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    Tax 8611 43272

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    October 2019 ESTATE TAXATION Atty. C. Llamado GROSSESTATE ~ Depends upon the citizenship and/or residence of the decedent: iealear Pale. Tangle Penesl Tatagie Fea Within | Without [~ Within | Without | Within | Without 3) Citizen o Ss 2 oS 9 So 2) Resident Alien [s) @ oS o ) 9 prwomensia| @ | 9] © eo | cd (Gt there is reciprocity) Intangible persoual property moans incorporeal property but represents rights and privileges. Examples include wich do not have any physical form, bank deposits, redemarts, shares of stock, patents, copyrights, bonds, nots, interest ina partnership, a. Tntangible Asset Situs 1), Reveivable (promissory note) Reidenoe of the debior 2)" Bank deposit Location ofthe bank 3)_ Other intangible properties ‘a) Franchises, patents, copyrights, trademarks ‘Where property is used or exercised | b)_ Investment in parmership ‘Where partnership is established ©) Shares of stock (including corporate bonds) (1) Domestic corporation ‘Within the Philippines () Foreign corporation Except: 4) If 85% of business is inthe Philippines il) If shares have acquired a business situs in the Philippines Without the Philippines ‘Within the Philippines Within the Philippines PROPERTIES INCLUDED IN THE GROSS ESTATE OF A DECEDENT ~ Includes all properties, rights, and interests which the decedent owns atthe time of his death; 1) Properties owned by the decedent and physically present in his estate at the time of death; 2) Interest (whether legal or beneficial) in property owned or possessed by the decedent at the time of death (Ex. usuftuctuary ight, leaschold rights), Cctober 2019 3) Taxable Transfers — made during lifetime, but are in the nature of testamentary dispositions (mortis causa in substance). ‘Though he has transferred the property during his lifetime, he fein in cot of the roperty, nd the nse inkended oak fet oly to ater is death, 4) Transfers in Contemplation of Death ~ Transfer is impelled by the thought of death, Ex. Donation mortis causa - donation which takes effect upon the death of the donor, ‘and therefore partakes of the nature of testamentary disposition 1) No transfer of ttle or ownership to the donee; 2), The donor retains ownership (cither legal or beneficial) and remains in full control ‘of the property during is lifetime; 3) The transfer is revocable by the donor at will during his lifetime; and 4) The transfer is void if the donee dies first. ) Revocable transfers; ‘The transferor reserves the power to alter, amend, revoke, ot terminate the enjoyment of the property by the transferee, or where such power is relinquished in contemplation of the decedent's death. + Whether or not such power is exercised during lifetime. If not exercised during lifetime, itis considered exercised atthe time of death. ©) Transfer_with retention or reservation of certain rights over the income or ‘enjovme ‘transferred; + Transferor reserves his right to the income ofthe property until his death. + Transferor reserves his right to the possession or enjoyment of the property until his death, » | power of appointment (*GPA’ + The decedent isthe donee + The (appointed) property comes from a donor (ofthe power) with « GPA for the once (OF the power). The donee is authorized to dispose of the property by {exercising his power of appointment in designating any person who shall possess cr enjoy the propery andor is income. + AGPA makes the appointed property, fo all purposes, the propety of the dance of the power of appointnent. ° is ynsideration In all the taxable transfers above, if the transfer is a bona fide sale for adequate and full, ‘consideration in money or money's worth, no value (of the property transferred) shall be included in the gross estat. However: October 2019 1) Ifthe transfer is not a bona fide sale for an adequate and full consideration in money ‘or money's worth, there shail be included in the gross estate the excess of the FMV of the property atthe time of death over the value ofthe consideration received by the decedent, Included in gross estate ~ FMV of property at time of death ~ Consideration received 2) If transfer is fictitious, the total value of the property at time of death shall be included in the gross esate ofthe decedent. 