San Jose Estate Planning Attorney Blog

Avoiding Probate is often a key goal for clients in their estate planning.  This article will give you eight examples of property that passes directly to your beneficiaries without the need for probate.

1.   Property Passing Outright to the Surviving Spouse

California has a very simple probate procedure for property that passes outright to the surviving spouse.  The spouse may file a Spousal Property Petition with the probate court.  If no one objects, the court will generally grant the petition and the property will ordered to the surviving spouse.  We commonly do these for estates where the first spouse died without a Will or a Trust.  Under California law, under those circumstances, the surviving spouse would get all of the Community Property and a third to half of any Separate Property of the deceased spouse.  The Spousal Property Petition avoids the need for the lengthy and expensive probate process most client's dread needing.

2.   Estates of Less than $150,000 in Value

Small estates do not have to go through the full probate process.  A Section 13100 affidavit is given to the institution holding the property.  Upon receipt of the affidavit, the institution will turn over the asset the Personal Representative for distribution to the proper beneficiaries.  You cannot do a 13100 affidavit, however, if the estate consists of any real property, no matter the size of the estate.

3.   Assets in a Trust.

Generally, assets that are in a Trust do not pass through probate.  The Trust terms declare who is to receive the property when the Trustmaker's pass away.  The Trustee follows the terms of the Trust and distributes the property to the Trust beneficiaries.

4.   Life Insurance

If there is a valid beneficiary designation the life insurance will be distributed to the beneficiaries named on the designation.  The life insurance contract governs who the beneficiary will be, so there is no need to probate the life insurance policy.  However, if there is no named beneficiary of the policy, then the insurance company will usually require that the policy be included in the probate so they know who should get the death benefit of the policy.

5.   Retirement Plans and Annuities

In the same way that life insurance usually avoids probate, retirement plans like your 401(k), 403(b), etc. avoid probate if there is a valid beneficiary designation.  Avoiding probate of the retirement plans is especially important due to the negative income tax consequences of having the probate estate as the recipient of the plan proceeds.

6.   Bank and Brokerage Accounts

Most financial institutions offers the ability to use a beneficiary designation on the account.  This will cause the account to pass to the named beneficiary and avoid probating the account.  Sometimes these are called “Pay on Death” designations.  Other times, they may be called “Totten Trusts.”

7.   Buy-Sell Agreements

In a Buy-Sell Agreement, the owners of a business agree among themselves to purchase the ownership interest from any owner who passes away.  This allows the business to continue operating the way it has in the past without interference from the spouse or children of the deceased owner.  In exchange for purchasing the ownership interest, the surviving business owners pay the deceased owner's beneficiaries in cash or in kind.  These payments are made directly to the beneficiary and avoid probate.

7.   Property Held as Joint Tenancy

If you own property as Joint Tenants, title to the property will pass to the remaining joint tenants on the death of one of the joint tenants.  I would not advise using Joint Tenancy as your method for transfering property outside of probate without consulting a lawyer to work out the potential problems and unintended consequences that can occur.  Certainly, do not expect that if you name one of the children as the joint tenant that you are leaving the property to all of the children.  The property passes by law to the surviving joint tenants, not all of the brothers and sisters of that joint tenant.

One of the best strategies for clients with wealth is to find ways to maximize the value and economic efficiency of that weath in a way that benefits the family without increasing the tax impact on the client's estate.  An intrafamily loan is often an excellent strategy.

Loans to the children and grandchildren can be used to help the kids purchase a home, pay for living expenses, start a business, and many other things.  With short term interest rates less than .25% per year, even loaning funds for investment purposes can be an excellent freezing technique for the client's estate.

Here are 5 tips to avoiding traps when making an intrafamily loan.

1.   Always Have the Loan in Writing

The importance of making the loan in writing cannot be overstated.  How do you prove to the IRS what the terms of the loan were?  What if someone dies before repayment of the loan?  Who gets the future income and payments?  Will other family members be upset that one child got “free” money that they didn't get?  If you need to prove that the loan was a bona fide loan and not a gift (very important for tax purposes) you will need documentation to prove it.

