International Taxation - Major Sovereign Wealth Funds - Coursework Example

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Actualwords..................................................... Date due.............................................................................................................................. Date submitted.......................................................................................................... Table of Contents Table of Contents 1 Executive Summary 3 Major Sovereign Wealth Funds 4 References 19 Introduction The People's Republic of China has currency reserves of US $2 trillion. The China Investment Corporation was established in 2007 with the intent of using these reserves for the good of the state, designed according to Singapore’s Temasek Holdings. CIC began operations on September 29, 2007 and it wholly acquired the Central Huijin Investment Corporation. The aims of the Corporation are to invest in approximately fifty large-sized enterprises all over the world. To create the capital, the government issued special treasury bonds worth 1,550.35 billion Yuan. The sale of the bond was completed in December 2007. The CIC have to make a profit of 300 million Yuan every day to pay the operation costs and interest on the bonds. In February 2008, the CIC paid 12.9 billion Yuan as its first interest on the bond. The China Investment Corporation’s management and the board, reports to the State Council of the People’s Republic of China. The board comprises. So far, China has made two thirds of its investment mostly in the US treasury bonds and agency bonds in US dollars currency. Poor returns brought about by the US dollar’s devaluation on the world currency markets prompted the Chinese to form the CIC to manage investment in equities. CIC acquired a $3 billion venture in Blackstone, one of the largest US private equity firms. Credit Suisse predicted the CIC would take a 5-10% stake in each company. This meant that it would remain an inactive investor in these companies to shun from hassles in overseas market. CIC refrains from influencing the investment strategy of Blackstone1. In addition, the CIC is engaging in building influence by acquiring major stakes in companies that have big influence in European governments including airline businesses as well as those firms with heavy investment in China. These investments are intended to help the government to influence the significant policies of international companies and protect her interest in international sphere. On March 2, 2009, Chinese media made a report that the CIC was directing its investment strategy to real estate, resources, and other areas more related with the “real economy”2. Executive Summary Sovereign Wealth Funds refers to investment vehicles financed and controlled by foreign governments.  China, Singapore, Abu Dhabi (UAE), Saudi Arabia and Norway control the largest funds in the world.  These funds have become fully fledged in recent years.  Jointly, these funds have power over perhaps $2-$3 trillion in capital, an amount that is far more than the size of the United States private equity industry.  Influenced by oil profits and/or trade surplus, SWFs are predicted to grow to as much as $10 trillion for the next ten years. Traditionally, foreign governments would often recycle trade surplus back into the US by purchasing Treasury bonds. However, more recently, these governments take a more dynamic investment role, seeking a higher profit than what Treasury bonds offer.  SWFs are the investment alternative they use to do that.  Their collection of investments includes a mix of corporate equity, corporate debt, and governmental obligations3.  The relationship between the Sovereign Wealth Funds and private equity has a complex relationship.  For the last 20 years, SWFs have regularly been limited associates with private equity funds. Sometimes, SWFs aim to make direct investments in target companies, competing with private equities funds for deal flow. In the most recent times, SWFs have bought direct equity in private equity sponsors and other United States financial institutions such as Citigroup, Blackstone, and Merrill Lynch.  Another way to think about SWFs is as a discounted (and tax-subsidized) provider of capital to the private equity industry.  The table below shows the world major Sovereign Wealth Funds as sourced from the Sovereign Wealth Fund Institute website. IMF has projected that foreign assets management under SWF will grow to US$6 trillion by 20134. Major Sovereign Wealth Funds Name of Fund mangers Country of origin Assets under management (US$ billions) Abu Dhabi Investment Authority UAE – Abu Dhabi $875 Government Pension Fund – Global Norway $396.5 SAMA Foreign Holdings Saudi Arabia $365.2 Government of Singapore Investment Corporation Singapore $330 SAFE Investment Company China $311.6 Kuwait Investment Authority Kuwait $264.4 China Investment Corporation China $200 Hong Kong Monetary Authority Investment Portfolio China – Hong Kong $173 National Welfare Fund Russia $162.5 Temasek Holdings Singapore $159 National Social Security Fund China $74 Qatar Investment Authority Qatar $60 Australian Future Fund Australia $58.5 Libyan Investment Authority Libya $50 China Sovereign Wealth Funds China’s operates her