1) Proceeds of Life Insurance Proceeds of life insurance taken out by the decedent upon his own life shall be included. in his gross estate when: 1) His estate, his executor or administrator is the beneficiary; whether nor not the Sesignation of the beneficiary is revocable; or 2) The beneficiary is any other person, but the decedent retains the power to revoke the ‘designation. Note: When designation of the beneficiary is not clea, it is presumed to be revocable. Proceeds of life insurance are not included in gross estate when: 1) Beneficiary is other than the estate, his executor or administrator, and the designation is irrevocable; 2), Proceeds of a group insurance policy: 3) Benefits from the GSIS, SSS, accruing by reason of death. 4) Claims Against Insolvent Persons. ~ Feceivables due from persons who are insolvent + shall be included in the gross estate at its full amount ~ bad debt deduction is taken for the uncollectible portion 5) ConjugaV/community properties if decedent was married. ~ the decedent's gross estate will include both his exclusive properties, and the Conjugal/community properties of his mariage, Note: Proceeds of life insurance are: 8) Conjugal or community property if the money used to pay the premiums ‘comes from the conjugal or comnaunity funds; +b) Exclusive property of the decedent, if the money used to pay the premiums ‘comes from the decedent's exclusive properties; ©) Partly conjugal or community property and partly exclusive property of the decedent if the premiums were paid partly from the conjugal funds and partly from the exclusive funds ofthe decedent. October 2019 PROPERTIES OF SPOUSES = the extent of the gross estate of the decedent shall depend upon the property relations between the decedent and his/her spouse, ! Property Regimes: 1) Absolute Community of Propery ("ACP"); 2) Conjugal Partnership of Gains ("CPG"), 3) Separation of Property ‘The spouses may, in pre-nuptal agreement (marriage settlement) agree upon the regime that shall gover their property relations However, in the absence of a marriage settlement, the property relations shall be governed by: 4) the CPG for those married before August, 3, 1988, or ) the ACP for those married on or ater August 3, 1988, waren cer Sets Paper isd iy is “Pegs ranma ime oe nr i 2» Ree wt ep Po sot ne Pet ent Sree meormn pee » Rmecian ee See, atet ah oe Pee aed rete pee peiritaee t Sota e eee = oe a OS decd mee, et mere, dion = aa me Wife Conjugal Properties 1) Properties acquired by onerous tile using the common funds (even if the Property is only for one ofthe spouses); 2) Properties obtained from the labor or work of the spouses during marriage; 3) Properties acyvired by chance such as winnings from gambling or betting. (However losses therefrom shall be borne exclusively by the loser-spouse). 4) Fruits (natura! or civil) and income of the conjugal properties; ‘5) Fruits (natural or civil), and income of the exclusive properics of each spouse; October 2019 What isthe ACP? Exclusive Propenty of Husband Exclusive Property of Wife 1) Propeny acquired during the 1) Property secured during the mariage by gratuitous tle (by marriage by gratuitous title (by inheritance or donation) UNLESS inheritance or donation) UNLESS, the donor or testator expressly the donor or testator expresiy provides that the property. shal provides that the property. stall form pat of the community form. pat of the community property propery 2) Fruts and income of exchsive 2) Fruits and income of exchusive properties; Properties, 3) Properties for the personal or 3) Propertis’ for the personal or exclusive use of dhe busband exclusive use of the wife except excep jenely, ewelry 4) Property acquired efore marrage 4) Property acquired before mariage by the usband who bas leptimate by the wife who bas legitimate escendaais from a. previous descendants fom a previous mage roariage 5) Propet designated as exeusve in 5) Property designated as exclusive marrage setlement ina marrage selement = a ‘Community Properties 1) ALL properties owned bythe spouses atthe time ofthe mariage (excent (4) above) 2) ALL properties acquired thereafe. 