2.   Take Advantage of the Annual Gift Tax Exclusion

Every year, a client can give $13,000 to as many different individuals as they wish.  If the client is married, the couple may give a combined $26,000 per year.  If there is a loan outstanding, the client could potentially forgive the annual exclusion amount of the loan each year until it is paid off.  This is often preferable to an outright gift that use up exemption and may create negative tax consequences.  However, be careful not to merely “loan” the money and then never expect repayment because of future forgiveness of the annual exclusion amounts.  This may impact whether or not you actually make a bona fide loan in the first place.  You will want to work with a qualified attorney to help avoid that pitfall.

3.   Show That You Intended to Collect the Loan

This follows from the comment above.  You must have every intention of collecting according to the terms of the loan.  I think it is important to have some repayment history on the loan. 

4.   What if the Loan is in Default

It is not appropriate to let a loan linger in default.  This goes towards whether or not you have a bona fide loan.  Some attempt at collecting should be made.  If the loan is secured, for example, against a house, you will need to consider whether or not foreclosure is appropriate.

5.   Charge Interest on the Loan

The Treasury Regulations require that interest be paid on the loan at the Applicable Federal Rate (AFR).  The AFR is divided into Short Term (up to 3 years), Mid-Term (3 to 9 years), and Long Term (over 9 years) interest rates.  In any intrafamily loan, you must charge at least the appropriate interest rate.  In most cases this interest is taxable income to the client and should be reported on their 1040 income tax return.  Even if the interest is not paid or is forgiven as a gift, the interest income is still reportable taxable income.

A power of appointment can be an effective estate planning technique, facilitating how your property may ultimately pass to your heirs.  There are two types of powers of appointment: general & limited. Both of these powers are the same with one exception:  The general power allows the power holder to appoint the property to themself, their estate, their creditors, or the creditors of their estate.  If you grant a general power of appointment, allowing the power holder to appoint to themself, the property will be included in the powerholder's estate for estate tax purposes.

Greatest Benefit of Creating a Power of Appointment

There is one great benefit to granting a power of appointment to the beneficiary of a trust you create:  Flexibility!!!

It is very difficult to know what the future will hold.  What are the needs and wants of the beneficiary in the future. Who is better able to manage the trust assets as they pass to third and fourth generations?  A Power of Appointment can create that flexibility to allow each beneficiary to make the best appropriate decision based on the information they have available rather than mandating a distribution scheme that may be inappropriate in the future.

Reasons to Choose a Limited Power of Appointment

Most of the time, the attorney will recommend a limited power of appointment. This will create flexibility in your estate plan by allowing the beneficiary of the trust to determine who gets the trust property next (after they die) without having to worry about estate tax inclusion.  This also allows you to preserve the generation skipping transfer tax exemption so all of the assets in that trust that are exempt will not be included in the beneficiary's estate, no matter how large they have grown into.

Reasons to Choose a General Power of Appointment

You should not create a general power of appointment without the recommendation of your attorney.  The power of the beneficiary to appoint the property to him or her self, their estate, their creditors or the creditors of his or her estate will cause the enitire trust amount to be included in the estate of the beneficiary for estate tax purposes.  The whole trust estate could also be subject to the payment of the claims from creditors of the beneficiary.  Finally, the beneficiary may be able to subvert the original intent of the trustmaker (or power grantor) by appointing the property to his or her estate and then leaving the property to someone else in their Will.

San Jose Estate Planning Attorney Responds: It is not uncommon for financial planners to believe that their conversations and records regarding the information they learn from a client is confidential. In fact, the CFP Board Code of Ethics requires planners to keep client information confidential.

However, there are many areas where a financial planner’s documents or testimony regarding conversations may be discoverable by a court of law or the IRS. This is particularly true in the advanced estate tax planning area.

There is no legal privilege for financial planners. Conversations with your clients regarding tax planning and strategies may be subject to discovery. Papers detailing and explaining these strategies in your possession may also be discoverable.

You do not want to fall into the trap this financial planner did. As his clients decided to go aggressive in some of their estate tax planning strategies, the planner was involved in every aspect of the planning along the way. He sat in meetings with the attorney involved. He helped the client understand the strategies and what they involved. No one told him that there was a problem. No one told him that there was no privilege.

Later, after an estate tax audit, the IRS subpoenaed records from the financial advisor. You can guess the rest of the story.

