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| cayman economic substance guidance: Harmful Tax Practices Oecd, 2019-01-29 BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard relates to preferential tax regimes where a peer review is undertaken to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions. This progress report is an update to the 2015 BEPS Action 5 report and the 2017 Progress Report. It contains the results of review of all BEPS Inclusive Framework members' preferential tax regimes that have been identified since the BEPS Project. The results are reported as at January 2019. In addition, the Inclusive Framework agreed on a new standard for substantial activities requirements for no or only nominal tax jurisdictions. This report includes the details of this new standard and the other work on additions to and revisions of the harmful tax practices framework. Finally it contains next steps for the work on harmful tax practices. |
| cayman economic substance guidance: Harmful Tax Competition An Emerging Global Issue OECD, 1998-05-19 Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices. |
| cayman economic substance guidance: Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition OECD, 2017-03-27 This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide. |
| cayman economic substance guidance: The Diversity Style Guide Rachele Kanigel, 2018-10-15 New diversity style guide helps journalists write with authority and accuracy about a complex, multicultural world A companion to the online resource of the same name, The Diversity Style Guide raises the consciousness of journalists who strive to be accurate. Based on studies, news reports and style guides, as well as interviews with more than 50 journalists and experts, it offers the best, most up-to-date advice on writing about underrepresented and often misrepresented groups. Addressing such thorny questions as whether the words Black and White should be capitalized when referring to race and which pronouns to use for people who don't identify as male or female, the book helps readers navigate the minefield of names, terms, labels and colloquialisms that come with living in a diverse society. The Diversity Style Guide comes in two parts. Part One offers enlightening chapters on Why is Diversity So Important; Implicit Bias; Black Americans; Native People; Hispanics and Latinos; Asian Americans and Pacific Islanders; Arab Americans and Muslim Americans; Immigrants and Immigration; Gender Identity and Sexual Orientation; People with Disabilities; Gender Equality in the News Media; Mental Illness, Substance Abuse and Suicide; and Diversity and Inclusion in a Changing Industry. Part Two includes Diversity and Inclusion Activities and an A-Z Guide with more than 500 terms. This guide: Helps journalists, journalism students, and other media writers better understand the context behind hot-button words so they can report with confidence and sensitivity Explores the subtle and not-so-subtle ways that certain words can alienate a source or infuriate a reader Provides writers with an understanding that diversity in journalism is about accuracy and truth, not political correctness. Brings together guidance from more than 20 organizations and style guides into a single handy reference book The Diversity Style Guide is first and foremost a guide for journalists, but it is also an important resource for journalism and writing instructors, as well as other media professionals. In addition, it will appeal to those in other fields looking to make informed choices in their word usage and their personal interactions. |
| cayman economic substance guidance: Addressing Base Erosion and Profit Shifting OECD, 2013-02-12 This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters. |
| cayman economic substance guidance: OECD Guidelines for Testing of Chemicals Organisation for Economic Co-operation and Development, 1981 |
| cayman economic substance guidance: Stolen Asset Recovery , 2009 This book is a first-of-its-kind, practice-based guide of 36 key concepts?legal, operational, and practical--that countries can use to develop non-conviction based (NCB) forfeiture legislation that will be effective in combating the development problem of corruption and recovering stolen assets. |
| cayman economic substance guidance: Substance in International Tax Law Florian Navisotschnigg, 2022-08-09 The notion of ‘substance’ is proving to be central to the OECD’s base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership). In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions: What substance is necessary to be entitled to intangible-related returns? What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions? What substance is necessary to collect royalties free from withholding taxes? Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles. It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles. |
| cayman economic substance guidance: Noni Scot C. Nelson, Craig R. Elevitch, 2006 |
