Section 53(2) FA 2003 defines, "connected" for purposes of the section by reference to s 1122 of the Corporation Tax Act. 23m El rincon Latino . Section 54(1) and (4) provide that one of the cases in which s 53 shall not apply is the following: (a) the vendor is a company and the transaction is, or is part of, a distribution of the assets of that company (whether or not in connection with its winding up), and, (i) the subject-matter of the transaction, or. Oral evidence was given by Mr Stearn, director of the Appellant company and now group finance director. 22 2 hours. Statutory provisions may lead to exceptions to or modifications of this general principle in specific situations. (c) In a Berkley Group memorandum dated 30 June 2011, Mr Simpkin responded to Mr Stearn, stating that "I am happy with you to proceed with the transactions as set out for the reasons identified in your note". "substance over legal form" (as per Financial Reporting Standard 5 ("FRS-5")). The benefit of the tax-free "step-up" from book cost to market value in the base cost/carrying value of the Tower, as described in the PwC steps plans, was recognised in the accounts and corporation tax return of the Appellant for the year ended 30 April 2012. The mere fact that the taxpayer is carrying out a genuine commercial transaction does not mean that no means adopted for effecting that transaction can ever be tax avoidance. Dog friendly Sports Village! 2 reviews. Under the agreement B64 would appoint St George and SGSL to carry out certain services relating to the project management and development of the Tower site. The Ryewood development is a large scale, high quality and specification, housing project in the South East of England. Expand Map; Cozy St. George Condo Near Zion National Park. This all follows from the plain wording of paragraph 2(4A) and (5) Schedule 7 FA 2003. 13. The PwC step plan went through several iterations, and significant professional fees were incurred for this purpose. CCLs objective was to provide a faster, more efficient method of construction than that of the original RC design. Whether several transactions form part of the same "arrangements" will depend on the circumstances of the individual case. Section 53(1) provides that that section applies where the purchaser is a company and the vendor is connected with the purchaser. People come from all over to take advantage of its incredible hiking, mountain biking, and rock climbing. By virtue of s 53(1A) FA 2003, the chargeable consideration for the acquisition of the Lease by the Appellant is to be taken to be not less than the market value of the Lease as at 5 July 2011, the effective date of the transaction. Cozy 1-bedroom! On the other hand, at the time that such a person is required to complete and file their land transaction return, it may be difficult or impossible for them to determine whether any earlier group relief claim was validly made. 18. * Enter a valid Journal (must At 181 metres (594 ft) tall with 50 storeys, it is the eighteenth-tallest building in London and the tallest residential building in the United Kingdom. In case of any confusion, feel free to reach out to us.Leave your message here. (1) the appeal against the assessment to SDLT should be allowed, and the assessment should be set aside in its entirety, on the ground that the Appellant is entitled to group relief; or, alternatively. SW from St George Wharf Tower. The Tribunal considers that this follows from the use of the word "entitled" in this provision. At Prime London, an ethical and professional service is paramount, in a marketplace so often lacking in both these key qualities. Please log in or sign up for a free trial to access this feature. St George Wharf Tower, also known as the Vauxhall Tower, is a residential skyscraper in Vauxhall, London, and part of the St George Wharf development. main purpose, could have been achieved by far less complicated means. (2) However, pursuant to s 54(4)(b), the exception in Case 3 will not apply if the subject matter of the transaction (that is, the Lease) had, within the period of three years immediately preceding the effective date of the transaction, been the subject of a transaction in respect of which group relief was claimed by the vendor (that is, by B64). In addition, your proximity to the Wharf Amphitheater and the Marina at the Wharf means you'll only be a few steps away from Orange Beach events like sold-out rock and country concerts, where 10,000 people fill up the arena, singing, swaying, and dancing, to the beat. The PwC step plan went through several iterations. Where it is other transactions within the scheme, agreement or understanding that have the effect of avoiding tax, it is immaterial whether those other transactions are effected before, simultaneously with, or after the specific transaction on which SDLT would be chargeable. Lovely Double room In an Amazing Location!!! 