Recently, the IRS issued Notice 2011-53, the third Notice that addresses the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010. Title V of that Act was about making sure that Americans could not hide assets in foreign bank accounts and essentially evade U.S. tax laws.
FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest. In order to avoid being withheld upon under FATCA, a participating FFI will have to enter into an agreement with the IRS to:
• Identify U.S. accounts,
• Report certain information to the IRS regarding U.S. accounts, and
• Withhold a 30% tax on certain payments to non-participating FFIs and account holders who are unwilling to provide the required information.
FFIs that do not enter into an agreement with the IRS will be subject to withholding on certain types of payments, including U.S. source interest and dividends, gross proceeds from the disposition of U.S. securities, and pass-thru payments.
The prior two Notices, 2010-60 and 2011-34 outlined the way in which the IRS expects to implement the law. These are the basis for "final regulations."
Many banks, brokers, funds and others affected by the impending regulations lobbied for repeal or significant revisions More recently, there have been calls for some kind of phased implementation to allow firms to assess the nature and scope of changes they need to make both to client-facing procedures such as account opening, and to back office systems which, in some cases, may need to be re-built.
Notice 2011-53 essentially spreads the implementation period out across 2013 to 2015 with different bits of the regulation coming into force at different times.
Notice 2011-53 provides a more workable timeline for FFIs and U.S. withholding agents to implement the various requirements of FATCA. Specifically, the notice phases in the implementation of FATCA in the following manner:
• An FFI must enter an agreement with the IRS by June 30, 2013, to ensure that it will be identified as a participating FFI in sufficient time to allow withholding agents to refrain from withholding beginning on January 1, 2014.
• Withholding on U.S. source dividends and interest paid to non-participating FFIs will begin on Jan. 1, 2014, and withholding on all withholdable payments (including on gross proceeds) will be fully phased in on Jan. 1, 2015.
• Due diligence requirements for identifying new and pre-existing U.S. accounts (including certain high-risk accounts) will begin in 2013. Reporting requirements will begin in 2014.
• For purposes of the Notice, high risk accounts include private banking accounts with a balance that is equal to or greater than $500,000.
If you have any questions, please contact Saltmarsh, Cleaveland & Gund, (850) 435-8300.
© EisnerAmper LLP 2011
This publication is intended to provide general information to our friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.
Tuesday, July 19, 2011
Friday, July 15, 2011
Discipline: Your Secret Weapon
Working with markets, understanding risk and return, diversifying and portfolio structure – we’ve heard the lessons of sound investing over and over. But so often the most important factor between success and failure is ourselves.
The recent rocky period in financial markets has brought to the surface some familiar emotions for many, including a strong urge to try to time the market. The temptation, as always, is to sell into falling markets and buy into rising ones.
What’s more, the most seemingly “well-informed” people – the kind who religiously read the financial press and watch business television – are the ones who feel most compelled to try and finesse their exit and entry points.
This suspicion that “sophisticated” investors are the most prone to try and outwit the market was given validity recently by a study, carried out by London-based Ledbury Research, of more than 2,000 affluent people around the world.1
The survey found 40 per cent of those questioned admitted to practising market timing rather than pursuing a buy-and-hold strategy. Yet the market timers were more than three times more likely to believe they traded too much.
“On the face of it, you might think that those who were trading more actively would be more experienced, sophisticated and able to control themselves,” the authors said. “But that seems not to be the case – trading becomes addictive.”
This perspective has been reinforced recently by one of the world’s most respected policymakers and astute observers of markets – Ian Macfarlane, the former governor of the Reserve Bank of Australia and now a director of ANZ Banking Group.
In a speech in Sydney2, Macfarlane made the point that the worst investors tend to be those who follow markets and the financial media fanatically, extrapolating from short-term movements big picture narratives that fit their predispositions.
“Most people experience loss aversion,” he said. “They experience more unhappiness from losing $100 than they gain in happiness from acquiring $100. So the more often they are made aware of a loss, the unhappier they become.”
Because of this combination of hyper-activity, lack of self-control and loss-aversion, investors end up making bad investment decisions, Macfarlane noted.
