This includes US corporate subsidiaries of foreign-based multinationals. Finally, assume that the foreign group member, because of the agency activities performed by the related U.S. group members on the foreign group member’s behalf, has met the above-mentioned threshold test of being engaged in a trade or business within the United States. To report the income from the taxpayer’s Form 1042-S as effectively connected income, mark this field and report the income on the appropriate input screen. Found inside – Page 57The entire $ 100,000 is " subpart F income ” which would without this provision be treated as effectively connected for the taxable year with the conduct of ... Gross income is then reduced by subtracting deductions allocable … The group personnel in the United States primarily performed the extensive work to create the group’s online presence, including design, software architecture, and coding, under a cost-sharing agreement that spread the costs among various group members, including the foreign group member. As for the second question, the answer generally will be “yes” where a foreign corporation’s U.S. office actively participates in solicitation, negotiation, or performance of other significant services necessary for the consummation of a sale. Found inside – Page 64... the branch's effectively connected earnings and profits, or ECE&P). ... that are qualified residents of countries having an income tax treaty with the ... Business Activities Test – The activities of that trade or business conducted in the United States are a material factor in the realization of the income. For example, California,13 New York,14 and Pennsylvania15 each adopt the treaty approach and only tax income that is effectively connected with a U.S. trade or business, without regard to whether the company has a PE in the United States. For example, an NRA landlord of a US Property who elects to treat the income as ECI instead of the default FDAP (Fixed, Determinable, Annual and Periodic), can claim deductions associated with the income. Internal Revenue Code section 897, as enacted by FIRPTA, [4] treats the gain on a disposition of an … We have excellent - Facility, Database & Network. Nonresident aliens with limited business activities in the U.S., who generally do not believe that they had any gross income effectively connected with a U.S. trade or business during the year, can file a protective return (Form 1040-NR) by the due date described below. Regarding the third question, where the foreign group member is making sales of inventory property for use, disposition, or consumption inside the United States, then all such income will be U.S.-source and therefore ECI. If the answer to every question is yes, the income will be U.S.-source and taxable as ECI: 1. You usually are considered to be engaged in a U.S. trade or business when you perform personal services in the United States. © Association of International Certified Professional Accountants. taxable under graduated corporate tax rates on its income effectively connected with the conduct of a trade or business withi n the U.S. IRC Section 864 covers the types of gross income that are treated as effectively connected with the conduct of a U.S. trade or business. In conclusion, when a foreign nonresident has U.S. sourced income, they may have either FDAP or ECI — or both. These exceptions from gross income include Subpart F income, effectively connected income, income excluded by the high-tax exception, dividends received from certain related parties, and several other items. Does the foreign corporation have income from any sale of personal property (including inventory property) attributable to that U.S. office (see Secs. Sec. Not Effectively Connected income will usually include all FDAP (Fixed, Determinable, Annual, or Periodic) income that came from a US trade or business that is not effectively connected. With 2021 marking the 100th anniversary of the first Black licensed CPA in the United States, a yearlong campaign kicked off to recognize the nation’s Black CPAs and encourage greater progress in diversity, inclusion, and equity in the CPA profession. Under the first regime, a foreign corporation engaged in trade or business within the United States during the taxable year is taxable on its income which is effectively connected with the conduct of such trade or business within the United States (effectively connected income). Making the right moves now can help you mitigate any surprises heading into 2022. Like … In contrast to FDAP income, the foreigner is allowed to deduct the expenses incurred in generating its effectively connected income, and that net income is taxed at graduated rates. We advise most of … Whether a foreigner is engaged in a USTB depends upon the nature and extent of the foreigner’s activities within the U.S. For example, assume the foreign group member earns services income in the form of fees and commissions from: To determine the source of this services income, it is necessary to ask where the foreign group member has performed these services. Found inside – Page 474The following examples through ( c ) ( 4 ) of this section . ... Bank X for certain effectively connected income this section expires on January 16 ... 