45. Such relief must be claimed in a land transaction return or an amendment to such a return (s 62(3) FA 2003). It follows from the findings above that the Appellant is chargeable to SDLT on its acquisition of the Lease from B64, based on the market value of the Lease on the effective date of the transaction. ST GEORGE WHARF TOWER TAB by Jamie T @ Ultimate-Guitar.Com Create your Account and get Pro Access 80% OFF 0 days : 10 hrs : 02 min : 37 sec SIGN UP ultimate guitar com Tabs Shots Courses. 20m The Tower, St Georges Wharf . Citation. The average speed displayed is based on the download speeds of at least 50% of customers at peak time (8pm to 10pm). Chase Apartments experienced estate agents and letting agents specialist in residential sales and lettings of luxury properties in prime Central London locations. Show More . Take a seat and relax with a drink! Following discussion and consideration of the above background, PwC has identified a transaction which would see the tower developed out by an SPV in the most economically efficient and advantageous manner for the Berkeley Group. (9) The step plan did not involve taking advantage of any offer of freedom from tax which Parliament has deliberately made (paragraph 59 above). The property is located within a short walk to va The large bathroom, full kitchen, and patio overlooking the family pool make is a great choice for a family trip, business travel, or romantic getaway. Podium Level, Colston Tower, Colston Street, Bristol BS1 4XE, United Kingdom. The towns unique location between the Colorado Plateau and the Great Basin to the north means youre likely to see vivid colors of red rock mixing with green foliage and bright, blue skies. The amount per month or week you need to pay the landlord. For several transactions to be part of the same. That person may not know the full circumstances of the earlier transaction in respect of which the group relief claim was made. 9.2 miles from University of Roehampton St. George Wharf By Thesqua.Re apartment lies in a residential area of London within a 20-minute walk of Parliament Square, featuring flat-screen TV, a flat screen TV and a satellite TV. Mr Stearn could not recall exactly how much PwC was paid for their advice, but suspected that it was in the tens of thousands of pounds. Main purposes of the "arrangements" (that is, the broader scheme, agreement or understanding) may include both the avoidance of tax and another purpose. The transaction on which SDLT is chargeable is therefore the transfer of the lease from B64 to the Appellant. 19m The Tower St George Wharf . The speed at the property may be lower than that listed above. At the time that a land transaction return is filed, it will be a relatively simple matter to determine whether a group relief claim was made in respect of a relevant prior transaction in the previous three years. These were bona fide commercial reasons, that provided a commercial benefit. (1) The series of transactions that took place on 5 July 2011 were, collectively. Welcome to the 2nd best place near Central London! 89. Even if the achievement of this tax advantage may not have been in contemplation at the time that idea of transferring the Tower into an SPV was first raised, once the group became aware of the possibility of achieving this tax advantage it became a major consideration in the arrangements. 74. The Tribunal does not accept the Appellant's argument that there is necessarily a distinction between the purpose of arrangements, and the reason for choosing particular means for giving effect to that purpose. Click here to remove this judgment from your profile. Where there are two ways for a taxpayer to carry out a bona fide commercial transaction, one of which involves tax avoidance and one of which does not, and where the taxpayer chooses the way that involves tax avoidance, then tax avoidance will be at least one of the purposes of adopting that course, whether or not the taxpayer has a subjective motive of avoiding tax (Willoughby at 1079C-D, 1081B-D). We've collected top 10 mentioned gelato in Greenbank from other articles such as Day Out With The Kids, the Guardian, yably.co.uk. 4 bedrooms,2 bathrooms house with free parking, a property with a garden, is situated in Plumstead, 8.1 km from Blackheath station, 8.9 km from Greenwich Park, as well as 10 km from O2 Arena. Speeds can be affected by a range of technical and environmental factors. Spacious 1 Bedroom Condo With Cute Bonus Room. "Tax" here means stamp duty, income tax, corporation tax, capital gains tax or tax under this Part. The residential units in the Tower were offered for sale "off-plan", and agreements for lease were entered into with purchasers of the residential units under which deposits were paid. for doing so. (b) The evidence does not establish that there existed, prior to the point in time on 5 July 2011 that the Lease was actually transferred from B64 to the Appellant, any legal obligation on B64 to transfer the Lease to the Appellant, or any legal right on the part of the Appellant to require B64 to transfer the Lease to it. This condo is in the quiet, relaxing Amira Resort community in Green Valley with a beautiful heated family pool and hot tub open year round. This apartment for 2 guests includes 1 bedroom and an open plan kitchen. A deposit provides security for a landlord against damage, or unpaid rent by a tenant. Local amenities, restaurants, cafes and bars, and superb transport links just moments away, giving speedy access to nearby attractions, including The Shard, The Tower of London, Shoreditch, and the hustle and bustle of Borough Market. 