Governor Baker Proposes Tax Changes to Address Federal Reform, Wayfair Case

by Sullivan & Worcester


In a supplemental appropriations bill for FY 2018,[1] Governor Charlie Baker has proposed amendments to Massachusetts tax law that would deal with the two "hottest" issues on the state and local tax front nationally in the spring of 2018 – the impact at the state level of federal tax reform, and the implications of a pending decision on sales and use tax nexus in South Dakota v. Wayfair, Inc., which is now pending in the U.S. Supreme Court.[2]

Federal Reforms

The Baker package focuses primarily on the international aspects of the federal reforms included in what is commonly known as the Tax Cuts and Jobs Act ("TCJA"). Those reforms include three key provisions:

  • In transition from a system of "global" taxation of US companies to a modified territorial system, accumulated earnings and profits of controlled foreign subsidiaries were deemed repatriated under Subpart F of the Internal Revenue Code, for both individuals and domestic parent corporations, at the end of 2017.[3] This provision is called the "deemed repatriation." Deductions were allowed so as to tax the income at special, reduced rates.[4]
  • On a going-forward basis, TCJA provides for a new category of income of a controlled foreign corporation ("CFC"), known as Global Intangible Low Taxed Income ("GILTI"), that will be included in the tax base of the US owner of such a corporation.[5] GILTI income effectively is all income of a CFC that is not attributable to specified tangible property and is not already taxed as Subpart F income.[6] This provision is intended to encourage US companies to keep their income-producing intangibles in the United States. The GILTI regime also includes a deduction intended to reduce the effective tax rate on such income in the hands of US corporations.[7]
  • Also on a going-forward basis, domestic companies will pay a reduced effective rate of tax, via the mechanism of a deduction, on Foreign-Derived Intangible Income (“FDII”), which comprises certain income attributable to the sale of property to a non-US person for foreign use or the provision of services to a person or with respect to property outside the US.[8] This provision is also intended to curtail the outmigration of intangibles.

State Treatment of the Deemed Repatriation

Under the Baker Bill, for corporate taxpayers, the deemed repatriation amount would be treated as a dividend eligible for the 95% dividends-received deduction ("DRD") that applies generally to domestic or foreign dividends received or deemed received from a corporation in which the payee owns at least 15% of the voting stock.[9] For individual resident taxpayers, it would likewise be treated as a dividend that would be subject to tax, but the bill includes a 60% deduction applicable only to this category of income, in an attempt to closely mirror the federal reduced-rate treatment.[10]

The Massachusetts Department of Revenue ("DOR") estimates that its deemed repatriation regime will generate FY 2019 revenue of $65 million.[11]

State Treatment of GILTI

The state treatment of GILTI in general has been controversial. At the federal level, GILTI included in the income of corporations carries with it a foreign tax credit that in many instances will blunt or eliminate the adverse effect of this new provision. Neither Massachusetts nor the other states provide a credit for foreign taxes paid, so the GILTI impact on state taxes can be significant.

Further, many states are expected to tax GILTI without allowing any DRD, even if they generally apply a DRD to foreign dividends and to dividends deemed to have been paid under Subpart F. They may attempt to justify this treatment by reference to the fact that GILTI is treated like Subpart F income for some purposes, but is not Subpart F income in fact,[12] and also by reference to the fact that a corporation can have GILTI that exceeds the earnings and profits of the payor corporation.[13] On the other hand, failure to allow a DRD for GILTI invites a US constitutional challenge under Kraft v. Iowa Dept. of Rev.,[14] in which the US Supreme Court held that a separate return filing state that offered a DRD for domestic dividends could not deny the deduction for foreign dividends without violating the Commerce Clause.

The Baker Bill would eliminate such controversy in Massachusetts by providing that GILTI is deemed to be a dividend for purposes of the DRD (as well as for purposes of the rule that dividends are not included in the sales factor of the Massachusetts apportionment formula).[15]

For resident individuals, the bill provides that GILTI would be taxable as a dividend.[16]

DOR estimates that the GILTI provisions would generate $239 million in incremental revenue over the 10-year period from 2018 to 2027.[17]

State Treatment of FDII

The Baker Bill proposes to decouple Massachusetts from the FDII deduction.[18] DOR estimates that in the absence of such a decoupling the new deduction would cost Massachusetts $177 million over the same 10-year period.[19]

Treatment of Remote Sellers After Wayfair

On two occasions 25 years apart, the United States Supreme Court has held that remote sellers need not collect sales or use tax in states in which they do not have a "physical presence"[20] ("the Quill rule"). As Internet sales have become a bigger and bigger part of the overall economy, the states have grown concerned that the Quill rule is eroding sales and use tax revenues. Further, so-called "brick-and-mortar" retailers – those with stores in the states or other physical presence – have argued that the Quill rule creates a playing field that is not level vis a vis remote sellers.

Some states, including South Dakota, have reacted by mounting a direct challenge to the continued validity of the rule, arguing that the complexity of multi-jurisdictional compliance that underlay much of the reasoning of the Court in Quill has become a non-issue in practical terms because of advances in business technology. The South Dakota controversy was the first to reach the Supreme Court. Oral argument was heard on April 17, 2018, and questions from the justices suggested that the Court is very much divided on the question whether Quill should be overturned and, if so, what the collateral consequences of that should be.