sovereign wealth funds secretly and since its establishment in March 2007 has helped state-owned companies to expand overseas in a change of strategy after economic discussions with America. The negotiations ended with an agreement to open Chinese capital markets additional to institutional investors by cutting the “lockup” period for investments. China’s main aim is to receive reciprocal treatment to smoothen the way for its own companies to develop their foreign holdings5. Sovereign funds assist inexperienced Chinese corporations in financing, foreign-exchange risk management and managing trade barriers. This policy is intended to support institutions like the state-owned China Development Bank, which took a 3% stake in Barclays Bank in 2007 and it has been negotiating to increase its shareholding6. The funds have become indirect owners of big stakes in the US troubled financial institutions. They have also stepped up the pace of investment in other countries. By the year 2009 China through SWFs had committed more than $5 billion (£2.5 billion) to private-equity firms that were looking for opportunities in the financial sector. Since then this trend has been accelerating, according to Chinese analysts7. There have been sign that Beijing has given endorsement to a cautious risk-taking strategy in the search for higher returns, sensitive to the political and trade disagreements that can accompany conspicuous investments by the Chinese state in developed economies. China has been seeking to diversify its holdings of more than $1.7 trillion in foreign-exchange reserves, which are largely in US treasury bonds and other fixed-income assets. It is the second largest foreign holder of US treasury securities, with $490 billion after Japan, with $600 billion, according to official figures in March 2008. China made another move in 2008 to diversify its foreign investments the State Administration of Foreign Exchange (Safe) made a decision to invest more than $2.5 billion in a $17 billion fund initiated by the American private-equity firm TPG Capital. TPG had already agreed to buy a twenty three percent stake in Bradford & Bingley for £179m after the slump in the housing market strike the mortgage lender’s profits. This was Safe’s fifth known big investment outside China. It has more stakes in three Australian banks, invested $2 billion in BP Oil Company and acquired a $2.5 billion holding in Total, the French oil giant. Another important investment strategy is its stake of almost one percent in BHP Billiton, the Australian miner, valued at some $2 billion. Bankers and executives on the move to Beijing in search of fresh capital discover that very little is known about the political factions or decision-making at the top. Chinese financial observers have described a bureaucratic dispute between the finance ministry and the People’s Bank of China, the central bank, for management of the world’s biggest foreign-currency holdings. The central bank controls over Safe, although its reporting lines run to the state council, China’s cabinet8. An analysis of Safe’s senior management shows that there is little commercial experience in its upper ranks. Its top administrator, Hu Xiaolian, a rare example of a woman as the head of a Chinese institution, but she is also a lifetime central banker who graduated from the bank’s own university and rose to the position assistant governor. Her subordinates include a former spokesperson for the central bank, a number of managers who served in provincial ranks at Safe, and a senior executive who in the past occupied one of China’s slots at the International Monetary Fund. While many sovereign wealth funds are famous for their discretion, Safe is completely opaque. Many of the investments they make are barely publicly known. People are unable to know about its investments and it does not publish its investment strategy.” It is believed that Safe keeps a low profile because they don’t want to become the focus of public opinion in China because most of the investments they make do carry risk and second, because some western countries are still worried of Chinese sovereign funds. However, the purchase of BP met no resistance from the British government and this indicated that Britain welcomes Chinese capital. It is evident that the private-equity world holds significant attractions for publicity- unlike investment managers in Beijing. The other Chinese sovereign fund, China Investment Corporation (CIC), also made two important investments in the sector. It put more than $3 billion into a private-equity fund introduced by JC Flowers & Co, New York, targeted to selective investment in financial institutions. CIC’s managers anticipated it could better than the badly timed $3 billion investment in the American private-equity firm Blackstone, which it invested just before a slide of about 19% in the shares in 2007. It appointed Lou Jinwei, a former vice-minister of finance, to head CIC, with a position on the state council in acknowledgment of the importance of his role. The state council has a direct supervision over CIC’s management and investments9. Recent investments made by CIC Before we analyze the taxation of China’s Sovereign Wealth funds we are going to look at the most recent investments made by CIC. 10/15/2009: China Investment Corporation invested in Nobel Oil Group, which can be considered as commodity Investment. According to the CIC reports it had completed the settlement for what they called Phase I investment in 45% of the equity in Nobel Oil Group ("Nobel") based in Russia. CIC had agreed to invest a total US$ 300 million in this transaction. The US$ 150 million in Phase I investment included $ 100 million for the acquisition of equity stake from Russian shareholders and $ 50 million to be used in Nobel's operating expenses. In Phase II, the remaining US$ 150million was expected to be used within the next nine months for acquiring and developing oil reserve assets in close proximity to Nobel's existing oilfields"10. 