3) Fruits and income of community properties October 2019 ACQUISITIONS OR TRANSMISSIONS WHICH ARE NOT INCLUDED IN THE GROSS ESTATE OF A DECEDENT (@) Merger of the usufruct in the owner ofthe naked tle tothe property; (b) Fideicommissary substitution — where the inheritance or legacy is delivered ot transmitted by the fiduciary heir or legatee to the second heit (ideicommissary); (©) The transmission ‘tom the first heir, legatee, or danee in favor of another beneficiary, in ‘accordance with the desire of the predecessor, Note: In the three (3) cases, there is actually one transfer involved. Such transfers were already subjected to estate tax, and taxing these would amount to double taxation, (@) All bequests, devises, legacies, or transfers to social welfare, cultural, and charitable institutions, no part of the income of which inures to the benefit of ‘any individual. Provided, however, that not more than 30% of the said bequests. devices, legacies, of transfers shal be used by such institutions for administration purposes (See. 87, NIRC), Other Exemptions fram the estate tax: (©) Proceeds of life insurance and benefits received by members of the Government Service Insurance System (“GSIS") (PD. No, 1146), (O) Benefits received by members from the Social Security System by reason of death (R.A. No. 1161, as amended), (@) Amounts received from the Philippine and United States governments for war damages Ra 2, (h) Amounts received from the United States Veterans Administration (R A. No. 360); (i) Retirement benefits of empioyves of private firms from private pension plans approved by the BIR, @) Intangible personal property located ia the Philippines of a non-resident alicn decedent under the principle of reciprocity (See. 104, NIRC); and (k) Personal Equicy and Retirement Account ("PERA") assets shall not be considered assets Of the Coutributor for purposes of estate taxes (R.A. No, 9505). Furthermore, Qualified PERA Distributions received by the Cootributor, or in ease of the death of the Contributor, received by his beis o: beneficiaries, whether in a lump sum or pension for a definite period or lifetime pension, shall not be subject to estate tax (See. 10, Rev. Regs. No. 17-2011). () Proceeds of life insurance when the beaoficiary is not the estate, the executor, oF the ‘administrator, and the designation is isevocable, (a) Bank deposit ia the name of the decedent on which the 6% estate tax has been withheld and remisted by the bank tothe BIR upon withdrawal by th: bei ‘October 2019 ‘VALUATION OF THE GROSS ESTATE + Properties shall be valued at the time of death of the decedent Property ‘Valuation Usufract, use, habitation, annuity Value sail be based on the probable life of the beneficiary in ‘accordance with the latest Basic Standard Mortality Table approved bby the Department of Finance ‘Real Property FMV which is the higher of the zonal value or the assessor's value [Personal Propeny { Generally, FMV at the time of death ofthe decedent Stocks listed in the stock | Average of the lowest and highest quotes on the valuation date exchange {Gate of death) or day nearest to the valuation dat. Stocks not listedin any |For common shares: Book value on the valuation date (date of local exchange eath), or onthe date nearest the valuation dae. For preferred shares, per value. ‘Notes, cunts FMV isthe discounted amount of the unpaid principal pas interest receivable Units of participation in| FMV is the bid price on the date of death or nearest the date of any association, death, published in any newspaper or publication of general recreation, orarousement | circulation. club (also called | proprietary shares) ‘Cash in bank in local or foreign currency "The peso value of the balance atthe date of