A good financial planner is invaluable to the planning team. In fact, for many of our clients, it is the financial planner who quarterbacks the team and leads the process. However, it is important to remember where the limits of the financial planner's involvement may need to end. There are times when a good attorney will want everyone to leave the room except for the client. The attorney is trying to bypass the other advisors. They are asking you to leave so they can have a private, attorney-client privileged conversation with the client. If any one else is there, whether it is the client's children or advisors, there is no attorney-client privilege. And therefore, no protection.

Never Forget: your work papers, correspondence, and recollections or notes of client conversations are all discoverable in court or by the IRS.

What is the proper way to plan for taking advantage of the deceased spouse’s portability exemption amount? I have written previously on portability planning here and here.

In traditional estate planning, the client will create an ABC trust where the A Trust is for the Alive Spouse, the B Trust is for the Buried Spouse, and the C Trust is the leftover amount of the deceased spouse’s remaining property not placed in the B Trust. The C Trust qualifies for the marital deduction so there is no estate tax owed on the first death.

As we have discussed previously, however, for many estates, there is no income tax benefit for using a traditional ABC Trust model in your planning.

Instead, we are recommending that client's consider having an ACB Trust instead. Technically, we want the trust to be drafted to allow for the making of a Clayton election.

Essentially, all of the deceased spouse's property is allocated to the C trust. Remember, the C Trust qualifies for the marital deduction so there is no estate tax owed on the first death. It also does not use up any of the deceased spouse's estate tax exemption. This allows for maximum usage of the estate tax exemption by the Surviving Spouse.

The trustee has 15 months from the first spouse's date of death to claim the marital deduction on a timely filed estate tax return. If the trustee claims the marital deduction, they will also elect portability of the deceased spouses exemption amount on the same return.

If the trustee does not claim the marital deduction on the estate tax return, then the property will be placed in the B trust. Some or all of the deceased spouse's estate tax exemption will be used. Whatever is not used is still available to be ported over to the surviving spouse.

Using this Clayton Election Strategy gives the surviving spouse maximum flexibility to determine what the best course of action is at the time the decisions matter. Trying to draft an estate plan in today's ever changing tax climate is like shooting at a moving target and hoping to hit the bullseye.

On the first death, the surviving spouse can take a survey of the assets owned, the tax law in place, and the economic conditions and assumptions going forward to create the best result for themselves and their families at that moment.

This is almost impossible to do today unless clients are going to change and revise their plans every time the law changes beneath them.

It is easy to find problems with something or to claim that it will not work. Previously, I blogged about the arguments that many attorneys are using against portability in an effort to avoid change.

It is much more difficult to champion something, to investigate, and to find a way to explain how something may be beneficial to a client.

There is essentially ONE reason why clients should consider Planning for Portability. It minimizes taxes while maintaining control over the ultimate disposition of the assets. The traditional estate planning structure does not do this!!!

The Traditional Model
On the first death, traditional estate planning will place all of the deceased spouses assets, up to the estate tax exemption amount, into a Credit Shelter Trust (what is sometimes called a Bypass Trust). The surviving spouse is generally given all of the income and principal distributions if necessary for his or her health, education, maintenance and support.

This trust preserves the estate tax exemption of the first spouse to die. No matter how large the trust grows it is not subject to estate tax on the death of the surviving spouse.

The structure has been used for years as a fundamental concept of estate tax planning. Always preserve the deceased spouse's estate tax exemption.
The strategy worked very well when the estate tax exemption was only $600,000 as in the mid-90s. Even as the exemption was raised to $1 million in 2001 and continuing to $3,500,000 in 2009, the strategy was fundamental to estate tax savings.

However, in today's estate tax environment, where each person receives a $5 million estate tax exemption, very few families will have estate tax issues. As I have been speaking to CPA's, Enrolled Agents, and CFP's and their professional associations, I have been explaining to them that the estate tax is only one of many taxes that proper planning investigates.

The income tax is now as important as the estate tax. Consider that the top estate tax rate is 35%. This is also the top tax rate for the income tax. In fact, saving income taxes may be more important than saving estate taxes once you factor in California's 9.3% state income tax rate.

Minimize Taxes
One of the primary reasons for Portability Planning is to minimize income taxes on the second death. When the surviving spouse dies, all of the assets in his or her estate are "stepped-up" to fair market value but, not the assets in the Credit Shelter Trust.
When the beneficiaries acquire the assets from the Credit Shelter Trust, they typically sell them immediately. This usually creates a capital gain and taxes must be paid on the growth of those assets. Portability Planning allows beneficiaries to avoid paying the tax because they will get a step-up in basis on the property included in the surviving spouses estate.

