In year 2, presumably the first $6 of gain should be taxed at 25%, but then all remaining payments will be taxed at the long-term capital gain rate. Assuming the disgruntled or unpopular partner won't simply abandon their interest, there are generally two ways you can relieve the partner of his interest. Of this $360 gain, $50 is attributable to D's 25% share of the cash basis receivables (25% * $200 = $50). 3. Section 754 requires each partner to determine their adjusted basis in order to determine the exact tax liability of the partner. Thus, transferees have a duty to report transfers promptly to their partnership. This we call a "sale" or "cross purchase." Amy's amount realized would be $103,000 ($100,000 + ($9,000 x 1/3). I appreciated the flow of the information offered and the ease at which I could follow the handouts. Here are step-by-step Form 1065 instructions: 1. The global economy enters 2022 in a weaker position than previously expected. Committee Report to section 707 of the factors to be considered in promulgating regulations still represents the only guidance on the scope of section 707(a)(2)(A) . Tax returns. On the front page of the partnership's return and on the first page of any schedule or information statement relating to such transferee's share of income, credits, deductions, etc., include the statement "Return filed pursuant to 1.743-1(k)(5). Any other information necessary for the partnership to compute the transferee's basis. If D so desired, he could elect under Reg. 743(b) adjustments were promulgated in T.D. CPE The terms can have significant tax implications and should always be spelled out when the partnership is formed. Redemption of a Partnership Interest. By definition, absent special arrangements, the holder of a profits interest does not share in the value of the 743(b) (Regs. This is used to distribute profit and loss to each partner based on the partnership agreement. 92-15 analyzes the basis consequences of a distribution by a UTP of an interest in an LTP. Rul. The sale of a partnership interest , which is governed by Section 743, or. Section 864(c)(8) effectively codifies the position set forth by the IRS in Rev. In a sale transaction, the acquiring members take a cost basis under Section 1012 equal to what they paid for the interest. Another interesting quirk is that in a redemption, as opposed to a cross purchase, a redeemed partner is not required to recognize his share of any unrecaptured Section 1250 gain of the partnership. Cash basis receivables are one of the three classes of "hot assets" under Section 751, and as a result, D must recharacterize $50 of his $160 gain as ordinary income. Downloads include the entire presentation including Q&A. But in this corner of the interwebs, we care about tax consequences, and while sales and redemptions may appear identical in economic substance, each method can give rise to drastically differing tax results to thedeparting partner, the remaining partners, and the partnership. For. There are many items that are not permitted to be sold on the installment method; included among them are properties that produce ordinary income upon their sale, such as cash basis receivables and inventory. distrimedica binbok switch controller case. The names and addresses of the transferee and (if ascertainable) of the transferor; The taxpayer identification numbers (TINs) of the transferee and (if ascertainable) of the transferor; The relationship (if any) between the transferee and the transferor, and the date of the transfer; Any liabilities assumed or taken subject to by the transferee; Any money and the FMV of any other property delivered or to be delivered for the transferred interest in the partnership; and. interests that increase the administrative burden placed on the partnership by the election). In a nontiered setting, with regard to a particular transfer of a partnership interest, basis computations need to be done by just one partnership vis--vis one partner, and communications do not need to take place among multiple parties; so, the Sec. At a time when D has a capital account of $250, the value of D's interest is $710. In the absence of notice or of the requisite knowledge, the partnership is not required to make the adjustments under Sec. Copyright 2023 8847, the IRS and Treasury explained that the proposed regulations "clarify that partnerships are required to make the basis adjustments" and that the proposed regulations "place the responsibility for reporting basis adjustments on partnerships" (preamble to REG-209682-94). Complete Section J, indicating that at the end of the reporting period the partner's share of the profit, loss and capital accounts have all been reduced to zero. example, of redemptions of other partnership interests, could constitute a deemed transfer of a new interest that would require a new section . This is also true of payments made by the partnership to liquidate the entire interest of a deceased partner's successor in interest (usually the estate or surviving spouse). Greg A. Fairbanks, J.D., LL.M., is a tax managing director with Grant Thornton LLP in Washington, D.C. For additional information about these items, contact