George Washington Law Review最新文献

{"title":"The U.S. Tax Treatment of Foreign Source Income Earned in Developing Countries: A Policy Analysis","authors":"P. McDaniel","doi":"10.2139/SSRN.476581","DOIUrl":"https://doi.org/10.2139/SSRN.476581","url":null,"abstract":"The purpose of this Article is to explore whether the United States should amend its international tax rules in ways that might encourage U.S. companies to invest in developing countries. Some scholars, notably Professor Karen Brown, have argued that the current U.S. international tax regime works against the interests of developing countries and should be replaced by one that, she asserts, would benefit developing countries in general and African nations in particular.1 She has proposed that the United States replace its foreign tax credit mechanism with an exemption system for developing countries, at the least for Africa. One of the reasons for the proposal is that, as explained below, the current U.S. system prevents developing countries from offering tax incentives, such as tax holidays, to attract foreign direct investment (FDI) by U.S. multinational corporations (MNCs). Certainly, it is the case that little U.S. FDI finds its way to developing countries. At the end of 2001, total U.S.-owner assets earned abroad totaled $6.2 trillion (valued at cost). But the following shows how little of these assets were in developing countries (in $ billions):2 There is thus a real shortfall in U.S. FDI in developing countries as compared to its FDI in other developed countries. But, proposals such as the one put forward by Professor Brown raise several questions. Is FDI an unqualified good for developing countries? What are the determinants in the location of FDI? Are tax incentives offered by developing countries effective in attracting FDI, even in situations where home country tax rules do not thwart them? Can tax incentives alone attract FDI or are there necessary preconditions a developing country must satisfy before there is FDI at all? Are home country unilateral tax incentives effective in increasing FDI by its MNCs? Is it better for developed countries to assist developing countries by offering tax subsidies to its MNCs or by providing direct financial assistance to developing countries? This paper is an effort to explore these questions to see where the evidence supports clear answers and where it is inconclusive. Part I of this Article provides a broad overview of international tax systems, which countries can adopt, with particular attention to aspects of the system adopted by the United States. Part II examines how, and under what circumstances, the current U.S. system defeats the objectives of developing countries in offering tax holidays to U.S. MNCs. It then proposes a structural solution that would address the problem in the context of the ciirrent system. It is, of course, possible that the proposal would not be acceptable to the U.S. Treasury or to developing countries in general. Thus, the remainder of this Article examines Professor Brown's proposal and others that might be considered in meeting the objectives of increasing the FDI of U.S. MNCs in developing countries. Part III identifies the economic, social, and political factors ","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"33 1","pages":"265"},"PeriodicalIF":1.5,"publicationDate":"2003-12-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"86187467","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Judicial Review and the War on Terrorism","authors":"J. Yoo","doi":"10.2139/SSRN.461721","DOIUrl":"https://doi.org/10.2139/SSRN.461721","url":null,"abstract":"This article examines the role of the federal courts in the war on terrorism, and contrasts the different judicial roles in reviewing decisions about the conduct of war abroad and within the United States. It explains that judicial refusal to adjudicate questions concerning the initiation and conduct of the war abroad is consistent with a narrow view of judicial review and the political question doctrine. Because the Constitution allocates different war powers to the President and Congress, allowing them to shape warmaking through the interaction of these powers, there is no single, constitutionally-required process for making war that requires judicial enforcement. This view has been borne out in practice, as most recently demonstrated in the wars in Afghanistan and Iraq. The paper also reviews the role played by federal courts with regard to the domestic effects of war, particularly when the war involves American citizens as enemies or when operations occur within the territory of the United States itself. It illustrates the wartime role of judicial review by examining cases arising from the current war against the al Qaeda terrorist organization. In the context of surveillance, the federal courts have granted warrants under the Foreign Intelligence Surveillance Act (FISA) using more flexible standards than exist for a normal search warrant, to permit surveillance of terrorist suspects. With American citizens detained as enemy combatants, the courts have entertained habeas corpus petitions, but have followed a deferential standard of scrutiny for the executive branch's war making decisions. These cases show that while the courts have exercised judicial review over the consequences of the decision to go to war, they have adopted a more flexible, deferential standard of review than would apply to normal, peacetime governmental actions, in order to accommodate the imperatives of conducting war. Thus, judicial review may apply to domestic wartime measures, but in a manner that provides options to the political branches for the conduct of the war, rather than simply serving as a negative check on government action.