Maintaining Control
The only way to get a step-up in basis is to have the assets included in the surviving spouse's estate. Assets in the Credit Shelter Trust do not get basis. If you leave all of the assets to the surviving spouse, you get basis, but the surviving spouse can choose who gets the property when [he or] she dies. In other words, you have no control.
In our next post, we will blog about the proper use of portability planning, and how it is used to properly plan for clients.

If you have questions on whether portability planning is appropriate for you or not, please contact a qualified estate planning attorney.

6 ARGUMENTS AGAINST PLANNING FOR PORTABILITY

It seems like all I hear or read from other lawyers are all of the problems and uncertainties that exist in Portability Planning in the client's estate plan. Last week I listened to another attorney go on and on about the best course of action to take: "Keep Doing Things The Way We Have Always Done Them! Portability has problems!!!"

Living in the past is not usually the best solution for our clients. It is true that there are unknowns in Portability Planning. There are also some situations where it is not appropriate for that particular client. However, for most clients who have non-taxable estates, planning to use the deceased spouse portability exemption is the BEST planning available to them. At a minimum, it ought to be actively considered in the planning process.

Over the next couple of weeks, I will examine the potential problems of portability planning and the advantages and benefits as well.

Problems of Portability Planning

There are six primary arguments I hear attorney's make when they speak against planning for the surviving spouse to use Portability.

1. "It is only a two year law. Portability is only possible if the client dies in 2011 or 2012. Since that is not likely, why spend much time on it. Who knows what the law will be in 2013."

While it is certainly true that the law may change in 2013, not everyone will live to see that day. But we create estate plans to be in place when client's die. They need to be accurate and subject to the best information we have available at the time. It is not a good response to say, “I did not think you were going to die today?

2. "The law is ambiguous and there are no regulations and cases to help us interpret the law."

This one really upsets me because it is one of the reasons lawyers have such a bad reputation among the general public. Attorneys are generally perceived as being too conservative. In this case, however, the attorney, along with the rest of the client team of advisors, needs to weigh the risks and rewards of the strategy. As we will discuss in later posts, the benefits for some clients, clearly outweigh the risks.

3. "Use of the Portability Exemption is not automatic. It requires you to file an estate tax return."

True again. But at what cost? The cost of filing the return may be very small compared to the taxes lost for failing to tax advantage of Portability. In addition, there is the possibility the IRS will create a 706A short form as an alternative to the standard 706 Estate Tax Return currently required.

4. "There is no statute of limitations for examining the estate tax return."

There is also no statute of limitations if you don't file a return at all. However, if a return is filed, the IRS may only examine it after three years for a limited purpose and not to assess taxes. There are no limitations for an unfiled return."

5. "Although the surviving spouse estate tax exemption is indexed for inflation (also only for the next two years), there is no inflation adjustment for the deceased spouse Portability Exemption."

This is a risk to be considered in implementing Portability after the first spouse dies. It is not a reason not to plan. For many clients, this will not matter. It is good information to know, but it does not stop us from planning to use Portability.

6. "Portability only applies to Estate and Gift Taxes.. It does not apply to Generation Skipping Transfer Taxes."

Finally, an argument that makes sense! Therefore, if GST planning is important to the client, you should not use Portability as a planning option.

In our next post, we will discuss the many positive benefits for Portability Planning for clients.

It's All My Kids Fault :) A recent article in the San Jose Mercury News suggested that young children may make parents less fit. As many of you know, my wife and I adopted two young girls from Russia a few years ago. They are 5 & 4 now. And I am out of shape. :)

However, I am starting to remedy that situation by eating healthier and getting some exercise. This made me think about planning for parents of young children. If someone is the parent of a young child, what should they look for to make sure their affairs are in order.

Here are 8 suggestions to make sure your planning is good to go if you don't.

1. Is your Trust (or will) up to date? if you haven't reviewed your estate plan recently, you should do so. The law has been changing a lot recently. in 2010, we had another major change. The last thing you want is the Probate Court to decide your children's future.