These behavioural issues and how they impact on investors are well documented by financial theorists. Commonly cited traits include lack of diversification, excessive trading, an obstinate reluctance to sell losers and buying on past performance.3
Mostly, these traits stem from over-confidence. Just as we all tend to think we are above-average in terms of driving ability, we also tend to over-rate our capacity for beating the market. What’s more, this ego-driven behaviour has been shown to be more prevalent in men than in women.
A study quoted in The Wall Street Journal4 showed women are less afflicted than men by over-confidence and are more likely to attribute success in investment to factors outside themselves – like luck or fate. As a result, they are more inclined to exercise self-discipline and to avoid trying to time the market.
The virtues of investment discipline and the folly of ‘alpha’-chasing are highlighted year after year in the survey of investor behaviour by research group Dalbar. The latest edition showed in the 20 years to the end of December 2010, the average US stock investor received annualised returns of just 3.8 per cent, well below the 9.1 per cent delivered by the market index, the S&P-500.5
What often stops investors getting returns that are there for the taking are their very own actions – lack of diversification, compulsive trading, buying high, selling low, going by hunches and responding to media and market noise.
So how do we get our egos and emotions out of the investment process? One answer is to distance ourselves from the daily noise by appointing a financial advisor to help stop us doing things against our own long-term interests.
An advisor begins with the understanding that there are things we can’t control (like the ups and downs in the markets) and things we can. Some of the things we can control including ensuring our investments are properly diversified – both within and across asset classes – ensuring our portfolios are regularly rebalanced to meet our long-term requirements, keeping costs to a minimum and being mindful of taxes.
Most of all, an advisor helps us all by encouraging the exercise of discipline – the secret weapon in building long-term wealth.
Article by Jim Parker, Vice President, DFA Australia Limited
June 2011
1 ‘Risk and Rules: The Role of Control in Financial Decision Making’, Barclays Wealth, June 2011 2 ‘Far Too Much Economic News for Our Own Good’, Ross Gittins, Sydney Morning Herald, June 13, 2011 3 Barberis, Nicholas and Thaler, Richard, ‘A Survey of Behavioral Finance’, University of Chicago 4 ‘For Mother’s Day, Give Her the Reins to the Portfolio’, Wall Street Journal, May 9, 2009 5 ‘2011 QAIB’, Dalbar Inc, March 2011
The recent rocky period in financial markets has brought to the surface some familiar emotions for many, including a strong urge to try to time the market. The temptation, as always, is to sell into falling markets and buy into rising ones.
What’s more, the most seemingly “well-informed” people – the kind who religiously read the financial press and watch business television – are the ones who feel most compelled to try and finesse their exit and entry points.
This suspicion that “sophisticated” investors are the most prone to try and outwit the market was given validity recently by a study, carried out by London-based Ledbury Research, of more than 2,000 affluent people around the world.1
The survey found 40 per cent of those questioned admitted to practising market timing rather than pursuing a buy-and-hold strategy. Yet the market timers were more than three times more likely to believe they traded too much.
“On the face of it, you might think that those who were trading more actively would be more experienced, sophisticated and able to control themselves,” the authors said. “But that seems not to be the case – trading becomes addictive.”
This perspective has been reinforced recently by one of the world’s most respected policymakers and astute observers of markets – Ian Macfarlane, the former governor of the Reserve Bank of Australia and now a director of ANZ Banking Group.
In a speech in Sydney2, Macfarlane made the point that the worst investors tend to be those who follow markets and the financial media fanatically, extrapolating from short-term movements big picture narratives that fit their predispositions.
“Most people experience loss aversion,” he said. “They experience more unhappiness from losing $100 than they gain in happiness from acquiring $100. So the more often they are made aware of a loss, the unhappier they become.”
Because of this combination of hyper-activity, lack of self-control and loss-aversion, investors end up making bad investment decisions, Macfarlane noted.
These behavioural issues and how they impact on investors are well documented by financial theorists. Commonly cited traits include lack of diversification, excessive trading, an obstinate reluctance to sell losers and buying on past performance.3
Mostly, these traits stem from over-confidence. Just as we all tend to think we are above-average in terms of driving ability, we also tend to over-rate our capacity for beating the market. What’s more, this ego-driven behaviour has been shown to be more prevalent in men than in women.