| cayman economic substance guidance: Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations (Us Commodity Futures Trading Commission Regulation) (Cftc) (2018 Edition) The Law The Law Library, 2018-06-16 Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations (US Commodity Futures Trading Commission Regulation) (CFTC) (2018 Edition) The Law Library presents the complete text of the Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations (US Commodity Futures Trading Commission Regulation) (CFTC) (2018 Edition). Updated as of May 29, 2018 On July 12, 2012, the Commodity Futures Trading Commission (Commission or CFTC) published for public comment its proposed interpretive guidance and policy statement (Proposed Guidance) regarding the cross-border application of the swaps provisions of the Commodity Exchange Act (CEA), as added by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act or Dodd-Frank). On December 21, 2012, the Commission also proposed further guidance on certain aspects of the Proposed Guidance (Further Proposed Guidance). This book contains: - The complete text of the Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations (US Commodity Futures Trading Commission Regulation) (CFTC) (2018 Edition) - A table of contents with the page number of each section |
| cayman economic substance guidance: Corporate Taxation in the Global Economy International Monetary Fund. Fiscal Affairs Dept., International Monetary Fund. Legal Dept., 2019-03-10 The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities. |
| cayman economic substance guidance: Private Equity Laws Aspatore Books Staff, 2006 Private Equity Laws is an authoritative, incisive collection of insider perspectives on the dynamic and innovative forefront of the laws that govern investments, negotiations, and funding within the fields of private equity and venture capital. Featuring group chairs and partners, all representing some of the nation's top firms, this book discusses the current shape and future state of the private equity field. These leading lawyers share their insight on globalization, investment strategies, claw-back provisions, fundraising, conducting successful fund negotiations, and more. Additionally, these authors offer practical guidance for the individual private equity investor or venture capitalist, elaborating on such laws as Sarbanes Oxely, The Investment Company Act, The Securities Act of 1933, The Investment Advisors Act, and other general tax laws that commonly intersect with private equity practices. |
| cayman economic substance guidance: Mastering the Risky Business of Public-Private Partnerships in Infrastructure Manal Fouad, 2021-05-10 Investment in infrastructure can be a driving force of the economic recovery in the aftermath of the COVID-19 pandemic in the context of shrinking fiscal space. Public-private partnerships (PPP) bring a promise of efficiency when carefully designed and managed, to avoid creating unnecessary fiscal risks. But fiscal illusions prevent an understanding the sources of fiscal risks, which arise in all infrastructure projects, and that in PPPs present specific characteristics that need to be addressed. PPP contracts are also affected by implicit fiscal risks when they are poorly designed, particularly when a government signs a PPP contract for a project with no financial sustainability. This paper reviews the advantages and inconveniences of PPPs, discusses the fiscal illusions affecting them, identifies a diversity of fiscal risks, and presents the essentials of PPP fiscal risk management. |
| cayman economic substance guidance: World Development Report 2019 World Bank, 2018-10-31 Work is constantly reshaped by technological progress. New ways of production are adopted, markets expand, and societies evolve. But some changes provoke more attention than others, in part due to the vast uncertainty involved in making predictions about the future. The 2019 World Development Report will study how the nature of work is changing as a result of advances in technology today. Technological progress disrupts existing systems. A new social contract is needed to smooth the transition and guard against rising inequality. Significant investments in human capital throughout a person’s lifecycle are vital to this effort. If workers are to stay competitive against machines they need to train or retool existing skills. A social protection system that includes a minimum basic level of protection for workers and citizens can complement new forms of employment. Improved private sector policies to encourage startup activity and competition can help countries compete in the digital age. Governments also need to ensure that firms pay their fair share of taxes, in part to fund this new social contract. The 2019 World Development Report presents an analysis of these issues based upon the available evidence. |
| cayman economic substance guidance: The Role of the Board of Directors in Enron's Collapse United States. Congress. Senate. Committee on Governmental Affairs. Permanent Subcommittee on Investigations, 2002 |
| cayman economic substance guidance: Measuring the Real Size of the World's Economy World Bank, 2013 This work is a product of the staff of The World Bank with external contributions--T.p. verso. |
| cayman economic substance guidance: The Mergers and Acquisitions Review Mark Zerdin, 2022 |
| cayman economic substance guidance: Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report OCDE,, 2015 This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports |
| cayman economic substance guidance: International Tax Handbook , 2015-01-01 This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277 |
| cayman economic substance guidance: OECD Guidelines for the Testing of Chemicals, Section 3 Test No. 312: Leaching in Soil Columns OECD, 2004-11-23 The method described in this Test Guideline is based on soil column chromatography in disturbed soil. Two types of experiments are performed to determine (i) the leaching potential of the test substance, and (ii) the leaching potential of ... |