10/26/2009: China Investment Corporation financed US$500 million convertible debenture to South Gobi Energy Resources. According to a press release, made by Alexander Molyneux, President and CEO of SouthGobi Energy Resources Ltd., announced on this date that SouthGobi would accelerate the development of its Mongolian coal projects through its fully owned Mongolian operating subsidiary, Southgobi sands LLC. Mr. Molyneux said financing for the investment program had been secured from a fully owned subsidiary of China Investment Corporation (CIC), which would provide US$500 million in the form of a secured, convertible debenture bearing interest at 8.0%. 11/8/2009: According to the China Investment Corporation Press Release made on this date it said that CIC had made an investment through a wholly-owned subsidiary of the amount of USD 1.58 billion in AES Corporation (AES). At close, it would acquire 125.5 million shares of AES stock for USD 12.6 per share, which is approximately 15% equity interest of the company. According to the investment agreement, CIC would nominate one director to the AES board11. CIC had also signed a letter of intent with AES to invest a further USD 571 million for an approximate 35% interest in the wind generation business of AES. AES, headquartered in Arlington, Virginia, owns and operates a wide portfolio of power generation and distribution businesses in 29 countries. More than two-thirds of AES’ revenue is generated outside of the United States. AES is looking to invest in high growth areas of the power sector, including renewable energy and emerging markets. 11/19/2009: China Investment Corporation made another investment in GCL-Poly Energy Holdings Limited. This was according to the China Investment Corporation's Press Release made on November 11, 2009 that it had signed a binding framework agreement with GCL-Poly Energy Holdings Limited (GCL-Poly) for the purchase of approximately 3,108 million shares of GCL-Poly at a price of HK$1.79 per share. The total investment was around HK$5.5 billion. The agreement was conditional upon, plus other things, the signing of definitive documentation and approval by GCL-Poly’s shareholders. Upon conclusion of the subscription, CIC would own an approximately 20% stake of GCL-Poly on a fully diluted basis. CIC and GCL-Poly partnership intends to invest in and develop photovoltaic projects or other solar energy projects on an initial capitalization of US$500 million"12. As part of the investment, CIC revealed on December that it was intending to buy a 2.3% stake in the private equity group's management company, Apax Partners Worldwide LLP. This company is one of the largest of its kind in Europe, the Financial Times reported, without citing sources. The move showed China’s eagerness to invest abroad, even though it has been obstructed in its attempts to do so in the past, the same report said. In April 2010, according to China Daily reports, Sovereign wealth fund had already finalized a $956 million investment deal with British private equity fund group Apax Partners. 12/27/2009: Taipei Times reported on December 27, 2009 that a US-British asset management giant and a Chinese sovereign wealth fund had agreed to take part in the Hong Kong initial public offering of the world’s largest aluminum producer, UC Rusal. 1/25/2010: China’s CIC Held Talks for Brazil and Mexico Investments. According to Bloomberg on 25 January 2010, China Investment Corporation, the nation’s sovereign wealth fund, had had talks for direct investments in Brazil and Mexico, Chairman Lou Jiwei had said. According to Jiwei the sovereign wealth fund planned to increase direct investments this year, 2010, and prioritizes such investments in developing markets, he added at a financial forum in Hong Kong that CIC planned to be an “active, minority” shareholder in companies, rather than being involved in day-to-day operations. The China’s sovereign wealth fund is also in discussion with Italian power operator Enel SpA on acquiring stakes in the energy firm and its subsidiary company Enel Green Power. CIC's moves may persuade other foreign private equity groups to seek financial support from the Chinese sovereign wealth fund. It also shows that China is still eager to invest its rapidly increasing foreign reserves in foreign markets after the heavily criticized unprofitable investment in Blackstone two years ago. The recent development of CIC shows that the kind of investments it had projected may not be coming by because according to Reuters, China Investment Corporation (CIC)’s earlier proposal to the finance