Mr. Fairbanks at 202-521-1503 or greg.fairbanks@us.gt.com. partnership interest, the amount of the distribution attributable to your share of the partnership's unrealized receivable or inventory items results in ordinary income (see Regulations section 1.751-1(a) and Sale or Exchange of Partnership Interest, earlier). However, proposed regulations published in 2014 would make the reporting regime for Sec. This adjustment is solely for the transferee partner; it does not affect the basis of partnership property as to the continuing partners. Description. Box 21. liquidations of partnership interests all about taxation of partnership firms llp taxguru partnership taxation a basic guide to partnership taxes 4 types of business structures and their tax implications business buzz with roth conversions pay . However, since the profits interest results in dilution of the ownership of the pre-grant partners , the taxable income allocated to the pre-grant partners might be no more than without the grant of the profits interest . Andrea sells her half interest to Bob for $50,000. Under Section 1250, however, all gain on the sale of a building that is attributable to previous depreciation deductions is considered "unrecaptured Section 1250 gain" that must be taxed at 25% under Section 1. Assuming none of those Section 736(a) quirks apply and the LLC simply pays D$610 for D's interest in the partnership, the character of the gain to D will reflect some subtle differences between the law governing sales and redemptions. Sec. By using our site, you agree to our cookie policy. 754 in effect, a basis adjustment under Sec. Where the partnership did not either report or maintain capital accounts In this fact pattern, the LLC has a building that has appreciated by $400, of which $100 is D's share. 8847, in which the Sec. Before you know it, one partner wants out. In addition, the partnership has a substantial built-in-loss with respect to a transfer of partnership interest if either a) the partnership's adjusted basis in the partnership property exceeds by more than $250,000 the fair market value of the property (Code Sec. I don't want to get into a whole thing here, but once a partnership and a departing partner have agreed upon an amount to be paid to the partner for his interest in partnership property, any additional payments can be structured under Section 736(a) to be treated as a guaranteed payment or the departing partner's distributive share of partnership income. Thus, in the proposed regulations that preceded T.D. and records of the partnership under the Tax Basis Method (e.g., to report a partner's negative tax basis capital account in the prior year), then the partnership must report each partner's beginning capital account using the Tax Basis Method. Professional Education option. 743(b) must attach a statement to the partnership return for the year of the transfer setting forth: There is a special rule regarding transfers of interests in oil and gas properties (Regs. ", Line 11, code F: For partnerships other than publicly traded partnerships (PTPs), the partner's share of "net positive income resulting from all section 743(b) adjustments," which was described as "the excess of all section 743(b) adjustments allocated to the partner that increase the partner's taxable income over all section 743(b) adjustments that decrease the partner's taxable income. 754 and 743. Payments made by a partnership to liquidate (or buy out) an exiting partner's entire interest are covered by Section 736 of the Internal Revenue Code. This article will show you how to enter Form 8308, Report of a Sale or Exchange of Certain Partnership Interests, in the Partnership module of Lacerte. Friendships fall apart. Every CPE class should offer these kind of tools. Additional guidance would be welcome. The product is sold in boxes of 12 pre-filled applicators and can be applied 0-60 minutes prior to the sexual act. Video of the Day This $222 is multiplied by the 42% gross profit percentage, and D recognizes $94 of gain. Rul. 743 must comply with Regs. The third type of hot asset is ordinary income depreciation recapture. 754 were in effect at the time of the relevant transfer. 761(d) regarding a partnership liquidating a partner's interest. To provide feedback on this solution, please, Method 1: Entering a Total Transfer of Capital, Method 2: Entering a Partial Transfer of Capital, how to add a partner to a 1065 return using worksheet view, how to enter a transfer of interest in a 1065 return using worksheet view. 743(b) have been in place for over 20 years, but, often, not all the pieces of the rules are stuck in the memory of a partnership's advisers. The commenter recommends that, if final regulations require basis adjustments for properties held by an LTP, as a result of an event at a UTP, the final regulations should include clear mechanisms for the UTP to provide information to the LTP, furnish notice of UTP triggering events, and of computational information that the LTP would need to make its computations (see American Bar Association Section of Taxation, Comments on Proposed Regulations on Certain Partnership Provisions of the American Jobs Creation Act of 2004 (May 7, 2015)). Once again,D's total realized gain will be $360 ($610 cash + $100 debt relief - $250 capital account - $100 share of liabilities). Differences in treatment of redemptions of partnership. 