A study quoted in The Wall Street Journal4 showed women are less afflicted than men by over-confidence and are more likely to attribute success in investment to factors outside themselves – like luck or fate. As a result, they are more inclined to exercise self-discipline and to avoid trying to time the market.
The virtues of investment discipline and the folly of ‘alpha’-chasing are highlighted year after year in the survey of investor behaviour by research group Dalbar. The latest edition showed in the 20 years to the end of December 2010, the average US stock investor received annualised returns of just 3.8 per cent, well below the 9.1 per cent delivered by the market index, the S&P-500.5
What often stops investors getting returns that are there for the taking are their very own actions – lack of diversification, compulsive trading, buying high, selling low, going by hunches and responding to media and market noise.
So how do we get our egos and emotions out of the investment process? One answer is to distance ourselves from the daily noise by appointing a financial advisor to help stop us doing things against our own long-term interests.
An advisor begins with the understanding that there are things we can’t control (like the ups and downs in the markets) and things we can. Some of the things we can control including ensuring our investments are properly diversified – both within and across asset classes – ensuring our portfolios are regularly rebalanced to meet our long-term requirements, keeping costs to a minimum and being mindful of taxes.
Most of all, an advisor helps us all by encouraging the exercise of discipline – the secret weapon in building long-term wealth.
Article by Jim Parker, Vice President, DFA Australia Limited
June 2011
1 ‘Risk and Rules: The Role of Control in Financial Decision Making’, Barclays Wealth, June 2011 2 ‘Far Too Much Economic News for Our Own Good’, Ross Gittins, Sydney Morning Herald, June 13, 2011 3 Barberis, Nicholas and Thaler, Richard, ‘A Survey of Behavioral Finance’, University of Chicago 4 ‘For Mother’s Day, Give Her the Reins to the Portfolio’, Wall Street Journal, May 9, 2009 5 ‘2011 QAIB’, Dalbar Inc, March 2011
Tuesday, July 12, 2011
Home Energy Efficiency Tax Credits
It is the hot lazy, hazy days of summer and along with the heat comes additional expenses. If you own your home, you can make your home more energy efficient. Not only will you save on utility bills, you can reduce what you owe the IRS. For 2011 the maximum credit is $500 for eligible energy upgrades. These upgrades include heating and air conditioning systems, insulation, water heaters, windows, and doors. If you previously claimed an energy credit between 2005-2010 of $500 or more, you are not eligible for the 2011 credit.
However, if you make solar energy, wind power, or geothermal system upgrades, the tax break is even better; up to 30% of the cost, with no upper limit. This credit is available through 2016.
For questions or more information about Home Energy Efficiency Tax Credits, please call Lisa Fairbanks at (850) 435-8300, ext. 1066.
However, if you make solar energy, wind power, or geothermal system upgrades, the tax break is even better; up to 30% of the cost, with no upper limit. This credit is available through 2016.
For questions or more information about Home Energy Efficiency Tax Credits, please call Lisa Fairbanks at (850) 435-8300, ext. 1066.
Wednesday, July 6, 2011
QuickBooks Tips & Tricks
Do you need to track your inventory by location or site? QuickBooks now has this feature available in the Enterprise version. If you store inventory at different warehouses, consignment locations or different areas in one warehouse QuickBooks Enterprise will track this for you by location and keep the total average cost of your inventory. On all your purchase and sales forms, you will be able to specify by location for transactions. This Advanced Inventory feature will track drop ship orders too. QuickBooks added six new reports to provide inventory information by location such as Quantity on Hand by Site, Inventory Valuation Summary by Site and Inventory Stock Status by Site.
Do you want QuickBooks payroll detail that allows you to sort, filter and has a summary report which includes all payroll items? You can export the payroll information for quarterly and annual reports to Excel. The option is on the grey menu bar at Employees>Payroll Tax Forms & W2s>Tax Form Worksheets in Excel. This option will export the payroll information for the date range you specify. The Excel workbook that is created will have two tabs: one for the return you specified such as the 941 and another tab with all the payroll data by individual employee that you can sort and filter as needed.
Please call any of our QuickBooks ProAdvisors at (850) 435-8300 if you would like more detail on these tips or if you have any QuickBooks questions.