2. Have you selected an appropriate guardian? I have bloged before about suggestions for choosing a guardian here. Make sure that the people you have named as guardians are still willing and able to serve. Do you have temporary guardians in case your permanent guardian needs to travel to San Jose to get your kids? Have you planned for contingencies? Will the guardian need your financial resources to support their family along with your children?

3. Do you have adequate Life Insurance? I can't tell you the number of clients we see in our office who come in with very little life insurance. All of the documents in the world only direct what happens to the money and assets you own. If you don't have much, there is not much there for your suriving spouse or children. The documents do not create wealth. Life Insurance creates weath. Give our office a call if you need a referal to a quality Life Insurance Agent who can work with you to make sure you are adequately insured.

4. What if you become incapacitated? Who will manage your finances if you can't manage them yourself. Are they trustworthy?

5. Do you have an Advance Health Care Directive? This is the one document that protect you. Are you sure that the person you have asked to be your agent to make medical decisions for you will follow your instructions? Will they ask questions of the doctor? Get a second opinion? Consult with other family members?

6. Do you have a HIPAA Release? Without one, the doctor will not tell anyone about your private medical condition. This can make it difficult for your successor trustee and your health care agents to actually take over if necessary. If the doctor can't talk to them about your condition, he or she will also not be able to sign the necessary paperwork to allow them to effectively take care of you. Since there were no HIPAA releases just a few years ago, make sure you have an updated one in place.

7. Is your Trust funded? Have you titled all of your property into the trust. Unfortunately, there are many attorneys who never talk to clients about trust funding, so they don't know that it needs to be done. Make sure all of your bank accounts, brokerage accounts, real estate and other properties are actually titled in the name of the trust. If they are not, your Trustee will be heading to court after you die to either Probate the assets or get another court order to establish proper title to the property. Either way, this is easily avoided if you actually title the assets in the Trust.

8. Do you have an Estate Tax Reduction Strategy? Most people no longer have an estate tax problem. The Estate Tax Exemption is now five million dollars ($5,000,000) per person. If, however, you are one of the lucky ones with assets greater than five million, make sure you see a qualified estate tax attorney like Sheffield Law Office to better help you reduce the tax burden on your children.

Choosing a qualified Guardian for your children is one of the most difficult things my clients ever have to do. For many, they can't do the rest of their estate planning until they resolve this issue. And then the planning doesn't get done.

Here are a few suggestions and tips to naming a Guardian for your children:

1. Family is NOT required. You do not have to name family members. You can pick anyone you wish.

2. No matter who the guardian is, make sure that both of your families have access to the children. This should include age appropriate taveling to meet with relatives who may not be local. It is important that the guardian understand, from the nomination document, that you expect this. It is not uncommon for the guardian to not like the other sides family. He or she may think they are a bunch of uncouth hillbillys and a bad influence on the children. But these are your children. You should decide who should have influence.
By the way, we generally suggest that the guardian create a web site for the child and keep it updated with school photos, information regarding activities and such.

3. Have Backups. Life happens. Sometimes the person that we are counting on to be the guardian has some drama in their life at the time they are needed. Perhaps they were in the car with you when you had the accident? Make sure that you have enough people on your list, so someone you trust will be appointed the guardian.

4. You Don't Have To Ask Everyone You Put On The List. I would recommend that you ask the first or second choice whether they are interested and get a commitment from them, if possible. However, we often will have clients give us a list of 15 names. I don't expect the client to ask all 15. But if, God forbid, anything happens to your primary choices, it is better to have someone on the list who is willing, then to have your children go into the Foster Care System because nobody steped forward. Sometimes, people will only step forward if they are asked. Otherwise, they may not even know there is a need.

5. Only Nominate Individuals. I do not recommend nominating couples. What if the relationship falls apart. Do you want your children part of their custody battle?

6. Make Good Use of Contingincies. Instead of nominating a husband and wife, if you want a couple to raise your children, use a contingency. For example, "Mary, if she is married to Bob." You can use a contingency for location, such as: "Alice, as long as she lives in Los Gatos." Or perhaps you want to broaden that to Northern California. If Alice moves to Arizona, she is no longer an acceptable guardian.

Hugh Hefner is purchasing the 30% of Playboy Enterprizes he doesn't own for an 18% premium. The media is focusing on his age and the poor future propects for the company. They seem to be ignoring the tax aspects of this deal for Mr. Hefner's family.