death. October 2019 DEDUCTIONS FROM THE GROSS ESTATE 1. ORDINARY DEDUCTIONS A) CLUT (Claims, Losses, Unpaid Mortgages, Taxes, etc.) 1) Claims against the estate - consist of the bona fide unpaid personal obligations of the decedent of a pecuniary nature. These can arise from contract, tort, or by ‘operation of law. These must be incurred in good faith by the decedent during his lifetime, and can be enforced’ against the estate by his creditors, {A)IF the claim arses from the purchase of yoods or services by the decedent, the following must be submitted: 1) Documents evidencing the purchase (invoices, receipts, statements of accounts), 2) Creditors certification as to the unpaid balance of the debt, including interest; and 3) Cerified true copy of the latest audited balance sheet of the oreditor ‘bowing the unpaid balance of the decedent (B) If the claim is in the form of a loan, the following requirements must be ‘complied with: 1) the instrument must be notarized except if it is not the business practice ofthe financial institution-lender to notarize such instruments; 2) ‘notarized certification from the ereditor as tothe unpaid balance of the debi, inclusive of interest; 3) proof of financial capacity of the ereditor to lend the amount at the ‘ime the Ioan was grontod: 4) if the loan was contracted within 3 years prior to the death of the decedert, a stateroent under oath executed by the adrinistawr/executor of the estate stating the disposition of the proceeds of the loan. (C) Where settlement of the estate is made through the cours: 1) Documents filed with the court evidencing the claims; 2) The court order approving the claus; 3) The documents in (A) or (B) above, 2) Claims against insolvent persons must fist be included nthe gros estate; ~ Porton or amount that cannot be calested fiom the decedent's debtor is seducible rom the gross estat= 3) Unpaid mortgages ~ the unpaid mortgage or indebtedness is deductible from the (goss estale provided that the decedent’s interest in the property, gross of the ‘mortgage, is included in the gross estate, " Mast nc have heen forgiven by the erditr, rte action to cllct must nt have preveribed, October 2019 ifthe loan is an accommodation loan where the loan proceeds went to another ‘person, the value of the unpaid loan must be included in the gross estate as a receivable, 4 Tncome taxes and property taxes the following taxes can be deducted from the gross estate: ') Unpaid income taxes on income due or received before the death of the decedent; ') Real property taxes which have accrued prior to the death of the decedent, ‘Note: Real property taxes accrue atthe beginning ofthe year. '5) Casualty Losses - on account of mishaps, accidents, casualties, acts of God, robbery, theft, embezzlement can be deducted provided: ') The loss is not compensated for by insurance or otherwise; ) The loss is in not claimed as a deduction in an income tax retum; ©) The loss must occur not later than the last day for payment of the estate tax (generally within 1 vear after death). B) TRANSFERS for PUBLIC USE 1) Transfers made to the government or any political subdivision for public purposes; oF 2) Transfers to social welfwre, cultural, and charitable institutions, provided: 48) No part ofits net income inures tothe benefit of any individual; and ) <30% of the bequest, devise, or legncy is used for administrative purposes. Note: No purely eligious organization ©) VANISHING DEDUCTION (Property Previously Taxed - “PPT") + To minimize double taxation on same property (located in the Philippines) which was previously received by the decedent as a donation or inheritance, 1. Conditions for AUowance of the Vanishing Deduction (@) The present decedent must have acquired the property by inheritance or donation within five (5) years prior to his death, (b) The property acquired formed a part of the gross estate of the prior decedent, ot ofthe ‘wxable gift of the donor, (©) The estate tax on the prior estate, or the donor's tax on the gift must have been paid; and (4) The estate ofthe prior decedent has not previously availed ofthe vanishing deduction. 