Other states, including Massachusetts, have attempted to work around the Quill principle by arguing that notwithstanding Quill, many remote sellers can be required to collect because they have some form of physical presence in the state. In Massachusetts, such a physical presence (called "deemed nexus" elsewhere in this advisory) may include, according to DOR, "property interests in and/or the use of in-state software … and ancillary data (e.g., 'cookies') which are distributed to or stored on the computers or other physical communications devices of a vendor’s in-state customers."[21] Where such a physical presence exists, DOR requires collection by a remote seller if, during the preceding calendar year, it had in excess of $500,000 in Massachusetts sales from transactions completed over the Internet and it made sales resulting in a delivery into Massachusetts in 100 or more transactions.[22]

The Baker Bill would authorize DOR to create a special registration program for remote sellers having less than $500,000 in sales into Massachusetts in the previous 12 months, but having a physical presence in the state by virtue of tangible property maintained in the state by unrelated fulfillment providers or contacts related to remote Internet sales, including but not limited to the "cookie" nexus referenced above.[23] Qualifying sellers would be permitted to register for collection of sales and use tax on or before June 30, 2019 without incurring any liability for periods prior to registration.[24]

The sales and use tax provisions of the Baker Bill seem designed to create a relatively painless path forward for remote sellers in the event that the Supreme Court in Wayfair overturns Quill in such a way as to suggest that the states may chase remote sellers retroactively. The Baker Bill would protect many of such sellers from retroactive liability if their sales into Massachusetts are less than $500,000 and they register before July 1, 2019.  Further, while it is not certain, it appears that DOR has no intention of going back before October of 2017 with respect to vendors over the $500,000 threshold whose contacts are limited to "deemed nexus," even if Wayfair holds that no physical presence is required to impose a collection responsibility.

Legislative Prospects; What Happens If the Bill Is Not Enacted?

It is difficult to predict what reception the Baker Bill will receive in the Massachusetts legislature. Because it comprises a supplemental appropriations bill, it has the "look and feel" of non-controversial "clean-up" legislation. It is not expected to give rise to concerted business opposition because some of its provisions, such as treating GILTI income as if it were Subpart F income and committing not to go retroactive with respect to smaller remote vendors who take advantage of the registration program, are relatively friendly to business interests. Further, it purports to raise significant revenue by virtue of provisions such as incorporating the taxation of GILTI in the hands of individuals, even though the GILTI regime was not in effect under the 2005 Internal Revenue Code that governs most Massachusetts individual taxation.[25] Finally, it must be said that the nuances of the federal reforms with which the bill deals will certainly not be understood by the legislators charged with passing on the bill. Taking all of these factors together, it seems likely that the bill, perhaps with material revisions, will indeed make it to the desk of Governor Baker for signature.

It is important to remember that, even if the Baker Bill dies on Beacon Hill, some of the approaches embodied in it are merely clarifications of what DOR intended to do even in the absence of legislative authorization. For example, DOR has already announced that its treatment of the deemed repatriation as dividends would give rise to $65 million in incremental revenue. And if the bill does not pass, DOR may consider itself to have administrative discretion nonetheless to adopt the registration program for small vendors.

[1] HB4520 ("the Baker Bill").

[2] South Dakota v. Wayfair, U.S. Sup. Ct. Doc. No. 17-494.

[3] IRC Sec. 965(a).

[4] IRC Sec. 965(c)(1).

[5] IRC Sec. 951A(a).

[6] See IRC Sec. 951A(b)(1).

[7] IRC Sec. 250(a)(1)(B).

[8] IRC Secs. 250(a)(1)(A), 250(b).

[9] Baker Bill Section 10, by amendment of G.L. c. 63, s. 30. Because the DRD is allowed, the Baker Bill would decouple from the federal deductions that effectively reduce the rate of tax on the deemed repatriation for corporate taxpayers. Baker Bill Section 11, by amendment of G.L. c. 63, s. 30.

[10] Baker Bill Section 13.

[11] See Administration and Finance Explanation of the Baker Bill. The TCJA permits taxpayers to elect to spread the tax on the deemed repatriation over eight years.  IRC Sec. 965(h)(1). There is no such option at the Massachusetts level.

[12] IRC Sec. 951A(f).

[13] See IRC Sec. 951A(c).

[14] Kraft Gen. Foods v. Iowa Dept. of Rev., 505 U.S. 71 (1992).

[15] Baker Bill Section 10, by amendment of G.L. c. 63, s. 30. As in the case of the deemed repatriation, Massachusetts would decouple from the federal deduction for GILTI on the grounds that allowing that deduction in addition to the state-level DRD would be duplicative. See Baker Bill Section 11, by amendment of G.L. c. 63, s. 30.

[16] Baker Bill Section 4, by amendment of G.L. c. 62, s. 1(e).

[17] See Administration and Finance Explanation of the Baker Bill.

[18] Baker Bill Section 11, by amendment of G.L. c. 63, s. 30.

[19] See Administration and Finance Explanation of the Baker Bill.

[20] National Bellas Hess v. Dept. of Rev., 386 U.S. 753 (1967); Quill Corp. v. North Dakota, 504 U.S. 298 (1992).

[21] Reg. 830 CMR 64H.1.7(1)(b)(2)(a). Certain contracts with "content distribution networks" and with "online marketplace facilitators and/or delivery companies" are treated the same way as so-called "cookie nexus." See Reg. 830 CMR 64H.1.7(1)(b)(2)(b),(c).

[22] Reg. 830 CMR 64H.1.7(3)(b). The collection requirement referenced here took effect October 1, 2017. See Reg. 830 CMR 64H.1.7(3)(a).

[23] Baker Bill Section 14.

[24] Id.

[25]  See G.L. c. 62, s. 1(c).

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sullivan & Worcester | Attorney Advertising

Written by:

Sullivan & Worcester

Sullivan & Worcester on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.