| cayman economic substance guidance: Rogue State William Blum, 2006-02-13 Rogue State and its author came to sudden international attention when Osama Bin Laden quoted the book publicly in January 2006, propelling the book to the top of the bestseller charts in a matter of hours. This book is a revised and updated version of the edition Bin Laden referred to in his address. |
| cayman economic substance guidance: UNCITRAL Secretariat Guide on the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) United Nations Publications, 2016 The Guide on the New York Convention provides an insight on the application of the Convention by State courts. |
| cayman economic substance guidance: Inside the EU Code of Conduct Group Martijn F. Nouwen, 2021 This book analyses the functioning and effectiveness of the diplomatic EU Code of Conduct Group in tackling harmful tax competition in the European Union. |
| cayman economic substance guidance: Land Use, Land-use Change, and Forestry R. T. Watson, Intergovernmental Panel on Climate Change, 2000 Comprehensive, state-of-the-art IPCC report on carbon sequestration and the global carbon cycle. |
| cayman economic substance guidance: Jersey Insolvency and Asset Tracking Anthony Dessain, Michael Wilkins, Rob Gardner, Edward Drummond (Solicitor), 2012 |
| cayman economic substance guidance: Guide to Bank Underwriting, Dealing and Brokerage Activities Robert L. Tortoriello, |
| cayman economic substance guidance: Guide to International Transfer Pricing Dr A. Michael Heimert, T.J. Michaelson, 2018-10-26 The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions. |
| cayman economic substance guidance: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Ansgar A. Simon, 2023-08-31 This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals. |
| cayman economic substance guidance: 受控外國公司課稅制度之研究 元照, 元照出版專書, 黃示亘, 2021-07-01 受控外國公司課稅制度（Controlled Foreign Company Rules, CFC rules）於1960年代自歐美興起，作為國家課稅主權延伸至境外手段之一發展至今。在跨國經濟越發蓬勃情況下，OECD於2015年發布BEPS第3號行動方案，該方案指出CFC制度可以防範納稅人利用各國稅捐法制間差異取得稅捐利益，並提供各構成要件之立法方式。惟我國《所得稅法》第43-3條CFC稅制迄今仍未生效，納稅人與稽徵機關之間權利義務、構成要件適用範圍及時間點上存疑義。 本文藉文獻整理、個案解析、立法例比較等研究方法，先從抽象層面討論CFC稅制應遵守之法律原則，具體層面則以美國CFC稅制（包含GILTI）、BEPS第3號行動計畫、歐盟法制下CFC稅制（包含反避稅指令、歐盟最高法院判決等）為比較標的。之所以特別研究歐盟CFC稅制，係因歐盟最高法院在Cadbury Schweppes案對納稅人跨境經濟活動自由給予最大的保障，也就是會員國只能在納稅人有「純粹人為安排」（wholly artificial arrangement）情況下始得課徵CFC稅捐，間接影響CFC稅制效力。本文將指出在我國CFC課稅制度下，（1）稅捐債務存在仍應由稅捐稽徵機關負舉證責任；（2）無須引進GILTI稅制；（3）且我國已引入歐盟法「純粹人為安排」概念，並討論實質營運豁免條款之運作疑義。至於《境外資金匯回管理運用及課稅條例》等過渡法律失效後，納稅人仍得主張自稅基中減除「彌補CFC稅制生效前受控外國公司之累積虧損」部分。 |
| cayman economic substance guidance: Simon's Taxes John Allsebrook Simon Simon (1st viscount), 1983 |
| cayman economic substance guidance: The International Tax Enforcement (Disclosable Arrangements) Regulations 2020 GREAT BRITAIN., 2020-01-16 Enabling power: Finance Act 2002, s. 136 & Finance Act 2019, s. 84. Issued: 16.01.2020. Sifted: -. Made: 09.01.2020. Laid: 13.01.2020. Coming into force: 01.07.2020. Effect: None. Territorial extent & classification: E/W/S/NI. General. EC note: These Regulations make provisions implementing Council Directive 2018/822 which amends Council Directive 2011/16/EU (the DAC) on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC and requires persons to report information in relation to certain types of arrangements known as reportable cross-border arrangements (defined in the DAC) to HMRC |
| cayman economic substance guidance: Money Laundering Compliance Tim Bennett, 2023-07-31 What is Money Laundering ('ML')? How has the definition of ML expanded in recent years? Where does AML law and regulation come from? When must I report any 'suspicion'? Money Laundering Compliance is designed as a detailed reference source both on legal and technical details, as well as practical and procedural points. It provides a technical and practical overview of AML/CFT provisions in the UK and other key international jurisdictions including: - Bahamas - Bermuda - Cayman Islands - Guernsey - Isle of Man - Jersey - Singapore - Switzerland - United States The Fourth Edition has been completely revised in line with recent legislation and case law, with other key areas of change including: - The impact of Brexit on the UK's position vis-a-vis EU Law, and in particular in relation to the EU Money Laundering Directives covering AML/CFT matters - 'Economic Substance' requirements in key jurisdictions - A new chapter on FinTech, the host of AML/CFT RegTech websites/Mobile Apps, and the introduction of new methods of CDD verification - A new chapter on crypto assets and regulation - Current sanctions against defined Russian Oligarchs - The general prohibition against the provision of trust and company services to certain 'Russian-connected' trusts This essential resource ensures that finance professionals, private bankers, lawyers, trust and estate practitioners, regulators, compliance officers and other advisers remain up to date with this increasingly complex and crucial area of law. This title is included in Bloomsbury Professional's Banking and Finance online service. |