ministry for $200 billion, an additional funding was not approved. It was forced to cut the amount to $ 100 billion. The CIC completed most of its investments projects for its initial funding in 2009, leaving quite little cash on hand, but whether it would receive new funding was the decision of the central government13. Taxing Sovereign Wealth Funds There have been so many discussions about Sovereign Wealth Fund in the recent past. Nevertheless, two big questions have been basically ignored. The first being how SWFs are taxed and how they should be taxed. That is the object of this project report: purposely, to evaluate the current tax systems affecting SWFs especially from the perspective of People’s Republic of China with intention of identifying suitable tax policies applicable to SWFs. Other countries taxation policies are very important to China because she is among the leading countries, which have made their foreign investments in the form of SWFs. Therefore, when looking at the taxation of SWFs of China it is compulsory to look at the US taxation policies on SWFs. In order to appreciate the special tax rules at times available to SWFs, it is essential to analyse the taxation of foreign investors generally14. As mentioned above, the distinction between SWFs and the many other funds owned or controlled by governments is unclear. As a result, it is anticipated that SWFs generally to be taxed in the same fashion as all the other government owned and controlled funds. The tax systems applicable to SWFs and other governmental funds are grouped into three categories that are characterized by their underlying policies. The three categories are: (i) unilateral exemption for passive investment income (i.e., interests, dividends and capital gains from dealings in bonds, stocks and other securities); (ii) reciprocal exemptions for passive investment revenue either under host country’s law or as a result of bilateral tax treaties; and (iii) Taxation to the equal extent as private foreign investors. Each of these three categories is described in greater detail below. Unilateral Exemptions. In the first category are countries that provide unilateral exemptions for SWFs on their passive investment income. The exemption is granted as an extension of the doctrine of sovereign immunity. Because of the prevalent adoption of the restrictive premise of sovereign immunity, and this immunity no longer applying to commercial activities of foreign government enterprises, the unilateral tax exemptions typically only apply to passive investment income and do not apply to income from commercial activities. The United States, Australia, and the United Kingdom are in the first category. Under the domestic tax law, the United States grants a unilateral exemption to foreign governments. As long as the SWFs are either an essential part of a foreign government or an entity managed by the foreign government, SWFs enjoy the advantage of the tax exemption. The exemption is applicable to interest, dividends and capital gains from transactions in stocks, bonds and other securities15. The exemption is also applicable to capital gains realised on the sale of stock in a US real property holding company. On the other hand, proceeds from the sale of a directly owned US real property interest would be subject to tax. Additionally, royalty income, income directly realised from commercial activities and dividends, as well as capital gains realised from a controlled commercial enterprise do not qualify for the exemption16. The Australian exemption for foreign governments is applied administratively on a case-by-case basis. To qualify for this exemption, a foreign government or its agency must ascertain (i) that the one making the investment (and therefore receiving the income) is a foreign government or an agency of a foreign government, (ii) that the moneys being invested are and will continue to be that government moneys; and (iii) that the income is realised from non-commercial activities. Income realised by a foreign government or by any other body implementing governmental functions from interest bearing investments or investments in equities is normally not considered to be income realised from a commercial operation or activity. In relation to a investment in shares of a company, a portfolio holding of ten percent or less of the equity in a company is normally accepted as a non-commercial activity and dividends earned from such investments are exempt from tax. Direct investments of real estate are not within the exemption; consequently, rental income earned from Australian real estate and gains from the sale of such real estate is not exempt from tax. The UK exemption for foreign governments is also conducted administratively. The UK Government has a policy, which says that where a SWF is an integral element of a foreign government it is going to benefit from the exemption from UK taxes. Since the UK acknowledges the principle of sovereign immunity in which one state does not attempt to tax the activities of another state, the present practice of the UK Government is to treat all passive income and gains constructively owned by a foreign government as immune from direct taxes17. Reciprocal exemptions. The second category incorporates governments that exempt foreign