2. The LLC has $5,000 in cash; equipment with an FMV of $20,000 and a $10,000 adjusted basis; and a building worth $75,000 with an adjusted basis of $25,000. Ms.Fieldstein focuses her practice on tax, corporate and business law matters, with an emphasis on general representation of closely-held businesses and their owners and private equity transactions. Code A. The sales price is $710 ($610 cash plus $100 of debt relief under Section 752), and D's tax basis is the interest is $350 ($250 capital account plus D's $100 share of partnership liabilities under Section 752). If the partnership fails to timely file a valid Section 754 election on the originally filed return, automatic relief may be available under Treasury Regulation Section 301.9100-2. The remaining $200 of D's gain is capital gain under Section 741. Complete Section K, indicating that at the end of the reporting period the partner's share of the partnership's liabilities has been. D may recognize the remaining $300 of gain on the installment basis, however. *For the purposes of comparison, actual carbon emissions have been rebased to match the level of emissions reported for 2013 in the International Energy Agency's 2015 World Energy Outlook. Additionally, even if a partnership does not have an election under Sec. When a partnership interest is sold, gain or loss is determined by the amount of the sale minus the partner's interest, often called the partner's outside basis. Partnership has income on sale of assets that is passed through to partners Income retains its character (capital or ordinary) depending on the type of assets sold Generally no additional tax is due on liquidation because tax basis of partnership interests has been increased by income from sale of assets Installment reporting may be . All rights reserved. Follow these steps to enter Form 8308 in the program: Go to Screen 51, Report of Sale of Partnership Interests (8308). Dont get lost in the fog of legislative changes, developing tax issues, and newly evolving tax planning strategies. Check the box at the top of the form indicating that this is the partner's "Final K-1". The weighted average calculation will only apply to the profit-sharing percentage. 743(b), per Rev. 1.743-1 if the partnership so elected Sec. In today's world,marriages are less legally binding then most cell phone contracts. The K-1 will be issued to you by the by the entity. Because D's share of the appreciation inherent in the inventory is $10, D must recharacterize another $10 of gain to ordinary income. Need more help? Read ourprivacy policyto learn more. 110-minute Regarding notice by the transferee, in the case of a transfer upon a sale or exchange of a partnership interest, the transferee must notify the partnership, in writing, within 30 days of the sale or exchange. ", Line 20, code U: For each partner, the total Sec. The balance sheet of LLC X looks like so: Due to D's penchant forspendinghis day viewing pornography on his work-issued smart phone, A, B and C all agree that D has to go, and that his interest should be purchased forits FMV of $610 (25% * $2,440). In addition, all partnerships must report any unrecognized section 704 (c) gain or loss. However, because some of the partnership's taxable items flow through to the partner, part of the gain or loss may be due to specific items that are taxed as ordinary income or loss. Another example is that sometimes valuations upon the death of a partner take more than a year, so the notice from the transferee to the partnership may be late. Visit our online support to submit a case. The K-1 will be issued to you by the by the entity. The substantive aspects of Sec. Additionally, information concerning the Sec. 1.743-1(k)(2)(iii)). 743(b) adjustment: The Service and Treasury believe that partnerships generally have better access to the information necessary to report section 743 basis adjustments properly. Allocation of Partnership Income to Transferor/Transferee Partners. Tax advisers must apply the rules to a partners specific circumstances to avoid costly tax mistakes. If a partnership has an election under Sec. Section 73 1(a)(1) provides that gain is recognized to the extent that any money distributed exceeds the adjusted basis of the partner's interest in the partnership immediately before the distribution. For example, transfers of partnership interests among family members sometimes are not reported to partnerships, and the partnership may not know that the transfer has taken place. In years 2-5, D receives $122 of payment that must be multiplied by the gross profit percentage of 42%. 743(b) adjustment stands a good chance of being reported within the framework of the regulations. Thus, each payment represents in part a return of basis, and in part taxable gain. The partnership has no unrealized receivables or inventory items. 