1446 on any foreign partners’ share of effectively connected taxable income from such business. Effectively Connected Gross Income To compute the taxable effectively connected income of a foreign corporation engaged in a U.S. trade or business, the first step is to identify the gross income that gives rise to effectively connected net income. Profit Shifting: Effectively Connected Income and Financial Statement Risks. 1.954-3(a)(4)(iv)(b)) that will allow a company to be considered a manufacturer when it uses a contract manufacturer for the physical manufacturing: Where an IRS examination determines that any related U.S. group member performs these functions as an agent for the foreign group member, the IRS may reasonably conclude that the foreign group member is manufacturing inventory property in the United States. For example, both U.S. citizens and resident aliens are required to have income taxes withheld from each paycheck. An election for income derived from real property to be taxed on a net basis is available in most U.S. tax treaties. 01 Effectively connected income 02 Exempt under IRC7 03 Income is not from U.S. sources 04 Exempt under tax treaty 05 Portfolio interest exempt under IRC 06 Qualified intermediary that assumes primary withholding responsibility This includes foreign corporations that are subsidiaries of U.S.-based multinational corporations. Effectively connected income (ECI) is when an NRA engages in a trade or business in the USA and earns income connected with the conduct of that trade or business. Found inside – Page 261This income ubject to 30 % withholding if it is not efvely connected with a U.S. ... or unless that income is effectively connected with a U.S. trade or ... This sidebar accompanies the article “Profit Shifting: Effectively Connected Income and Financial Statement Risks” in the February 2016 issue of the JofA. Determine what income earned or received is not effectively connected with a U.S. Trade or Business. income are treated as ECI income because: Certain Internal Revenue Code Sections require the income to be treated as ECI. I.R.C. Exea conse quat duis irurey dolor sed reprehen derit volupta velit cilum lorem incididunt labore sed magna exceptur aliqua. called “effectively connected income” or ECI). Permanent Establishments The taxes and special rules applicable to the ECI of a foreign group member are: The above 54.5% or 38.25% or higher rates that apply when a foreign group member is directly taxed compare very unfavorably with the maximum 35% corporate tax rate imposed when income is taxed within a U.S. corporation and the branch profits tax and the potential loss of deductions and credits are not applicable. Found inside – Page 16( 4 ) Example ( 1 ) ( RESERVED ] ( m ) Adjusted current earnings of ... ( i ) Effectively connected pre - adjustment alternative minimum taxable income . Non-effectively connected income also includes capital gains. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. This site uses cookies to store information on your computer. Once the foreign group member is engaged in a trade or business in the United States, certain defined business income will be treated as ECI, and the foreign group member will be directly taxable on this income in the United States. (The related U.S. group members may enter into their own contract manufacturing agreements with these same contract manufacturers and acquire the products directly from them for sale within the United States.). When a foreign group member is entitled to the benefits of a tax treaty that reduces the branch profits tax rate, then the above-calculated rate of 54.5% or higher will be lower. The related U.S. group members are neither a party to any of the foreign group member’s contract manufacturing agreements, nor do these related U.S. group members take title to any products produced by the contract manufacturers for sale to the foreign group member. klgates.com 6 The second category is income not connected with a trade or business conducted in the US, or non-effectively connected income (NECI). If a foreign group member is not engaged in a trade or business within the United States, there can be no ECI and no U.S. taxation. Customer satisfaction is an expectation that we have built in our markets and we are always looking for new ways to meet and exceed our customers' needs and expectations. Refer to Publication 519, U.S. Tax Guide for Aliens. Will that be sufficient to meet the material-participation requirement? We have clients in the United States and all around the world. Found inside – Page 576... and that are not income of a related foreign person effectively connected ... paragraph ( b ) may be illustrated by the following examples : Example 1. Law360, New York (September 11, 2015, 11:45 AM EDT) --. Found inside – Page 724... and that are not income of a related foreign person effectively connected ... paragraph ( b ) may be illustrated by the following examples : Example 1. On the other hand, where the foreign group member is making sales of inventory property for use, disposition, or consumption outside the United States, it is necessary to examine for each sale what part, if any, the foreign group member’s foreign office played in making the sale and whether that part is significant enough to satisfy the material-participation requirement. 01 Effectively connected income 02 Exempt under IRC7 03 Income is not from U.S. sources 04 Exempt under tax treaty 05 Portfolio interest exempt under IRC 06 Qualified intermediary that … India’s Solar Market to Recover Rapidly in 2021: IEA Report. Found inside – Page 558EXAMPLE 3 As indicated in previous examples , the proposed bill excludes from effectively connected income , foreign source ... Found inside – Page 262Examples included bond anticipation notes , project notes , Public ... and the tax on effectively connected income was called “ Tax from Section II . 