governments and their SWFs just to the same extent that the foreign governments extend a comparable exemption. The reciprocal exemption is achieved either domestically or through enclosure in bilateral double taxation treaties. Revenue Canada has released the following statement describing the exemption for foreign governments, including SWFs: “Under the Doctrine of Sovereign Immunity, the Government of Canada may grant exemption from tax on certain Canadian-source investment income paid or credited to the government or central bank of a foreign country. Written authorization not to withhold tax is given to the Canadian resident payer upon request after substantiation that such investment income (other than that already exempt under the Act and Regulations) is the property of the government or central bank of a foreign country”. The above statement means that investment proceeds of a foreign government or its agency is exempted in Canada only if the other country provides a reciprocal exemption to the Canadian Government or its agencies. The income is realised by the foreign government or its agency in the course of implementing a function of a governmental nature and is not income realised in the course of a commercial or an industrial activity carried on by the foreign authority; and it is interest on an arm's length debt or portfolio dividends on listed company shares. Income from rentals, royalties or direct dividends from a company in which the foreign government has a large or controlling equity interest does not qualify for exemptions. The bilateral tax treaty between Singapore and Malaysia (with effect from January 1, 2007) is a good example of a reciprocal exemption for governmental bodies. Article 11 of this tax treaty provides that the withholding tax on interest paid to non-residents should not surpass 10 percent. Paragraphs 3 and 4 of Article 11 also provide that Singaporean source interest paid to the Malaysian Government, the governments of the Malaysian states, local authorities, Bank Negara Malaysia, statutory bodies and the Export-Import Bank of Malaysia Berhad is exempt from taxation in Singapore18. Malaysian source interest paid to the Singaporean Government, the Government of Singapore Investment Corporation PTE. Ltd, the Monetary Authority of Singapore, and Singaporean statutory bodies is exempt from taxation in Malaysia19. Among countries with main government investment funds, including SWFs, reciprocal exemptions by bilateral tax treaties seem common. The bilateral tax treaties between Singapore and Japan (with effect from January 1, 1996) and Russia and Norway, and for example, have reciprocal exemptions for interest given to foreign governments, regional and local authorities and their government associated agencies20. Even though United States provides a unilateral tax exemption for foreign governments and their agencies, it has received exemptions for its government funds, including sub national SWFs, like the Alaska Permanent Fund, and sub national government investment funds that are not SWFs, like CalPERS and SWIB. The latest amendment (May 2, 2006) to the US bilateral tax treaty with Denmark offers for reciprocal exemptions for dividends, whereas the original treaty offers a general exemption for interest paid to residents of the other country. The US tax treaties with Switzerland and the Netherlands also offers limited exemptions for pension funds, including government owned pension funds like CalPERS and SWIB21. No special exemptions. In the third group are countries that have no any special provisions for SWFs and other government owned and controlled entities. Seemingly, the dominant policy supporting this category is the impression of taxpayer equity. Under this policy, given that all foreign investors, irrespective of their ownership or the source of their funds, get benefits from the host country’s infrastructure and the investment opportunities it provides, they all should be subject to the same level of taxation. Germany is one example of such countries that have no special provisions for foreign governments, including SWFs. The consequence is that foreign governments and their SWFs are taxed in the similar fashion as foreign companies investing in Germany. The lack of any special tax preferences is softened, however, by the generally gentle tax system relevant to foreign investors. In Germany’s domestic tax laws, foreign investors’ interest income and capital gains from shares are usually exempt from tax. Additionally, foreign corporations, together with foreign governments and SWFs, are not taxed on ninety five percent of the dividends they obtain from German corporations. The result is that all foreign investors in German in reality pay little tax on their passive investments so the nonexistence of special tax benefits for foreign governments and SWFs is not very remarkable. On the other hand, New Zealand, Taiwan, and South Korea do have considerable withholding taxes charged on outbound remittances of passive income and they emerge to have no any special tax preferences for foreign governments, including SWFs. The reason might be that if the markets for global capital happen to tighter these governments will experience pressure to provide some tax preferences to large government investment