Do you want QuickBooks payroll detail that allows you to sort, filter and has a summary report which includes all payroll items? You can export the payroll information for quarterly and annual reports to Excel. The option is on the grey menu bar at Employees>Payroll Tax Forms & W2s>Tax Form Worksheets in Excel. This option will export the payroll information for the date range you specify. The Excel workbook that is created will have two tabs: one for the return you specified such as the 941 and another tab with all the payroll data by individual employee that you can sort and filter as needed.
Please call any of our QuickBooks ProAdvisors at (850) 435-8300 if you would like more detail on these tips or if you have any QuickBooks questions.
Friday, July 1, 2011
Terminating a 403(b) Plan – It’s Not So Easy
In Revenue Ruling 2011-7 issued earlier this year, the Internal Revenue Service (“IRS”) provided sponsors of 403(b) plans with some much-needed guidance regarding how to terminate their plans, since many 403(b) plan sponsors have been reconsidering whether they want to continue to maintain such plans in light of the final regulations that were issued by IRS in 2007 covering 403(b) plans. Until this guidance was issued, the IRS’s position was, generally, that a 403(b) plan could not be terminated, so the guidance is a welcomed step. However, there are issues that have not been addressed by IRS and issues that plan sponsors may need to address in order to terminate their plans.
Steps to Plan Termination
The guidance outlines the steps a plan sponsor needs to take to effectively terminate their plan and distribute plan assets. Below is a brief discussion of each of the steps and potential issues that a plan sponsor must consider.
Adopt a Binding Resolution to Terminate the Plan
On or before the date of termination, the plan sponsor must adopt a binding resolution establishing the termination date, freezing contributions to the plan, discontinuing the purchase of annuity contracts or mutual funds, fully vesting all plan participants, approving the distribution of plan benefits, and approving the termination of the plan.
This would seem to be relatively simple except that the IRS assumes that a plan’s document(s) allow the plan sponsor to terminate its plan. This is frequently not the case, so plan sponsors must review their plan document to be sure it allows for the termination of the plan. If the plan document does not contain termination provisions, then the plan sponsor should consult with their plan advisor to determine if the language authorizing the plan’s termination can be added to allow for the plan’s termination.
Freezing/Stopping Plan Contributions
The plan sponsor must stop contributions to the 403(b) plan beginning on the termination date. In addition, if the plan sponsor has a related entity (determined on a controlled group basis) with a 403(b) plan, no contributions may be made to that plan for the period that begins with the termination date and ends twelve months after all benefits have been distributed from the terminated plan. The preceding rule may be disregarded if during the period beginning twelve months before the plan termination and ending twelve months after the distribution of all assets from the terminated plan less than two percent of the employees who were eligible to participate in the terminated plan are eligible to participate in the plan of the related entity.
Participant Notification
Plan participants and beneficiaries must be notified of the plan’s termination and the related tax consequences. The form of the tax notice is described in Internal Revenue Code section 402(f).
Distribute Plan Assets
Plan assets must be distributed to plan participants and beneficiaries as soon as administratively feasible. The IRS generally considers this requirement to be met if all plan assets are distributed within twelve months of the plan’s termination. It should be noted that 403(b) plans covered by ERISA must comply with the qualified joint and survivor annuity requirements to the extent applicable, meaning if the annuity contracts offered under the plan provide for survivor annuity options, then the required notifications must be provided. Many 403(b) annuity contracts state that if the plan is an ERISA plan then such notices will be provided, but plan sponsors should check with the annuity provider to coordinate notification. The IRS’ guidance also leaves some open issues for plan sponsors as follows:
• Individual annuity contracts – If the plan provides individual annuity contracts, then the notice requires the distribution of fully paid individual insurance annuities to each plan participant and beneficiary. The guidance states that such distributions will not be taxable until amounts are actually taken from the annuity contract. The guidance is not clear regarding what should be done by the plan sponsor if plan participants already hold individual contracts in their own name, which is fairly typical. Whether the plan sponsor would simply be able to notify the participants and contract providers that the contracts are no longer part of a 403(b) plan is an open question.