2 Percentage of Vanishing Deduction ‘The rates depend on the interval between: (@) The death of the present decedent, and the death of the prior decedent if the ‘Property previously taxed ("PPT") was acquired by inheritance, or October 2019 (&) The death of the present decedent, and the date of the gift, if the PPT wes sscquired by donation. F the interval More Than Not More Than Rercentage xk 1 year 100% 1 year 2yean, 20% 2 years 3 years 60% 3 years 4 years 40% 4 years: ‘S years 20% ‘5 years cog 2000 © ® © @ Determine the lower value of the PPT ~ FMV of the PPT in the estate of the prior decedent, or FMV of the PPT in the estate ofthe present decedent, if PPT was inherited. FMV of the PPT at the date of donation, or FMV of the PPT in the estate ofthe present decedent ifthe PPT was donsied. ‘Where the PPT consists of 2 or more properties, the aggregate of the lower values shall be taken Deduct any mortgage or lien on the PPT which was paid by the present decedent, where such mortgage of lien was used as ‘a deduction in the computation ofthe estate tax ofthe prior decedent, or as « deduction in determining the donor's tax. Net Value of PPT ‘Prorate the deductions and subtract from the net value: —NetValueof PPT _ x Ordinary Deductions ‘Gross Estate (excluding the Van, Ded) Final Basis Apply the rate of Vanishing Deductisn ‘Rate (based on mumber of years intarval) ‘Vanishing Deduction (oa) October 2019 SPECIAL DEDUCTIONS ~ Deducted only after the ordinary deductions have been deducted from the gross estate, ‘A) FAMILY HOME = Must be included in the gross estate. + The deduction is only for one family home which must be the actual residential home of the decedent i 1) EMV of the family home; 1) IE faroily home 1s exclusive property of the decedent: FMV ) Iffamily home is conjugal property: FMV ©) family land is exclusive while the Family house i conjugal: FMV ofland + FMV of house/2 4) If family land is conjugal while family house is exclusive FMVofland’2 + FMV ofhouse OR 2) P10,000,000, 1B) STANDARD DEDUCTION 1) 5,000,000 for estates of citizens and resident aliens; 500,000 for estates of non- resident aliens, 2) Substantiation not required, (©) AMOUNTS RECEIVED BY HEIRS UNDER RA. NO. 4917 = Amounts/benefits received by the heirs from the decedent's employer as a ‘consequence of his death. = Such benefits must first be included in the gross estate before the same can be deducted. IIL SHARE OF THE SURVIVING SPOUSE IN THE NET CONJUGAL PROPERT! ~ Share of the surviving spouse is not subject to estale tax and must therefore be deducted fiom the gross estate ofthe decedent. Amount of deduction= {Conjugal properties less obligations chargeable to such ‘properties (conjugal deductions)] divided by 2 1 i i i t ; i | | 1 October 2019 ‘SUMMARY OF DEDUCTIONS 1. What deductions are available against the estates of citizens, residents, or non- resident aliens? Deduction Citizens/esident ‘Aliens Noo-Resident Alieo cur 1) Claims against the estate 2) Claims against insolvent persons 3) Unpaid mortgages 4 4) Taxes 5) Losses Aeeee “Transfer for public we ‘Vanishing Deduction Family Home E. D. i E. Standard Deduction F. € “Amounts received by heirs under RA 4917. Share of surviving spouse in conjupal nei assets *For the estate of a pon-tssident alien, the allowable CLUT deduction shall be prorated based on the size of the gross estate in the Philippines relative to his entire worldwide gross estate, as follows: Philippine Gross Estate Worldwice Gross Fstate cuut Mi. If the decedent was marriod, how da we allocate the deductions between the exclusive and conjugal properties? Exclusive |” Conjugal’ Total Gross] Properties | Commmunity | Estate Propertiss CUT 1) Claims against the extate ¥ ¥ 2) Claims ayainst insolvent persons x v 3) Unpaid mortgages y q 4) Taxes 1 q 5) Losses: v a TB Transfer Tor public we oe am (C_Vanishing Deduction [Net estate before Special Deductions woe D. Family Home ¥ ~ [E: Standard Deduction To cl F_Amouns received = ¥ ‘G. Share of surviving spoore in conjugal v net assets - a NET ESTATE ESTATE. ESTATE TAX RATE - 6% 2 OctoSer 2019 CREDIT FOR FOREIGN ESTATE TAX PAID Available only to estates of etiaen or resident alien decedents Subject to Limits Limits: (A) Net Estate (per Foreign Country) x Philippine Estate Tax Entire Net Estate (B) Net Estate (in all Foreign Countries) x Philippine Estate Tax Entire Net Estate Rules: 1) Tf there is only one (1) foreign country, only Limit (A) is used. 2) lf there are 2 two (2) foreign countries, use both Limits Formula: Enna tx pid in County 1 Lint a(Cousy yf temet®) Estate tax pid in Country 2 Limit A (Country 2) } tower (2) Lima(ay ‘Sum of estate taxes paid in Counties 1 and 2 Lower= Limit (B) Limit B 13 October 2019 Estate Tax Return ‘The estate tax retur is required tobe filed in the following cases: 2) When the transfer is subject to estate tax; or ) When the gross estate includes properties for which clearance from the BIR (Certificate Authorizing Registration (CAR) is needed before transfer of ownership to the transferees heirs can be effecied (regardless ofthe value of the gross estate) Who files? ‘The executor or administrator, or any of the legal heirs. Time of filing? ‘Within 1 year from death of decedent. ‘Time of filing can be extended for another 30 dsys or less in meritorious cases. The ‘pplication for the extension of time to file the estate tax return raust be filed with the Revenve District Office (“RDO”) where the estate is required to secure its TIN and file its tax returns. This request shall be approved by the Conimissioner or his duly authorized representative. Where fled? 1) decedent was a secure a new TIN time of his death ideut - the administrator or executor shall register the estate and. erefor from the RDO where the decedent was domiciled at the The administratoriexccutor shall file the estate tax return with: (a) an Authonzed Agent Bank (“AB”), or (b) Revenue District Officer or Collection Officer having jurisdiction over the place ‘where the decedent was domiciled ote tine of death, or (© duly authorized Treasurer of the city or municipality in which the decedent was omicited atthe time of his death, ‘whichever is applicable following prevailing rules and procedures on collection. 2) i decedent was a non-resident (whether citizen er alien) the TIN for the estate shall be secured from. and the esate tx rua shall Fe filed with: 1) Withan AB, or with the RDO where the evecut.xiadministator is registered, 2) Ifthe executor/administrator is not reguaered with the BIR, with an AB or with the RDO having jurisdiction over the legal residence ofthe executoradrinistrator 3) If there 15 no executoriadminisrator, with the Office of the Commissioner (RDO No. 39, South Quezon City). Contents ofthe Estate Tux Return 1) Value ofthe gross estate, 2) Gross esate oviside the Philippines for non-esidert alien deoodents, 3) Deductions ellowed and taken, 4) Other suppleroeatal daa, 4 October 2019 5) For estate tax returns showing a gross value exceeding PS Million, a statement ‘certified by a CPA as tothe assets, deductions, and tax duc. Payment of the Estate Tax When paid? + Estate tax is paid atthe time the return is filed (pay as you file) Extension of time to pey: When the Commissioner finds that the payment on the due date of the estate tax or any part thereof would impose undue hardship upon the estate oF any ofthe bets, he ‘may extend the time for payment of such tax or any part thereof not to exceed five (5) ‘years in case the estate is setled through the courts, or two (2) years in case the estat is sttlod extrajdicaly ‘The application for extension of time to pay the estate tax shall be filed with the RDO where the estate is required (0 secure its TIN and file its estate tax return. This request shall be approved by the Conamissioner or his duly authorized representative. ‘The Commissioner may require the executor, or administrator, or beneficiary, as the ‘case may be, to furnish a bond in such amount, not exceeding double the amount of ‘the tax, conditioned upon the payment ofthe said tax in accordance with the terms of the