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"72 1","pages":"427"},"PeriodicalIF":1.5,"publicationDate":"2003-11-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"67738937","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"A Review of Globalization and its Discontents","authors":"K. Kennedy","doi":"10.2139/SSRN.460481","DOIUrl":"https://doi.org/10.2139/SSRN.460481","url":null,"abstract":"Globalization and Its Discontents by Joseph Stiglitz is an insider's account of the failings of the Bretton Woods institutions during the Clinton Administration. The author, the 2001 Nobel laureate in economics, gives an insider's view of the role played by the Bretton Woods institutions in the globalization process. Professor Stiglitz's presents several case studies to illustrate how the IMF, with the aid and encouragement of the U.S. Treasury Department, failed to properly manage a number of financial crises that took place during the last decade of the 20th Century. Regrettably, his account is nothing less than a diatribe - unfortunately at times personalized - attacking the entire Bretton Woods system, and in particular the IMF. Stiglitz makes no pretense of being balanced or of writing a scholarly work. Globalization and Its Discontents generates a tremendous amount of heat, but sheds very little light on a critically important subject.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"23 1","pages":"251"},"PeriodicalIF":1.5,"publicationDate":"2003-10-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"85398401","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"A User's Guide to the Stored Communications Act, and a Legislator's Guide to Amending it","authors":"Orin S. Kerr","doi":"10.2139/SSRN.421860","DOIUrl":"https://doi.org/10.2139/SSRN.421860","url":null,"abstract":"Americans care deeply about their Internet privacy. But if they want to know how federal law protects the privacy of their stored Internet communications, they'll quickly learn that it's surprisingly difficult to figure out. The federal statute that protects the privacy of stored Internet communications is the Stored Communications Act (SCA), passed as part of the Electronic Communications Privacy Act of 1986 and codified at 18 U.S.C. section 2701-11. But courts, legislators, and even legal scholars have had a very hard time understanding the method behind the madness of the SCA. The statute is dense and confusing, and that confusion has made it difficult for legislators to legislate in the field, reporters to report about it, and scholars to write scholarship in this very important area.This Article presents a user's guide to the SCA. It explains in relatively simple terms the structure and text of the Act so that legislators, courts, academics, and students can understand how it works - and in some cases, how it doesn't work. I hope to explain the basic nuts and bolts of the statute and show that the statute works reasonably effectively, although certainly not perfectly. My second goal is to show how Congress needs to amend the SCA. I recommend three ways that Congress should rethink the SCA to better protect the privacy of stored Internet communications, clarify its protections, and update the statute for the present. Specifically, I argue that Congress should raise the threshold the government must satisfy to compel the contents of certain Internet communications; that it should simplify the statute dramatically by eliminating the confusing categories of electronic communication service and remote computing service, and eliminating redundant text; and that it should restructure the remedies scheme for violations of the statute.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"72 1","pages":"1208"},"PeriodicalIF":1.5,"publicationDate":"2003-08-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68734955","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Signaling Behavior, Congressional-Executive Agreements, and the SALT I Interim Agreement","authors":"Christopher B. Stone","doi":"10.2139/SSRN.379280","DOIUrl":"https://doi.org/10.2139/SSRN.379280","url":null,"abstract":"This Article, using a law and behavioral economics perspective, carves out a \"signaling exception\" to the general rule that Presidents must ratify national security accords as treaties and international trade accords as congressional-executive agreements. Under this signaling exception, the President can submit national security accords as congressional-executive agreements when 1) the accord is temporary, and 2) the accord signals that the United States has engaged in learning behavior (as described in the political science literature) about the nature of international affairs. Signaling behavior is particularly common in temporary agreements. The interim nature of such agreements allows the United States to signal incremental trust in its counterparties while hedging its risk. Using the SALT I accords as a case study, this Article locates the President's power to signal in the well-accepted sole communication power, which, under the signaling exception, trumps the Senate's right to advise and consent when the accord in question contains a disproportionate signaling component vis-a-vis its substantive, bargained-for component. Presidents could thus send signals in the form of sole executive agreements or congressional-executive agreements. The Constitution requires the latter vehicle because signals display network effects; they become more credible to foreign powers, and hence more valuable, with congressional support.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"9 1","pages":"305"},"PeriodicalIF":1.5,"publicationDate":"2003-04-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88418855","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Japanese Attitudes Towards Contracts: An Empirical Wrinkle in the Debate","authors":"Michael K. Young, Masanobu Kato, A. Fujimoto","doi":"10.2139/SSRN.363400","DOIUrl":"https://doi.org/10.2139/SSRN.363400","url":null,"abstract":"In this article, we re-examine, from an empirical perspective, the debate about Japanese legal consciousness. In particular, we analyze the result of a survey we conducted among Japanese law and business students to determine their attitudes towards the use of contracts as a device to order economic exchanges. We hypothesized that if the generally accepted view of Japanese attitudes towards law were correct, Japanese respondents who had not studied law and therefore possessed the \"traditional Japanese attitudes\" towards law would be relatively disinclined to urge strict compliance with the terms of a contract. Respondents who had studied law, on the other hand, we hypothesized, would be more inclined to see the contract enforced as written. In other words, legal education would imbue in its recipients an \"American\" attitude