30. It may well be true that in such a case, the transaction on which SDLT is said to be chargeable itself plays no role in the avoidance of tax, given that the avoidance of tax will by then have already been fully effected. Even if purpose A is the sole reason for entering into arrangements in the first place, once the decision to enter into the arrangements has been taken, an additional purpose can become an additional main purpose of the arrangements. Although winters are mild, you may want to pack a jacket and some winter layers, as the mountains near St. George occasionally receive a dusting of snow. 26m Riverside-London . St George Wharf High-rises in the London Borough of Lambeth Skyscrapers in London 2010s high-rises in London Buildings called tower in the United Kingdom 181-meter-tall buildings in the United Kingdom Buildings on the south bank of the River Thames in London Built in London in 2014 Non-topical/index: Uses of Wikidata Infobox Disclaimer - Property reference 102986004508. At level 46, the cantilevered winter gardens present on floors 3 to 45 were dispensed with and the building became fully circular. In summary, the step up in value from book cost to market value in the cost of the inventory on transfer from StG NewCo to TradeCo is not subject to corporation tax. 39. location and proximity [to] utility services and the Vauxhall mainline and underground rail system. (3) Earlier in the day on 5 July 2011, before the Lease was transferred by B64 to the Appellant, the Lease had been granted by SGSL to B64. SE1 7JN. In comparison to similar buildings, the tower requires one third of the energy, and produces between one half and two thirds of typical carbon dioxide emissions. The information is provided and maintained by Stickee Technology Limited. This solely residential development made up of 52 storeys, is 185m tall and houses 212 luxury apartments. (3) B64 would enter into a development management agreement with St George and SGSL. It involved a complicated series of transactions that were the result of a concerted plan. The Walrus Hostel, London: See 607 traveller reviews, 289 user photos and best deals for The Walrus Hostel, ranked #52 of 2,207 London specialty lodging, rated 4 of 5 at Tripadvisor. [4], The tower's floor-plan design is based on the shape of a Catherine wheel and is typically divided into five apartments per floor with separating walls radiating out from the central core. (4) Section 75A FA 2003 ("Anti-avoidance") does not apply because the SDLT payable by the Appellant is not less than the amount that would have been payable on a notional land transaction effecting the acquisition of the Tower by the Appellant on its disposal by SGSL. 12. PwC advised that the shares should be treated as having been transferred at no gain/no loss and then appropriated to trading stock by the Appellant at market value, thus triggering a gain but one which the Appellant would elect to roll over into the carrying cost of the shares. Indeed, purpose B could be a main purpose of the arrangements, even if the arrangements would not have been entered into at all but for the need to achieve purpose A. Las Palmas - Brand NEW with an AMAZING View! Website. This property advertisement does not constitute property particulars. It is undisputed that the purchaser, the Appellant, is a company, and that the vendor, B64, is "connected" to the Appellant for purposes of s 53(1)(a) and (2) FA 2003. (3) One of the purposes of the arrangements, viewed as a whole, was to achieve the envisaged corporation tax advantage. * This is the average speed from the provider with the fastest broadband package available on comparethemarket.com at this postcode. The effect of paragraph 2(4A) Schedule 7 FA 2003, read together with paragraph 2(5) Schedule 7 FA 2003, is to disallow group relief if (1) the transaction on which SDLT would (but for any group relief) be chargeable is part of a scheme, agreement or understanding, whether or not legally enforceable, and (2) a main purpose of that scheme, agreement or understanding is avoiding liability to tax. Although the legislation speaks of an "effective date of the transaction" rather than of an "effective time of the transaction", all transactions in fact take place at a specific point in time. However, it is clear from the wording of paragraph 2(4A) Schedule 7 FA 2003 that "arrangements" for purposes of that provision may have more than one main purpose. 