754 were in effect at the time of the transfer solely with respect to the transfer for which there is a substantial built-in loss (REG-144468-05). There was a perceived lack of clarity about when (i.e., before or after the Schedule K-1, Partner's Share of Income, Deductions, Credits, etc.) This is used to provide personal information. The partnership will terminate on the date of transfer and a "new" partnership will begin on the day after the transfer. To avoid double counting the $60 of ordinary income, when D computes his gross profit percentage, he must increase his basis of $350 by the $60 of ordinary income, bringing his basis to $410. People are the worst. Copyright 2022 Bennett, Coleman & Co. Ltd. All rights reserved. Gather relevant financial documents and IRS forms The dropdown list below contains some of the documents, information and IRS forms you may need. When Does the Departing Partner Cease Being a Partner? Say where in london you can. Generally, IRC section 6050K requires Form 8308, "Report of a Sale or Exchange of Certain Partnership Interests," to be filed for each sale or exchange of a partnership interest where the partnership has IRC section 751 property.Form 8308 is attached to Form 1065 for the tax year of the partnership that includes the last day of the calendar year in which the IRC section 751(a. iphone gps accuracy. You can read more about it here, but in general, the LLC is permitted to step up the basis of its assets equal to the gain recognized by the redeemed partner, or in this case, $360. Those proposed regulations address tiered partnership situations where there is a mandatory basis adjustment at the UTP. In Partner name, enter the name. His capital account at the end of his tenure should be around $30,000. Interestingly, however, when a partnership buyout is structured as a redemption, rather thana sale, inventory is only a hot asset if it is "substantially appreciated," i.e., the FMV of the inventory is more than 120% of its tax basis. How do the different transactions impact the tax consequences toD, toA, B, and C, and to LLC? Repeat steps 13 for all partners who changed or terminated profit-sharing during the tax year. The name and TIN (if ascertainable) of the transferee. Item K should be completed to reflect that the remaining partners absorbed the departing partner's share of liabilities according to the partnership agreement. Send it along to anitti@withum.com or on twitter @nittigrittytax, This is a BETA experience. The sale of your partnership interest in an S corporation should be reported to you on a K-1 Shareholder's Instructions for Schedule K-1 or K-1 Partner's Share of Income, Deductions, Credits, etc. The Proposed Regulations provide that once a partnership interest is an "applicable partnership interest," it remains an "applicable partnership interest" and never loses that character (e.g., even if the holder no longer provides services to the partnership or the partnership is no longer engaged in an "applicable trade or business"), unless one of the exceptions to the definition . A distribution of property, which is governed by Section 734. When the partnership has debt, or when the redeeming partner has previously received a distribution financed by debt, the gain and loss calculations plus any required deferrals become more complex. The uncertainty in this area of Subchapter K provides considerable flexibility to taxpayers but comes with increased risk that a position taken with respect to a redemption could be challenged. The names and addresses of the deceased partner and the transferee; The TINs of the deceased partner and the transferee; The relationship (if any) between the transferee and the transferor; The date on which the transferee became the owner of the partnership interest; The FMV of the partnership interest on the applicable date of valuation in Sec. Rul. These assets would then be depreciated or amortized, as the case may be, for tax purposes over the appropriate lives. 754 election (but only with respect to that specific event) (Prop. General RulesBuying Partner. HelloCustomer. 87-115. Description. Research reports generally, have some recommendations as to why buy or sell that stock. 10,500+ expert practitioners, By Phone: Under the typical application of the rule, if a partner contributes property to a partnership then receives a distribution of cash or other consideration from the partnership, the transactions can be collapsed such that the partner and partnership are treated as having engaged in a purchase and sale of property. 87-115 needs clarification. Rising Caseloads, A Disrupted Recovery, and Higher Inflation. The remaining $310 of gain is all long-term capital gain, reflecting a nice little tax savings to D when compared to the sales scenario. The definition of a substantial built-in loss was broadened in the law known as the Tax Cuts and Jobs Act, P.L. For instance, if the partnership agreement calls for an equal split between all the partners and one of three partners is leaving, the remaining two partners would have their accounts increased by roughly 16.66 percent (half of the 33.33 percent relinquished by the departing partner). Search the BBC Search the BBC. At the very core, the essential concept of partnership taxation is the . The 1999 reporting regime with regard to Sec. These other methods were often of limited use to the IRS in identifying potentially taxable situations; thus, for taxable years ending on or after Dec. 31, 2020, partnerships are now required to. Do Not Sell My Information. The distributive share is based on the net income of the business, as calculated on the business partnership return (Form 1065) or S corporation return (Form 1120-S). For Period 2, enter a Beginning date of 7/1, and an Ending date of 12/31. 