• Group annuity contracts – If the plan is funded with group annuity contracts, the IRS guidance contemplates the assets being distributed by issuing individual certificates (as opposed to contracts) evidencing entitlement to fully paid contract benefits to plan participants and beneficiaries. The guidance states that there are no tax consequences to the plan participant until amounts are actually withdrawn from the contract. From a practical point of view, it may take a very long time (more than twelve months) to issue such certificates because the required paperwork for old contracts is notoriously difficult for the issuing companies to find. Thus, the question is open whether a delay of more than 12 months from the termination date in issuing the certificates would cause the plan termination to be invalid.
• Custodial accounts – Many plans are funded by mutual fund custodial accounts that are maintained either as individual or group agreements. The IRS guidance assumes that such accounts will be distributed in cash, in-kind, or as a direct rollover from the 403(b) Plan to an IRA or another eligible retirement plan by a plan participant of beneficiary. The IRS guidance states that amounts distributed from a custodial account will be taxable unless rolled over to an IRA or another eligible retirement plan within 60 days. The IRS’ guidance is not clear regarding what happens if a participant or beneficiary fails to make an election to receive a distribution, i.e., will it cause the termination to fail?
File a Final Form 5500
403(b) Plans covered by ERISA must file a final Form 5500 by the last day of the seventh month after the date of final distribution of assets from the plan.
Other Issues to Consider in Terminating a Plan
The IRS failed to address some important items, which are discussed below and could cause a plan to fail to terminate. Plan sponsors that have these issues may want to delay terminating their plans until IRS issues additional guidance.
• Plans with grandfathered accounts excluded under Department of Labor’s (“DOL”) Field Assistance Bulletin 2009-2 need to consider whether these accounts may also be excluded from a plan’s termination.
• Plans that allow loans to participants need to determine with the vendor whether the loans can be transferred to the individual annuity account or contract. If they cannot, then tax guidance is need from IRS. Also, it needs to be determined how loan payments will be made, if they were being made by payroll deduction prior to the plan’s termination.
• IRS has not addressed the treatment of 403(b) contracts that include life insurance nor plans that have Roth 403(b) contributions or after-tax contributions. There needs to be additional tax guidance on the treatment of these items before distributions from accounts with these features can be correctly reported for tax purposes.
• The treatment of lost or nonresponsive plan participants needs to be addressed.
Given the number of open issues related to the termination of 403(b) plans at this time, many plan sponsors will want to delay attempting to terminate their plan until additional clarification is issued from IRS and possibly also the DOL. For those plan sponsors that urgently want to terminate their plans, it would be extremely practical to consult with professional advisors to review the particular circumstances of their plan to determine if a plan termination is feasible under current guidance before proceeding with the termination.
For more information, please contact Saltmarsh, Cleaveland & Gund, (850) 435-8300.
© 2011 EisnerAmper LLP
This publication is intended to provide general information to our friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.
Steps to Plan Termination
The guidance outlines the steps a plan sponsor needs to take to effectively terminate their plan and distribute plan assets. Below is a brief discussion of each of the steps and potential issues that a plan sponsor must consider.
Adopt a Binding Resolution to Terminate the Plan
On or before the date of termination, the plan sponsor must adopt a binding resolution establishing the termination date, freezing contributions to the plan, discontinuing the purchase of annuity contracts or mutual funds, fully vesting all plan participants, approving the distribution of plan benefits, and approving the termination of the plan.
This would seem to be relatively simple except that the IRS assumes that a plan’s document(s) allow the plan sponsor to terminate its plan. This is frequently not the case, so plan sponsors must review their plan document to be sure it allows for the termination of the plan. If the plan document does not contain termination provisions, then the plan sponsor should consult with their plan advisor to determine if the language authorizing the plan’s termination can be added to allow for the plan’s termination.
Freezing/Stopping Plan Contributions
The plan sponsor must stop contributions to the 403(b) plan beginning on the termination date. In addition, if the plan sponsor has a related entity (determined on a controlled group basis) with a 403(b) plan, no contributions may be made to that plan for the period that begins with the termination date and ends twelve months after all benefits have been distributed from the terminated plan. The preceding rule may be disregarded if during the period beginning twelve months before the plan termination and ending twelve months after the distribution of all assets from the terminated plan less than two percent of the employees who were eligible to participate in the terminated plan are eligible to participate in the plan of the related entity.