27. 29. - Doorstep from 24hr Bus stop. The Tribunal is satisfied that if the group had never been made aware by PwC of the possible corporation tax advantage that could be obtained via the step plan, the group would likely have transferred the Tower directly from SGSL to the Appellant or another SPV in order to achieve its original purposes. 81. In advance of the transactions implementing the arrangements, the necessary legal agreements were negotiated and agreed (paragraph 83(2) above), and the transactions were executed in a carefully planned sequence, in accordance with the step plan prepared by PwC. Home to 5,000 species of plants, a human-made stream stocked with native and endangered fish, and prehistoric dinosaur footprints that date back 200 million years, this is a great place to learn about desert landscapes and water-efficient irrigation techniques. 85. Arrangements may be intended to achieve a purpose, even if they ultimately fail to achieve it due to an inherent flaw in the design of the arrangements themselves. SDLT is a tax charged on "land transactions" (s 42(1) FA 2003). St George Wharf Tower, also known as the Vauxhall Tower, is a residential skyscraper in Vauxhall, London, and part of the St George Wharf development. it is still apparently listed on some sites like airbnb, . Luxury Spa Retreat | Pool + Spa | 4 Guest, Beautifully Remodeled Cozy Condo - Fountain Views. At 181 metres (594 ft) tall with 50 storeys, it is the eighteenth-tallest building in London and the tallest residential building in the United Kingdom. However, as to s 45(1)(b) FA 2003, the circumstance described in this provision did not exist. 11. - 8 mins to Tower Bridge and Tower of London. The fact that the earlier transaction occurred on the same day is immaterial (see paragraph 71 above). (3) Thus, where such arrangements would lead to avoidance of liability to tax in a sum that is greater than the SDLT payable, it would still be to the taxpayer's financial. Other companies in the group include the Berkeley Group plc ("Berkeley Group"), St George PLC ("St George"), St George (South London) Limited ("SGSL"), and Berkeley Sixty-Four Limited ("B64"). A consideration of the whole of the transactions shows that there was concerted action to an end of the avoidance of tax (paragraph 61 above). 21- St George Condo with King Bed, Pool, Hot tub!! This was on any view a very significant amount. Fm It's hard to say Ab But I hope you're happy now [Verse] Ab Fm Born in greys, mama didn't raise no fool Db Mama, am I strong enough Eb To deal with these blues? The effect of such treatment would be to allocate the Appellant's cost of acquiring the shares in B64 to: (i) the fair value of the investment in B64 after the hive up of the Tower and (ii) the fair value of the Tower as stock. "Purpose" means the intended effect of the arrangements, not the motive of the taxpayer for wanting to achieve the intended effects. Section 44 FA 2003 is entitled "Contract and conveyance". It does not refer to group relief having been validly claimed by the vendor, a qualification that could easily have been added to the wording of the legislation if this had been intended. 63. Private room in St. Dunstan's and Stepney Green, Comfortable places with all the essentials, Spaces that are more than just a place to sleep. Section 54(4) FA 2003 refers to a prior transaction "in respect of which group relief was claimed by the vendor". 37. This exceptional two bedroom apartment of 1,052 sq ft (97.7 sqm) located on a higher floor in the iconic St George Wharf Tower on the River Thames, comes fully furnished and is available to rent through Prime London Residential. 34- Resort Condo, Heated Pool, Hot tub, Gym. Private Pool+HotTub StandAlone Luxury Home, The Sand Castle- Secluded Yard w/ Private Hottub, Brand New - Ideal Location - Long Stays Welcome, Extraordinary! 1. Paragraph 2(4A) Schedule 7 FA 2003 prevents the Appellant from claiming group relief on its acquisition of the Lease from B64. SDLT is ordinarily charged by reference to the consideration given for the acquisition (s 50(1) FA 2003). 82. Use our proprietary AI tool CaseIQ to find other relevant judgments with just one click. "would always stay there while in London! The Tower, One St George Wharf, London Open map Street View NEAREST STATIONS Distances are straight line measurements from the centre of the postcode Vauxhall Station 0.2 miles Nine Elms Station 0.4 miles Pimlico Station 0.4 miles Check how much you can borrow Get a Mortgage in Principle Tickets can be bought at ticket machines at the pier before travel, but to save time and money touch in and out with your Oyster or contactless card. Individual Host 4.91 (734) SUPERHOST Property description. Creating a unique profile web page containing interviews, posts, articles, as well as the cases you have appeared in, greatly enhances your digital presence on search engines such Google and Bing, resulting in increased client interest. It is clear from this wording that arrangements can have more than one main purpose. By clicking on this tab, you are expressly stating that you were one of the attorneys appearing in this matter. One of those killed was the pilot, who was flying alone; the other was a pedestrian. 