865(e)(2) and (3) and 864(c)(5)(A))? 865(e)(2)(B) and 864(c)(3))? In contrast, income from a foreign nongrantor trust is generally taxed when distributed to U.S. beneficiaries, except to the extent U.S. source or effectively connected income is earned and retained by the trust, in which case the nongrantor trust would pay U.S. income tax for the year such income is earned. Gains and losses from the sale or exchange of U.S. real property interests (whether or not they are capital assets) are taxed as if you are engaged in a trade or business in the United States. (The statute remains open for a tax year, even though that same year may already be closed to further IRS assessment for related U.S. group members.). International Tax Attorney | IRS Offshore Voluntary Disclosure, “Generally, when a foreign person engages in a trade or business in the United States, all income from sources within the United States connected with the conduct of that trade or business is considered to be Effectively Connected Income (ECI). Effectively connected income (ECI) is when an NRA engages in a trade or business in the USA and earns income connected with the conduct of that trade or business. ECI is taxed based on various factors, and deductions can be claimed. This sidebar provides a brief explanation of the Internal Revenue Code’s effectively connected income (ECI) rules that may impose direct U.S. tax on certain income earned by any foreign corporation. Offering the complete renewable Energy Solution like Electronic Kart, Electric & Automation solutions, Process Automation, Home Automation, Field Instruments, Mechatronics. Found inside – Page 378United States income of $ 1,850 which is effectively connected with the ... of this section may be illustrated by the following examples : Example 1. Rarely, if ever, will a foreign group member directly conduct production activities within the United States in its own name. It is fair to say that the low-taxed foreign group members that are the subject of the accompanying JofA article seldom, if ever, conduct business in the United States through their own employees. Found inside – Page 27Topics This chapter discusses : • Income that is effectively connected with ... or Business Activities Connected Income Other examples of being engaged in a ... If you are a student or scholar with investment income, your trade or business in the United States is studying, teaching, or doing research. These decisions and activities, which are conducted on a regular and continuing basis, also go far beyond any normal shareholder oversight of a foreign subsidiary’s conduct of its own business. Example: Mathis and Carol Dubois are Argentinian citizens living in Argentina, and in December 2016, they purchased a rental property at Pike & Rose in North Bethesda. This quick guide walks you through the process of adding the Journal of Accountancy as a favorite news source in the News app from Apple. Found inside – Page 2940The benefit does not apply to any income from real property in respect of ... the dividends received from B are not effectively connected for 1967 with the ... For example, teams of personnel typically located within the United States will control and direct all contract manufacturers that are producing products that will be directly acquired by the foreign group member and one or more U.S. group members. ECI: Effectively Connected Income Tax. Refer to. Effectively Connected Income. Upon its enactment in March, the American Rescue Plan Act (ARPA) introduced many new tax changes, some of which retroactively affected 2020 returns. Found inside – Page 46-248[ Reserved ) . For further guidance , see entry in $ 1.884-1T ( e ) ( 5 ) Example 2 . ( f ) Effectively connected earnings and profits—( 1 ) In general . For example, investment income reported on a K-1 of a partnership you have an interest in could be classified as effectively connected income. Assume further that the foreign group member, through its disregarded entity (DRE) subsidiaries (see explanation below) maintains some local warehousing and customer support functions in various countries around the world. There is no specific withholding, so that the person can claim deductions and then file a tax return to report the income. However, sometimes U.S. group member employees conduct critically important functions for related foreign group members that may be sufficient to constitute manufacturing. Where a foreign group member has met the test of being engaged in a trade or business within the United States, all of certain types of income, including production income, to the extent they are U.S.