funds, including SWFs22. Conclusions Governments’ attitudes towards SWFs definitely are not uniform. Some countries, such as Singapore and China, are saturated with capital and may feel little pressure to unilaterally give special tax preferences to SWFs and other government owned and controlled investment funds. On the other hand, as the home to a number of the chief SWFs, these countries are in particular the ones that are likely to be concerned on the tax treatment of their SWFs in other countries. This implies that for such countries, a policy that offers tax preferences on a reciprocal basis would be more attractive. It does also emerge that the United States, with its unilateral exemption, is excessively generous. The reason might be that the American need for capital inflows currently is so immense that the United States cannot endanger continuing investments from the Middle Eastern or Asian based SWFs. However, the existing system puts the many American based SWFs as well as other national and sub national government owned and controlled funds at a negotiating difficulty as they look for tax preferences in other countries. If the other countries do not grant tax preferences, as Norway, South Korea, Taiwan, and New Zealand do not, the United States unilateral exemptions for foreign governments and their SWFs create no inducement for those countries to offer tax preferences equivalent to the exemptions available in the United States23. Therefore, it is as if the United States also should think about moving away from its unilateral exemption towards exemptions offered on a reciprocal basis. The reciprocity could either be through a change in domestic law, such as what was in Canada, or through the negotiation of tax treaties, as Russia, Singapore, Norway and Malaysia have done. The great problem with the tax treaty approach is that the snail pace of treaty negotiations means that our grandchildren will be already into their professional careers before the change in policies begins to become effective. On the other hand, providing reciprocal exemptions by bilateral tax treaties may promote the negotiation of tax treaties between the United States and many of the states in the Middle East. From a tax policy perspective, the most rational approach is possibly the third category i.e. not to offer any special tax preferences for foreign governments and their SWFs. Actually; a good case could be taxing all foreign investors, including large charitable organizations, on the same basis. The competition for foreign government investments, incorporating SWFs, is likely to increase, however, as potential host governments come to recognize that the great predominance of these investments are long term and established. It may be that competitive pressures will compel the Taiwanese, New Zealand and South Korean governments to agree to a more attractive tax system for investments by foreign governments and their SWFs24. References Fleischer, V. “Taxing Sovereign Wealth Funds” 2008. [Online] available at: http://www.theconglomerate.org/2008/03/taxing-sovereig.html (Accessed: 29 April 2010). Focus: Bance de France, “Assessment and outlook for sovereign wealth funds” 2008. [Online] Available at: http://www.banque-france.fr/gb/publications/telechar/focus/focus_1.pdf (Accessed: 10 May 2010). Irish, C. R. “Income taxation of sovereign wealth funds” 2008. Wisconsin Madison: East Asian Legal Studies. Joint Committee on Taxation, Economic and U.S. “Income Tax Issues Raised by Sovereign Wealth Fund Investment in the United States” 2008. [Online] available at: http://www.jct.gov/x-49-08.pdf (Accessed: 14 May 2010). Kleinman, M. Griffiths, K. “Barclays lines up sovereign wealth funds for cash boost” 2008. [Online] available at: http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/2791261/Barclays-lines-up-sovereign-wealth-funds-for-cash-boost.html. (Accessed: 2 May 2010). Michael F.M. “ China’s Sovereign Wealth Fund” 2008. Washington. Foreign Affairs, Defense, and Trade Department. Sovereign Wealth Fund Institute, “ Current News” 2010. [Online] available at: http://www.swfinstitute.org/ (Accessed: 14 May 2010). Times online, “China's sovereign wealth funds set for global spending spree” 2008.[Online] Available at: http://business.timesonline.co.uk/tol/business/industry_sectors/banking_and_finance/article4186899.ece (Accessed: 7 May 2010) International Monetary Fund, Monetary and Capital Markets Policy Development and Review Departments, “Sovereign Wealth Funds” 2008. [Online] Available at: http:/www.imf.org/external/np/pp/eng/2008/022908.pdf (Accessed: 15 May 2010). PWC, “Taxation of Sovereign Wealth Funds in Japan” 2008. [Online] Available at: http://www.pwc.com/en_JP/jp/taxnewsfinancialservices/assets/Sovereign_Wealth_Funds_E.pdf (Accessed: 15 May 2010). Michael F.M. “ China’s Sovereign Wealth Fund” 2008. Washington. Foreign Affairs, Defense, and Trade Department. find itwww.fas.org/sgp/crs/row/RL34620.pdf 2.Irish, C. R. “Income taxation of sovereign wealth funds” 2008. Wisconsin Madison: East Asian Legal Studies. http://www.google.co.ke/#hl=en&source=hp&q=2.Irish%2C+C.+R.+%E2%80%9CIncome+taxation+of+sovereign+wealth+funds%E2%80%9D+2008.+Wisconsin+Madison%3A+East+Asian+Legal+Studies.&btnG=Google+Search&aq=f&aqi=&aql=&oq=&gs_rfai=&fp=50dd7b1a7abb665c Read More