary Differences Accounting Tax Temp Diff Equipment * $1,000 $ 0 $1,000 SR&ED ITC Claimed ** $1,000 $ 0 $1,000 Total Tax’l Temp Diff $2,000 $ 0 $2,000 * Equipment deducted for tax purposes as SR&ED expenditure, but was capitalized for accounting. Future amortization for accounting will not give rise to any further tax deduction. ** ITC claimed in the current year will be added to taxable income in the following year, therefore represents taxable temporary difference. Tax Accounting Basics PwC 71 Generally applied approaches Refundable Non-refundable ASPE Above the line Above the line IFRS Above the line Choice US GAAP Above the line Tax Expense * *technically there may be choice under US GAAP Page 72 THANK YOU ! This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. © 2010 PricewaterhouseCoopers LLP. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers LLP, which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.
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