Participant Notification
Plan participants and beneficiaries must be notified of the plan’s termination and the related tax consequences. The form of the tax notice is described in Internal Revenue Code section 402(f).
Distribute Plan Assets
Plan assets must be distributed to plan participants and beneficiaries as soon as administratively feasible. The IRS generally considers this requirement to be met if all plan assets are distributed within twelve months of the plan’s termination. It should be noted that 403(b) plans covered by ERISA must comply with the qualified joint and survivor annuity requirements to the extent applicable, meaning if the annuity contracts offered under the plan provide for survivor annuity options, then the required notifications must be provided. Many 403(b) annuity contracts state that if the plan is an ERISA plan then such notices will be provided, but plan sponsors should check with the annuity provider to coordinate notification. The IRS’ guidance also leaves some open issues for plan sponsors as follows:
• Individual annuity contracts – If the plan provides individual annuity contracts, then the notice requires the distribution of fully paid individual insurance annuities to each plan participant and beneficiary. The guidance states that such distributions will not be taxable until amounts are actually taken from the annuity contract. The guidance is not clear regarding what should be done by the plan sponsor if plan participants already hold individual contracts in their own name, which is fairly typical. Whether the plan sponsor would simply be able to notify the participants and contract providers that the contracts are no longer part of a 403(b) plan is an open question.
• Group annuity contracts – If the plan is funded with group annuity contracts, the IRS guidance contemplates the assets being distributed by issuing individual certificates (as opposed to contracts) evidencing entitlement to fully paid contract benefits to plan participants and beneficiaries. The guidance states that there are no tax consequences to the plan participant until amounts are actually withdrawn from the contract. From a practical point of view, it may take a very long time (more than twelve months) to issue such certificates because the required paperwork for old contracts is notoriously difficult for the issuing companies to find. Thus, the question is open whether a delay of more than 12 months from the termination date in issuing the certificates would cause the plan termination to be invalid.
• Custodial accounts – Many plans are funded by mutual fund custodial accounts that are maintained either as individual or group agreements. The IRS guidance assumes that such accounts will be distributed in cash, in-kind, or as a direct rollover from the 403(b) Plan to an IRA or another eligible retirement plan by a plan participant of beneficiary. The IRS guidance states that amounts distributed from a custodial account will be taxable unless rolled over to an IRA or another eligible retirement plan within 60 days. The IRS’ guidance is not clear regarding what happens if a participant or beneficiary fails to make an election to receive a distribution, i.e., will it cause the termination to fail?
File a Final Form 5500
403(b) Plans covered by ERISA must file a final Form 5500 by the last day of the seventh month after the date of final distribution of assets from the plan.
Other Issues to Consider in Terminating a Plan
The IRS failed to address some important items, which are discussed below and could cause a plan to fail to terminate. Plan sponsors that have these issues may want to delay terminating their plans until IRS issues additional guidance.
• Plans with grandfathered accounts excluded under Department of Labor’s (“DOL”) Field Assistance Bulletin 2009-2 need to consider whether these accounts may also be excluded from a plan’s termination.
• Plans that allow loans to participants need to determine with the vendor whether the loans can be transferred to the individual annuity account or contract. If they cannot, then tax guidance is need from IRS. Also, it needs to be determined how loan payments will be made, if they were being made by payroll deduction prior to the plan’s termination.
• IRS has not addressed the treatment of 403(b) contracts that include life insurance nor plans that have Roth 403(b) contributions or after-tax contributions. There needs to be additional tax guidance on the treatment of these items before distributions from accounts with these features can be correctly reported for tax purposes.
• The treatment of lost or nonresponsive plan participants needs to be addressed.
Given the number of open issues related to the termination of 403(b) plans at this time, many plan sponsors will want to delay attempting to terminate their plan until additional clarification is issued from IRS and possibly also the DOL. For those plan sponsors that urgently want to terminate their plans, it would be extremely practical to consult with professional advisors to review the particular circumstances of their plan to determine if a plan termination is feasible under current guidance before proceeding with the termination.
For more information, please contact Saltmarsh, Cleaveland & Gund, (850) 435-8300.
© 2011 EisnerAmper LLP
This publication is intended to provide general information to our friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.
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