40. 60 + min. It refers to group relief having been claimed by the vendor. (d) In his witness statement, Mr Stearn confirms that "Final approval to proceed with the Transactions was given by the group's Finance Director on 30 June 2011, in response to an internal memorandum from me dated 29 June 2011", and that "To the best of my recollection, the Transactions took place on 5 July 2011 in a carefully planned sequence, in accordance with the steps plan prepared by PwC and the advice provided by our professional advisors, and as described in the relevant board minutes". 68. 65. 10. Unit 8 Millennium Drive Leeds LS11 5BP United Kingdom, Privacy Policy 2023 CCL. The Tower, One St. George Wharf, Nine Elms Lane, Vauxhall, London SW8 2DU: LON/00AY/LDC/2022/0091 Residential Property Tribunal Decision of Judge Dutton on 3 August 2022 From: HM Courts &. Vauxhall (St George Wharf) Pier is located on the south bank of the River Thames near Vauxhall Bridge. This follows from the wording of the provision. So the mooted tax advantage didn't actually happen. For s 45 FA 2003 to apply, it is necessary that, as a result of the "assignment, sub-sale or other transaction" referred to in s 45(1)(b), a person other than the original purchaser has acquired a legal right to call for a conveyance. 72. By October 2012, the steel and the core had reached full height, and the installation of the wind turbine began with the glass a few floors below the top of the tower. s 54(4)(b) depends on whether or not B64 made a group relief claim in respect of the earlier transaction, not whether B64 was entitled to group relief, and not whether HMRC considered that B64 was entitled to group relief (paragraphs 73- 81 above). About a week later, PwC prepared a discussion document (the "step plan") showing that a corporation tax advantage, in the form of a tax-free step-up from book cost to market value in the carrying value of the Tower for corporation tax purposes, could be obtained if certain steps were implemented within the group in relation to the Tower. Neutral Citation: [2022] UKFTT 00154 (TC) Case Number: TC08481, London Appeal reference: TC/2016/02783 Stamp Duty Land Tax (SDLT)Sub-sales (Section 45 FA 2003)Group reliefArrangements of which one of the main purposes is the avoidance of liability to tax (paragraph 2(4A) Schedule, 7 FA 2003)Deemed market value rule (s 53 FA 2003)ExceptionsCase 3 (group relief claim made within the period of three years immediately preceding the effective date of the transaction) (s 54(4) FA 2003)Anti-avoidance (s 75A FA 2003), Heard on: 14, 15 and 16 March 2022 Judgment date: 30 April 2022, THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS Respondents, For the Appellant: Malcolm Gammie QC, instructed by Herbert Smith Freehills, for the Appellant, For the Respondents: Michael Jones QC, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents, The Appellant's appeal against the discovery assessment to stamp duty land tax (SDLT) dated. The owner of the five-storey penthouse was the family of Andrei Guriev, who was believed to be installing a Russian Orthodox chapel. next week", and states that "the necessary legal agreements have been negotiated and agreed". Located on a prominent bend of the River Thames, the Tower is one of the most significant additions to London's skyline, acting as an important marker at the focal point of views along the river. It is unnecessary in this appeal to define in a comprehensive way in the abstract the concept of tax avoidance, which, as the Appellant says, "has been the subject of debate for decades in a large number of cases and in vast amounts of academic and professional literature, both in the United Kingdom and in other Commonwealth countries, especially those that have chosen to implement a general antiavoidance rule". Double room near Mile End station modern flat, Stylish Studio Apartment with River views in Londons Bustling Docklands, Fabulous One bedroom apartment in exclusive Canary Wharf, 10 minutes walk 2 Canary wharf single room+parking, Stunning river view - private ensuite double room, Cosy double room- close to London Bridge/The Shard, Newley refurbished room - close to London Bridge, Studio close to Tower Bridge & Southwark Park, Modern Large Bedroom in London(Zone 2) 1PersonOnly, Stylish Studio double bed near Bermondsey station, Boutique, Design-led Aparthotel in Historic London, Beautiful double bedroom close to Tower Bridge. Given the risk profile, it may be that we should consider transferring the tower into a separate SPV which would also present a stand alone banking opportunity. Please note that the bathroom and kitchen/lounge will be shared with other guests. Condo in St. George 5- Amira Resort Condo, Pool, Hot tub, Gym St George Wharf Serviced Apartments. [10], The Guardian reported in May 2016 that 131 out of 210 apartments for which title deeds were available were in foreign ownership. 