A publicly traded company is easy to value for estate and gift tax purposes. The publicly traded price is the valuation price for the stock. There is no discount. Not only that, but publicly traded companies generally trade at higher multiples of earnings than their closely held counterparts.

When a company is closely held, the value as a percentage of earnings is generally lower than corresponding publicly held companies and the shares are discountable as well.

Assuming Mr. Hefner is not going to live for another 20 years, this tranaction makes perfect sense from an estate and gift tax perspective. The cash he puts out to purchase the shares will reduce the value of his estate since the overall value of the company, now privately held, will go down.

The reduction in value for estate tax purposes will save the estate taxes on Mr. Hefner's death.
Later, when the economy is better, the family can sell the company back to the public for a premium to generate and realize the value that has been there all along.

This type of strategy works in reverse as well.

If your client has stock in a privately held company that may go public (i.e. Facebook, etc.), they should see a qualified estate tax planning attorney to create strategies for them while the valuation of the stock is still relatively low. As the day of going public nears, the value of the shares is increasing for tax purposes and the less tax savings your client will realize.

Movie actress Ann Francis passed away the other day. So did the oldest Von Trapp Family daughter. This made me think about what might happen to their reputations, or the reputations of people they care about, if private journals or stories about their lives were to be made public.

Most estate plans deal only with stuff. Either financial or tangible. Very few actually spend any time dealing with intangible assets like intellectual property or, in this case, your right to publicity. This is not something your typical estate planning attorney discusses with a client.

For client's who have some public recognition, there may be financial value in your client's memoirs. Unfortunately, your client may not want them published. Often, the children are more concerned with maximizing dollars than in preserving past memories. This can lead to family fights, juicy salacious details, and increase the value of the property even more. Sometimes people get hurt and reputations are destroyed.

If you have a client who has the public's eye. Make sure they see a qualified estate planning attorney to discuss these issues. Their reputation may hang in the balance.

Tim McCrone, a CPA in Los Altos, asked me yesterday whether or not beneficiaries of a trust are required to be given notice. Like many answers Lawyers give, it depends.

California Probate Code Section 16061.7 requires the Trustee of any Trust to provide notice to the beneficiaries (and heirs) on the occurance of either of two events:

1. The Trust becomes Irrevocable.
2. There is a change of Trustee.

This means that you do not have to provide anyone notice if your trust is still revocable. But if you die, your trustee will have to notice the current and remainder beneficiaries.

Notice is required to your heirs (i.e. next of kin) so that someone doesn't fraudulently create a trust for you leaving all of your property to them without your children knowing what happened to it.

There are a couple of states, however, that do not require notice like California does. A few require no notice to beneficiaries at all. If you have a client that wants absolute secrecy, they can find it.

We have a new law!

President Obama signed the new tax law on Friday extending the Bush tax cuts for two years. Included in this new law are significant estate tax ramifications. While the overall impact on advisors remains to be seen, there is no doubt that this is bad news for some and good news for others. As a general rule, however, this is good news for the rich.

Here is a quick summary of the estate tax provisions of the new law:

1. $5 million exemption: There is now a $5 million estate tax exemption for each individual. This means $10 million can be exempted from estate taxes for a married couple.

2. Reunification: The estate, gift, and GST tax exemptions have been unified to the $5 million amount. This means that a client can gift $5 million into a dynasty trust while they're alive, using up their estate tax exemption, and not have to wait until they die to take advantage of the increased exemption.

3. Portability: clients who no longer plan for their estate tax exemptions me transfer their unused portion of that exemption to their spouse when they die. If husband dies, he can transfer his $5 million exemption to his wife, and she will now have a $10 million exemption upon her death as she leaves the property to her kids.

4. 2010 election: for clients dying in 2010, they have a choice of law. The client may elect to have a $5 million estate tax exemption with a full step up in basis on all of the decedents property. The client could also choose an unlimited estate tax exemption, but they would only get carryover basis with the additional allocated basis maxing out at $4.3 million.

This law is going to create huge planning opportunities. But there is no doubt, that planning options will change. For many, this means simpler plans which are also less expensive. However, the opportunities for the wealthy to plan and avoid estate taxation have never been better.

We will be conducting a couple of workshops in San Jose, at the end of January or the beginning of February to better help the advisors that we work with understand the details and planning options more fully.

I will post the details in the future.