extension, ‘Any amount paid aftr the statutory due date of the tax, but within the extension period, shall be subject to interest but pot to surcharges Payment by Installment In case of insufficiency of eash for the immediate payment of the total estate tax due, the ‘estate may be allowed to pay the estate ax due through the following options: @) Cash Tnstattment The estate tax retum shall be filed within one (1) year from the date of decedent's death; b. ‘The cash installments shall be made within two (2) years from the date of filing of the estate tax return? ©. The frequency (ie., montly, quarterly, semi-annually, or annually), deadline, j and amount of each installment shall be indiceted in the estate tax return, | ‘subject to the prior approval of the BIR; aN ties of in ‘on esta to " ment. However, the Commissioner is not prevented | fom executing enforcement actions against the estate ater the due date of the 7 tn case the available cash of the ease is insufBcient to pay the total estate tax dus, payment by installment shall be allowed within rwo (2) years from the statutory date for its paymeat without civil peaaty and interest (Sec. 91(C), NIRC as inserted by R.A. No. 10963). 15 October 2019 stat tx, provided that all the applicable laws and required procedures are followed/observed; and Tn case of the lapse of2 years without the entire estate tax due being paid, the remaining balance thereof shall he duc and demandable subject to the applicable penalties and interest reckoned ffom the prescribed deadline for {ling the tum, sod payment of the estate tax 2) Partial Disposition of Estate and Application of its Proceeds to the Estate Tax Due? . ‘The estate tax return shall be filed within one (1) year from the date of decedent's death, ‘The written request forthe pertia! disposition’ of the estate shall be approved by the BIR. “The said request shall be fled, together with a nourized undertaking that the proceeds thereof shall be exclusively used for the payment of the tual esate tax due; ‘The computed estate tax due shall be allocated in proportion to the value of ‘each property; ‘The estate shall pay to the BIR the proportionate estate tax due of the property intended to be disposed of; ‘An electronic Certificate Authorizing Registration (“eCAR") shall be issued "upon presentation of proof of payment of the proportionate estate tax due of the property intended to be disposed, Accordingly, there may be as many ‘CARs issued as there are propertics intended 10 be disposed to cover the ‘total estate tax due, net of the proportionate estate taxes previously paid under this option; and {In case of failure wo pay the total estate tex due out ofthe proceeds of the said disposition, the estale tax due shall be immediately due and demandable subject to the applicable penalties and interest reckoned from the prescribed eyt (a) ‘0016 0 4S (@) ‘aad perce (e) jo sano, Sasvedra eens (4) "oaf oOo 20 ewoH ARs 0 Ay JO J0m0}- ewoH Knwed Cy) {cone ‘ssoupopropu)'s9e80) sosusds3) vooticy 1173 (V) OTMNGIT WISE 0 (here, Anoyraia Kvedoxd wo) vorerpeg BuasUeA (9) 4 SHOTS TEVNIGEO 1 SvoK2nPap BUND} suo NIp ssuononpep 210 pono axe ESPESET UOTE HOPI ERT IO BUSI Dunous Sia powone oan HLGpSSRE CTT UPATIS ave siqenony ‘weer So tesies ony conten roo Secs wencooth soe canoe Mw one's om ane aves 3¢ oat e002 aos owe cone) ovo ate aa ost org oo ~ << moni mo em tt = need 918 pow 9 am os 2981 ey aiNs3 99 30g oury ma one Rival NIV aa 18 seed jow pedun 10 wapsoep 0.0 Suan ped ~ eye og BBE sume ( “sono voetnio®- sense one 2 “tonid ojo caren mao sopoynouy one nan Sn ue Kyevod i> own woe sys0} ep Anaase Co ng way sek cnt UT SUT AG SMP THES ‘9 Aed 0 Demoye suse wry wa RIS Ly 2uoreAGHd PeUORND DY 2 aiese p wowed 16 299, -wepecep ou yo sop -wepooep ajo worp 2 oy, wn 0K | ROMA Po On SM UMA BSS OL, SIqUOU 9 URRIM pow og KEYS was arese OM (a)06 295 BUN ‘uyta30) oun, ‘Atodoud ogens6a1 10 parysiat “Auodoid ygensifas Joqsreu ore a "aIen Sau Ou J0 SsRIEORL (2) 40 parysbas jo Msrsuod aSSOLA‘onyOA esd eno sseipseEa! 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