-source, will be ECI subject to tax. A new generation organisation with strong belief on "Customer First" approach and expertise on Pole/Tower Infrastructure Hybrid Chiller Cooler, Tyre Pressure Monitoring Systems E-Kart, SPV, Electrical & Automation domain., headed by the team of professionals with experience of over 15 years across various communication industry and industrial verticals. (a) Scope. The group of which the foreign group member is a part maintains an extensive online presence through which it provides cloud application services to paying customers and earns commissions from the sale or rental of third-party-owned digital products including applications, music, movies, books, etc. Found inside – Page 44227Income from sources without following examples : residents of the United ... or busicome from sources without the United effectively connected income . Generally, you can receive effectively connected income only if you are a nonresident alien engaged in a trade or business in the United States during the tax year. Foreign persons, however, are not taxed on most capital gains . as being engaged in a U.S. trade or business and will be subject to U.S. income taxation at regular U.S. tax rates on any income of the fund that is effectively connected with the conduct of a U.S. trade or business. The IRS added this recognition of contract manufacturing business models to the regulations within the past decade to modernize them and take into account what has now become a common business model. By using the site, you consent to the placement of these cookies. Effectively Connected Income: A Close Look At The Rules. Assume that a foreign group member earns sales income from purchasing and selling products. In addition, a treaty may reduce or eliminate the tax. Not effectively connected, unless from asset or produced by U.S. trade/ business. A new generation organisation with strong belief on "Customer First" approach. Cloud services performed for customers in its market area; The sale or rental of third-party digital products to purchasers in its market area; and. Assume that a foreign group member earns services income from an internet-based business. Although this latter one-half would escape ECI treatment, for any foreign group member that is also a CFC under the Subpart F rules, the manufacturing branch rule described in Regs. A. Under the Treaty, a “permanent establishment” includes a fixed place of business (i.e., office) through which one … How Green Is India’s Stimulus for Economic Recovery? In brief, if the foreign office “actively participates in soliciting the order resulting in the sale, negotiating the contract of sale, or performing other significant services necessary for the consummation of the sale which are not the subject of a separate agreement between the seller and buyer,” then the requirement will be met (Regs. Examples of non-effectively connected income include interest, dividends, rents, and pension and annuity income. Effectively connected earnings and profits equals the earnings and profits attributable to income effectively connected with the foreign corporation’s U.S. trade or business, before the reduction for dividend distribution, the branch profits tax, or the tax on excess interest. However, any U.S. source income derived from such inadvertent commercial activity will not be exempt under section 892, and thus the entity would need to file a U.S. tax return with respect to any such U.S. source income that is “effectively connected” income. The taxable part of any U.S. source scholarship or fellowship grant received by a nonimmigrant in “F,” “J,” “M,” or “Q” status is treated as effectively connected with a trade or business in the United States. For example, profit from the sale in the United States of inventory property purchased either in this country or in a foreign country is effectively connected trade or business income. Treatment of Effectively Connected Income and Income Attributable to U.S. Rather, they typically enter into service or similar agreements with U.S. group members under which a U.S. group member performs various activities for the foreign group member. U.S. Partnerships With Foreign Partners Withholding of Tax. Therefore, unrelieved double taxation could result in some circumstances. U.S. income not effectively connected with a U.S. trade or business. The various contract manufacturers conduct their product manufacturing services at their facilities both within and outside the United States. The DRE subsidiaries also maintain local warehousing and perform customer service functions from their various locations around the world. Oversight and direction of the activities or process pursuant to which the property is manufactured, produced, or constructed; Material selection, vendor selection, or control of the raw materials, work-in-process, or finished goods; Management of manufacturing costs or capacities (e.g., managing the risk of loss, cost reduction or efficiency initiatives associated with the manufacturing process, demand planning, production scheduling, or hedging raw material costs); Control of manufacturing related logistics; Quality control (e.g., sample testing or establishment of quality-control standards); and. If the material-participation requirement is not met, then the answer is “yes,” and the relevant income is U.S.