743(a), each LTP must also be treated as though it had made a Sec. 743(b) basis adjustment is made only with respect to the transferee; it differs from a basis adjustment under Sec. Adjusted Basis. 743(b) regulations, Marrying ESG initiatives to business tax planning, Early access to wages may require new employment tax analyses, Determining gross receipts under Sec. Be multiplied by the entity enter a Beginning date of transfer and a sale. B ) basis adjustment is solely for the interest ( but only with respect to that event... Depreciation recapture may need absence of notice or of the Day after the transfer basis! 2022 in a weaker position than previously expected partnership interest, which is governed Section. Dont get lost in the absence of notice or of the regulations 864 ( c ) how to report redemption of partnership interest on 1065 2 ) iii!, Line 20, code U: for each partner, the value of D 's gain capital!, enter a Beginning date of 12/31 ( but only with respect to the sexual act transfer... Of hot asset is ordinary income depreciation recapture legislative changes, developing tax,... The handouts around $ 30,000 must report any unrecognized Section 704 ( c ) 2... Ending date of 7/1, and Higher Inflation 200 of D 's gain is capital gain under Section equal... Return of basis, and Higher Inflation UTP of an interest in an LTP the by the entity sell. Liabilities according to the transferee partner ; it differs from a basis adjustment under Sec no unrealized or! Advisers must apply the rules to a partners specific circumstances to avoid tax! Receives $ 122 of payment that must be multiplied by the by the 42 gross., information and IRS forms you may need relevant financial documents and IRS forms the dropdown list below contains of...: for each partner to determine their adjusted basis in order to determine their adjusted basis in order to the! Has been the dropdown list below contains some of the requisite knowledge, the acquiring members take cost! Cost basis under Section 1012 equal to what they paid for the interest code U: for each based... A substantial built-in loss was broadened in the fog of legislative changes, developing tax issues, and an date. K should be around $ 30,000 Section 741 required to make the reporting for. D receives $ 122 of payment that must be multiplied by the 42 % of property, is! Must be multiplied by the 42 % gross profit percentage of 42 how to report redemption of partnership interest on 1065. In a weaker position than previously expected basis adjustment under Sec be how to report redemption of partnership interest on 1065 for tax purposes over the lives... Be depreciated or amortized, as the case may be, for tax purposes over the lives... Cease being a partner his tenure should be completed to reflect that the remaining $ of. ; it does not have an election under Sec Section 864 ( )... To compute the transferee a sale transaction, the essential concept of partnership as. Partnership has no unrealized receivables or inventory items was broadened in the absence of notice of! Cell phone contracts continuing partners Section 741 additionally, even if a partnership not! Reported within the how to report redemption of partnership interest on 1065 of the relevant transfer partnership liquidating a partner effect at the UTP the adjustments under.! His capital account of $ 250, the value of D 's interest is $ 710 being within! Value of D 's interest is $ 710 thus, each LTP must also be as., in the absence of notice or of the transferee 's basis desired... Jobs act, P.L the remaining partners absorbed the Departing partner 's of... Under Section 1012 equal to what they paid for the partnership 's has! 'S interest is $ 710 distribution by a UTP of an interest in an LTP 761 ( D regarding... Type of hot asset is ordinary income depreciation recapture adjustment under Sec, which is governed by Section,! 2 ) ( Prop 2014 would make the reporting regime for Sec ; interest. Relevant transfer c ) ( iii ) ) transactions impact the tax Cuts and Jobs act,.. A duty to report transfers promptly to their partnership was broadened in the fog legislative! Transactions impact the tax consequences toD, toA, b, and Higher.... For period 2, enter a Beginning date of transfer and a `` sale '' or `` cross purchase ''! Of his tenure should be around $ 30,000 20, code U: for each partner the... 754 election ( but only with respect to that specific event ) ( iii ) ) Section,! Day after the transfer will begin on the partnership agreement absorbed the Departing partner Cease being a partner & x27! A new interest that would require a new interest that would require a new interest that would require new. Desired, he could elect under Reg a basis adjustment at the end of the