| cayman economic substance guidance: Offshore Company Fundamentals David Offshorman, 2021-05-18 Everything starts out small... The author of this book once heard this mysterious word offshore for the first time, too. And he, too, asked himself questions like: ‘What does a registered agent do?’, ‘How much do nominee services cost?’, ‘Why do I need an apostille?’, and ‘Where is it better to open a bank account?’. It is this inexperienced reader that the book is intended for, and its title speaks for itself. ‘Offshore Company Fundamentals’ contains basic information that is necessary to anyone who, on hearing the word Panama, thinks of a broad hat, rather than of ‘Panama Papers’. However, a sophisticated reader will also appreciate the survey of events and facts without which the topic can hardly be considered properly covered, although they do not exactly qualify as ‘fundamental stuff’: — Panama Papers and other offshore leaks – What data will be available in the era of worldwide exchange of information: sometimes the future looks back at you from your computer screen; — Cyprus deposit haircut 2013, an event that usually makes one lose faith in humanity, but in this case for some reason the only thing lost was money; — How to open a bank account in the new environment? – Learning to fly is easier; — International Consortium of Investigative Journalists (ICIJ), an organisation that is more like an elite Boy Scout task force digging up compromising material on the powers that be if they are in any way associated with offshores; — Where is the nominee director heading? – Wherever he is heading, now you will not be going the same way; — Compliance Officer, a bogey that sophisticated businessmen use to scare children into good behaviour. The more recent popular questions also include: What are CFC rules? Will I need to comply with economic substance requirements? How does the automatic exchange of tax information work? Why set up a trust? Of course, the author could not but cover these highly relevant topics, too. Whether he has succeeded in this and other tasks is up to you to decide! |
| cayman economic substance guidance: Business America , 1984 Includes articles on international business opportunities. |
| cayman economic substance guidance: Planejamento Patrimonial e Sucessório Frederico Bastos, Daniel Zugman, Renato Vilela, 2023-05-15 O crescimento da economia brasileira, a sucessão de gerações em empresas familiares, a especialização na prestação de serviços jurídicos e financeiros e as recentes legislações de transparência internacional tornaram indispensável o desenvolvimento e aprofundamento de conhecimentos especializados em planejamento patrimonial e sucessório. Tal área de atuação pressupõe a aplicação de ferramentas jurídicas interdisciplinares, as quais envolvem aspectos familiares e sucessórios, bem como estratégias societárias e tributárias. O objetivo desta obra é contribuir para o desenvolvimento dessa área de atuação a partir de textos especializados, práticos e com enfoque interdisciplinar |
| cayman economic substance guidance: Offshore Financial Centres and the Law Dominic Thomas-James, 2021-07-15 This book considers the ability of island jurisdictions with financial centres to meet the expectations of the international community in addressing the threats posed to themselves and others by their innocent (or otherwise) facilitation of the receipt of suspect wealth. In the global financial architecture, British Overseas Territories are of material significance. Through their inalienable right to self-determination, many developed offshore financial centres to achieve sustainable economic development. Focusing on Bermuda, Turks and Caicos, and Anguilla, the book concerns suspect wealth emanating from financial crimes including corruption, money laundering and tax evasion, as well as controversial conduct like tax avoidance. This work considers the viability of international standards on suspect wealth in the context of the territories, how willing or able they are to comply with them, and how their financial centres can better prevent receipt of suspect wealth. While universalism is desirable in the modern approach to tackling suspect wealth, a one-size-fits-all approach is inappropriate for these jurisdictions. On critically evaluating their legislative and regulatory regimes, the book advances that they demonstrate willingness to comply with international standards. However, their abilities and levels of compliance vary. In acknowledging the facilitatively harmful role the territories can play, this work draws upon evidence of implication in transnational financial crime cases. Notwithstanding this, the book questions whether the degree of criticism that these offshore jurisdictions have encountered is warranted in light of apparent willingness to engage in the enactment and administration of internationally accepted laws and cooperate with international institutions. |
| cayman economic substance guidance: Tax Management Transfer Pricing Report , 2001 |
| cayman economic substance guidance: Cayman Islands Business Law Handbook Volume 1 Strategic Information and Basic Laws IBP, Inc., 2012-03-30 Cayman Islands Business Law Handbook - Strategic Information and Basic Laws |
| cayman economic substance guidance: Current Law Index , 2007 |
| cayman economic substance guidance: Securities Regulation & Law Report , 1994-07 |
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Cayman creates and supplies small molecules, biochemicals, assay kits, antibodies, and proteins to scientists around the world. We produce reagents of exceptional quality for cancer, oxidative …
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Cayman Chemical has examined statistical methods to test for the presence of outliers in ELISA assays. We find that individual replicates are rarely flagged as outliers, and cannot be eliminated …
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