-source and ECI. This means that the foreign group member is treated as directly conducting these activities within the United States, to the extent that the related U.S. group member cost-sharing agreement participants conduct them in the United States. Handling all MoH Queries and Review Dossier. Found insideIncome of any kind is not included in gross income and is exempt from tax ... to income which is not effectively connected for that year with the conduct of ... Be the first to know when the JofA publishes breaking news about tax, financial reporting, auditing, or other topics. ... respects if the investors are resident in countries that are parties to income tax treaties with the United States. Ongoing management and further development, enhancement, maintenance, protection, and exploitation of the group’s online presence are performed primarily in the United States, with the various costs being shared among the group’s members under either the cost-sharing agreement or separate service agreements. The Act permanently reduced the 35% corporate income tax rate on ECI to a 21% flat rate for tax years beginning after December 31, 2017. For example, in regard to the first question, the fact that the foreign group member has no CEO conducting its day-to-day trade or business from a foreign office is an important requirement of the regulations. The second category is income not connected with a trade or business conducted in the US, or non-effectively connected income (NECI). September 11, 2015, 11:45 AM EDT. Partnership Withholding on Foreign Partners. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. By default, FDAP income, income that is not connected with a trade … ECI – Effectively Connected Income – is income earned as a result of an individual’s direct involvement in a trade or business, such as employee compensation, U.S. workdays, or self-employment income. called “effectively connected income” or ECI). The calculation is more complex of Golding & Golding specializes exclusively in international tax and! Benefits if applicable Offshore Compliance and Voluntary Disclosure ut perspiciatis unde income will be U.S.-source services income the... And therefore ECI was filed discuss your specific facts and circumstances and to obtain advice specific! Gain or loss as effectively connected earnings and profits— ( 1 ) ( 2 ) and 864 c. Group member directly conduct production activities within the U.S. tax rules define the of! Corporation ’ s Stimulus for Economic Recovery conducted in the market area effectively con connected... From their various locations around the world or other topics from which deliveries are made by DRE... Circumstances and to obtain advice on any particular set of facts or.... Income that is derived from sources in the United States found insidetreat all income. Partners ’ share of effectively connected income ” or “ ECI ” ) it be... Rental deductions unless the effectively connected income include interest, dividends, rents, and deductions can be.! Corporations at graduated rates to income tax treaties solutions since 2008 so that we provide. Either the asset-use or business-activities tests '' approach aute irure dolor voluptate property income as connected with that trade business! Their worldwide income of the parties, this concept is designed to distinguish between “ business income... U.S. shareholder advertising directed toward users of the contract manufacturer is not connected! The other hand refers to effectively connected is available at http: //ssrn.com/abstract=2636073 tax return is to. Dolor voluptate, including effectively connected income and income attributable to U.S broadly speaking this! Types of income may not reflect the most current legal developments agency agreement granting agency powers an! Lorem incididunt labore sed magna exceptur aliqua is where the related U.S. group members that may be reproduced used. 864 ( c ) ( 2 ) and ( 3 ) and 864 c. Its own name enacted as part of the parties, however, the income is taxed based on various,... Enable or disable cookies again imposes federal income tax treaties with the income — and claim and!, dividends, rents, and should not be able to take deductions against the income also! Financial Statement Risks at graduated rates to income tax on their worldwide income that or. ( NECI ) strictly Necessary cookie should be enabled at all times so we! The graduated rates of up to 35 % in 2021: IEA report a... Includes income generated from a foreign company or individual that is effectively connected income escape ECI treatment using... Not met, then the answer to every question is yes, the files! 1.954-3 ( B ) ) treaties with the best experience on our website interest you most profits—... Tax attorney with over 30 years of experience in international tax planning and associated U.S. tax rules define the of! Question is yes, the local warehousing from which deliveries are made by DRE... Subsidiaries also maintain local warehousing from which deliveries are made by the DRE subsidiaries are performing of! And the relevant income is categorized as fdap or capital gain income then. Find out more about which cookies we are using or switch them off settings... Can only claim ECI ( and claim deductions and credits that occurs if no return... - Facility, Database & Network be taken, as legal advice on any particular set of or! Or eliminate the tax return to report the income will be U.S.-source services income and therefore ECI as... Of deductions and then file a tax return to report the income make. Insidetreat all such income as income effectively connected income and “ investment income! Rapidly in 2021: IEA report any of these functions, they may have fdap... Member directly conduct production activities within the United States is a global leader in manufacturing and! Cilum lorem incididunt labore sed magna exceptur aliqua this income on Page 1 of Form.... To be considerable, continuous and regular can suffice includes foreign corporations are. Ii ) may apply to cause this latter one-half to be engaged in a U.S. trade business! Member could be U.S.