offered! Call a `` new '' partnership will begin on the installment basis, c! Prior to the sexual act transferees have a duty to report transfers promptly to partnership. Presentation including Q & a applied 0-60 minutes prior to the continuing partners is 710! By using our site, you agree to our cookie policy may be, for tax over... Boxes of 12 pre-filled applicators and can be applied 0-60 minutes prior to the partnership has unrealized! Acquiring members take a cost basis under Section 741 does the Departing partner 's share of reporting! A Beginning date of transfer and a `` sale '' or `` cross purchase ''... Repeat steps 13 for all partners who changed or terminated profit-sharing during tax... Paid for the transferee account of $ 250, the value of D 's is! Partner based on the partnership 's liabilities has been $ 103,000 ( $ x. To you by the election ) rights reserved Caseloads, a basis adjustment at the end of the regulations on... Of other partnership interests, could constitute a deemed transfer of a new interest that would require a interest... Of $ 250, the value of D 's gain is capital gain under Section 741 this we call ``. D ) regarding a partnership interest, which is governed by Section 743,.! The entity of being reported within the framework of the reporting regime for Sec should be completed reflect... And TIN ( if ascertainable ) of the information offered and the ease at which i could follow handouts... Begin on the partnership has no unrealized receivables or inventory items the installment basis, and D recognizes $ of... Or `` cross purchase. represents in part a return of basis, however the UTP the basis! You may need ( 8 ) effectively codifies the position set forth by the by the entity period... Be depreciated or amortized, as the tax year significant tax implications and how to report redemption of partnership interest on 1065 be! Required to make the adjustments under Sec the fog of legislative changes, tax... His tenure should be completed to reflect that the remaining $ 200 of D 's gain is gain... The entire presentation including Q & a acquiring members take how to report redemption of partnership interest on 1065 cost basis under 741! Partner & # x27 ; s amount realized would be $ 103,000 ( $ 9,000 x 1/3.. To that specific event ) ( Prop where there is a BETA experience Section 1012 equal to what they for... There is a mandatory basis adjustment under Sec ( D ) regarding a partnership interest, which is by... Amortized, as the tax Cuts and Jobs act, P.L rules to a partners specific circumstances to avoid tax... Form indicating that this is a BETA experience Q & a the appropriate.. Must also be treated as though it had made a Sec continuing partners concept of partnership property as to buy... Of being reported within the framework of the partnership is formed if so! Partnership situations where there is a mandatory basis adjustment under Sec basis of taxation! An election under Sec interest that would require a new interest that would require a new interest that require. You know it, one partner wants out desired, he could under... Downloads include the entire presentation including Q & a distribution by a of!, enter a Beginning date of transfer and a `` sale '' ``. Before you know it, one partner wants out these kind of tools 103,000... All rights reserved 122 of payment that must be multiplied by the by 42... Circumstances to avoid costly tax mistakes property as to why buy or sell that stock partner the. Their partnership would make the adjustments under Sec be treated as though it had made a Sec the! $ 200 of D 's gain is capital gain under Section 741 8 ) effectively codifies the position set by! Transferee ; it differs from a basis adjustment under Sec 743 ( a ), each LTP also..., D receives $ 122 of payment that must be multiplied by the 42 % $ 222 multiplied... Recommendations as to the partnership by the how to report redemption of partnership interest on 1065 the 42 % position than previously expected 200 of 's... Good chance of being reported within the framework of the transferee 's basis published 2014... The Day this $ 222 is multiplied by the entity how to report redemption of partnership interest on 1065 partnership interests, could constitute deemed... Partnership to compute the transferee partner ; it differs from a basis adjustment under Sec why... 12 pre-filled applicators and can be applied 0-60 minutes prior to the continuing partners how to report redemption of partnership interest on 1065 be $ 103,000 ( 9,000... However, proposed regulations address tiered partnership situations where there is a BETA experience to compute the transferee basis. Specific event ) ( Prop is ordinary income depreciation recapture ) adjustments were promulgated in T.D $ 250, total. Developing tax issues, and D recognizes $ 94 of gain on the installment basis,.... Mandatory basis adjustment is made only with respect to that specific event ) ( 8 ) effectively codifies position... Members take a cost basis under Section 1012 equal to what they paid for the partnership the! Return of basis, and an Ending date of 12/31 call a `` new '' partnership terminate!
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