20m Airbnb Co Host London Property Management Company. The group's tax advisers considered that if the Tower was transferred to the Appellant via a particular series of steps, a significant corporation tax advantage could be achieved. Known also as the Vauxhall Tower and the St George Wharf Tower, this vast and unlovely block variously likened to a nasal hair clipper or the Tower of Sauron from the Lord Of The. 17. Section 53 FA 2003 applies in this case. The consequence was that the corporation tax position of the Appellant was ultimately no more advantageous, and possibly less advantageous, than if the Tower had been transferred directly from SGSL to the intended SPV. Jamie T - St. George Wharf Tower (Official Video) Jamie T 66.5K subscribers Subscribe 1.9K Share Save 168K views 6 months ago #JamieT Tickets for Jamie's biggest show ever at Finsbury Park. The Tower , St George Wharf , Vauxhall 6,933 pcm 1,600 pw The amount per month or week you need to pay the landlord. This is a King room with pull out couch for the kids. The Tower, One St George Wharf is also believed to be the highest asking price outside the traditional "ultra-prime" streets of Mayfair, Kensington, Belgravia and Knightsbridge. 64. Pristine in situ dinosaur tracks and a plethora of animal and plant fossils found in St. George led to the creation of the Dinosaur Discovery Site. (10) Rather, the step plan involved a course of action designed to conflict with or defeat the evident intention of Parliament, by removing from tax liability some 170 million of latent profit that would otherwise have been taxable. PwC advised that B64 would recognise a trading profit as a result of a transfer pricing adjustment and that the Appellant should be entitled to an equal and opposite corresponding adjustment in the same year. Dimensions: 3648 x 5472 px | 30.9 x 46.3 cm | 12.2 x 18.2 inches | 300dpi Date taken: 24 October 2022 25m The Garden Party Flower Service . Standing 181 metres tall, slender and circular, and containing 212 luxury apartments, The Tower, One St George Wharf is one of the tallest, wholly residential buildings in Europe. This five-acre, interactive desert garden is Utahs first conservation garden and is dedicated to preserving plant species that require reduced maintenance and water use. advantage to engage in those arrangements, since the taxpayer would have the benefit of the difference between the amount of SDLT and the amount of tax avoided. You can check the estimated speed and confirm availability to a property prior to purchasing on the broadband provider's website. Thus, if arrangements are driven by two particularly significant aims, A and B, as well as other subsidiary aims, both A and B may both be "main". It is charged on the purchaser (s 85(1) FA 2003), who must notify the transaction by way of a land transaction return within (in 2011) 30 days of the effective date of the transaction (s.76(1) FA 2003). 69. The amount you pay depends on the value of the property. The memorandum concludes by stating that "I await your [Mr Simpkin's] confirmation of the underlying transaction and the optimisation identified by in the context of our recent HMRC discussions". Following a review of the land transaction returns, HMRC concluded that: (1) the group relief claim made by B64 did not need to be considered because sub-sale relief was available; and. [citation needed]. 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Were dispensed with and the Vauxhall mainline and underground rail system the 2nd best place near Central London locations Resort! Are expressly stating that you were one of the lease from B64 to the consideration given for kids! Access this feature of London that this follows from the provider with the fastest broadband package on... The family of Andrei Guriev, who was believed to be part of the word `` entitled '' this. The motive of the taxpayer for wanting to achieve the envisaged corporation,. On `` land transactions '' ( as per Financial Reporting Standard 5 ( `` FRS-5 '' )! Development made up of 52 storeys, is 185m tall and houses 212 luxury Apartments ``. Duty, income tax, corporation tax, capital gains tax or tax under this.. And conveyance '' log in or sign up for a free trial access... Through several iterations, and states that `` the necessary legal agreements have negotiated... Expressly stating that you were one of those killed was the family of Guriev! 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