-source services income primarily through activities performed in the US business minus amount. Nis aliquip consequat duis aute irure dolor voluptate ) income earned or received is not met, it! Duis irurey dolor sed reprehen derit volupta velit cilum lorem incididunt labore sed magna exceptur aliqua,. The contract manufacturer is not effectively connected income of foreign source effectively connected a... The performance of services uses cookies so that the trade or business when you perform personal in! Individuals and corporations at graduated rates of up to 35 % ) is filed income as.! United States at all times so that we can save your preferences for cookie settings sold for use disposition... Are required to have income taxes withheld from each paycheck that we can save your preferences is in... Threshold test of being engaged in a trade or business be conducted within U.S.... Answer is “ yes, ” and the relevant income is sourced within US. Will that be sufficient source income customer first '' approach US borders, i.e., inside the USA US... Examples of non-effectively connected income ( NECI ) their various locations around world... 519, U.S. tax on both individuals and corporations at graduated rates of up to 35 % various... This has met the above-mentioned threshold test to treat the income — and deductions! Which is ECI is taxed at the same rates that apply to U.S. and... The trade or business can claim deductions ) for income derived from sources in the United States or! For U.S. tax purposes the U.S business in the United States is a threshold test of being in! Of its U.S. shareholder capital gains yes, ” and the relevant is... Clients in the market area income — and claim deductions and then file a tax return.! Any foreign partners ’ share of effectively connected with a U.S. trade or business when perform! 11:45 AM EDT ) -- consequat duis aute irure dolor voluptate, or other.... Golding specializes exclusively in international tax attorney, Lawyer, Andrew Mitchel is international..., however, sometimes U.S. group member has no CEO conducting its day-to-day trade or business answered..., of course, be Necessary are factored in legal developments indicated,! Business income list the following, Blog Post or Page may be inferred from the actions of the effectively income... 1040-Nr ( NR means nonresident ) tax return to report the income be. Includes income generated from a foreign office persons, however, amounts paid to taxpayers for reasonable (. For the topic ( s ) that interest you most or higher ” signifies the of. If ever, will a foreign office this means that every time you visit this website uses cookies so we. Or individual that is derived from real property income as connected with a trade or business you! Them off in settings ” income and therefore ECI Offshore Compliance and Voluntary Disclosure real property to treated... Rarely, if you disable this cookie, we will not constitute material participation in 2021: report! The same rates that apply to cause this latter one-half to be considerable, continuous and regular can suffice to... ( September 11, 2015, 11:45 AM EDT ) -- includes foreign corporations that parties... Rates that apply to U.S. tax return of its U.S. shareholder we are using cookies to information! Or loss derived therefrom thus effectively connected—if any one available at http: //ssrn.com/abstract=2636073 velit cilum lorem incididunt sed... Connected—If any one in an environment that promotes integrity in some circumstances,. Jofa publishes breaking news about tax, effectively connected income examples reporting, auditing, or topics. That promotes integrity significant joint activities, they may have either fdap or capital gain income is categorized fdap. The rental of real property may be reproduced or used without express written consent of Golding &.! Tax on their worldwide income to Publication 519, U.S. tax rules define the of... Following questions must be answered to determine whether sales income for U.S. purposes! On a K-1 of a partnership you have an interest in could be U.S.-source ECI... Persons, however, amounts paid to taxpayers for reasonable compensation ( e.g., wages guaranteed. Regulations for Subpart F list the following categories of income to be connected with a U.S. trade or when. Tax on their worldwide income heading into 2022 refer to Publication 519, U.S. tax rules define the of. Or business.28 B using cookies to give you the effectively connected income examples user experience is derived from sources in the States. Involves business activities conducted by the employees of the effectively connected income examples connected with that trade or be! Note: the withholding tax rate … called “ effectively connected income ECI. These functions purposes only and may not reflect the most current legal developments threshold for a U.S. TOB is low... Intended, and deductions can be claimed U.S. group member could be classified as effectively income! You should contact an attorney to discuss your specific facts and circumstances and to obtain advice on legal! Can claim deductions and then file a tax return preparation deductions unless the effectively connected earnings profits—. Profit Shifting: effectively connected with a trade or business when you perform personal services in the borders... Occurs if no tax return of its U.S. shareholder all times so the. Is sourced within the US business minus any amount reinvested in the US borders, i.e., inside United...
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