towards law, that is, a preference for strict adherence to the precise contractual terms. The data suggested just the opposite. Law students had a decided preference, over their non-law counterparts, for flexibility in the interpretation and execution of contracts. The more law students studied, the stronger that preference. This preference seems to decline, however, when law students are placed in an advisory, as opposed to advocacy role. We also observed significant gender based differences, with women preferring flexibility to a significant degree over men. Some regional differences were also observed, but were comparatively minor. Finally, we also explored whether respondents were inclined to favor a company because it was Japanese. Generally speaking, we did not observe such bias in most cases. But interesting exceptions were found. For example, we observed some degree of bias against Japanese companies in cases in which the opposing company was Korean or Chinese. And when the opposing company was American, only law students exhibited any national bias in favor of the Japanese company. Non-law students did not show any bias in favor of companies from Japan in any of the samples.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"34 1","pages":"789"},"PeriodicalIF":1.5,"publicationDate":"2003-04-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"84873527","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Questions for the Critics of Judicial Review","authors":"S. Prakash, J. Yoo","doi":"10.2139/SSRN.2857464","DOIUrl":"https://doi.org/10.2139/SSRN.2857464","url":null,"abstract":"Judicial review remains one of the American Constitution's most controversial features. It has made American judges some of the most powerful in the world, with a potent role in shaping the everyday lives of Americans. Perhaps for this reason, scholars and judges continue to question its origins and legitimacy, with recent articles appearing in the Harvard Law Review and the Columbia Law Review,' and with Justices Stephen Breyer and David Souter challenging the constitutionality of judicial review in federalism cases. In earlier articles, we laid out the origins of judicial review. Rather than reiterating the affirmative case for judicial review, here we respond directly to the arguments of the leading recent critic, Professor Larry Kramer. We have no quarrel with Professor Kramer's uncontroversial (and indeed, so far as we know, uncontroverted) statement that the Founders envisioned that the Constitution would be enforced through popular means such as voting, petitioning, and mobbing. We likewise agree with his assertion that the Constitution was never meant to enshrine a Cooper v. Aaron type of judicial supremacy. Yet, we profoundly disagree with Professor Kramer's controversial claims that the Constitution, as originally understood, never authorized judicial review, and that the Founders regarded popular constitutional methods as the exclusive means of safeguarding the Constitution. First, Professor Kramer, like Professors Jesse Choper and Herbert Wechsler before him, ignores the constitutional text and structure. Fairly read, the Constitution's text and structure establishes judicial review in a number of ways. Second, the Constitution's text, as well as constitutional practice at the time of the Founding, contradicts Professor Kramer's theory that the Founders meant the Constitution to be a political-legal document ― a document to be enforced exclusively through popular means. Indeed, Professor Kramer's admission that the Constitution is judicially enforceable against the states undermines his own theory. Third, we believe that Professor Kramer has made methodological errors in his use of the historical materials. In particular, he never squares his claims with the secondary historical literature that runs counter to his thesis. Moreover, he implicitly adopts the stance that, in order for something to be historically established, there must be a solely quantitative level of historical proof; in his argument, the quality of the evidence is apparently of no moment. Fourth, the historical evidence, both quantitatively and qualitatively, refutes Professor Kramer's conclusions. The Founders acknowledged that the Constitution authorized judicial review dozens of times, and no Founder appears ever to have argued, during the ratification fight, that the Constitution either barred or did not permit judicial review. Ironically, though Professor Kramer belittles the evidence in favor of the constitutionality of judicial review, there is virtually no ","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"72 1","pages":"354"},"PeriodicalIF":1.5,"publicationDate":"2003-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68394862","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Identity Within: Cultural Relativism, Minority Rights and the Empowerment of Women","authors":"R. Coomaraswamy","doi":"10.4324/9781351157728-16","DOIUrl":"https://doi.org/10.4324/9781351157728-16","url":null,"abstract":"I. INTRODUCTION For the last three decades, the concept of \"identity\" has taken center place in political, social, and cultural debates. Charles Taylor has conceptualized identity as the search for the authentic self.1 Anthony Appiah has argued that identity involves the playing out of narrative scripts that we have learned from childhood.2 Whether we root out identity within the essence of the human personality or in the constructions of social life, identity politics has certainly conditioned many of the modern debates about rights, politics, and justice. Identity is not an essential, immutable, permanent status, it has many constituent elements. Future experiences often transform the nature and direction of personal identity. Identity is often composite, made up of multiple selves, often contesting, contradicting, and transforming the other. Identity therefore reconstitutes itself, reacting to and negotiating ideology and lived experience. The subjective identities that philosophers explore must come to terms with the objective reality of identity as it plays out in the real world. In all societies, as the Census and Statistics departments will attest, people are categorized and identified by a social identity, especially as it is expressed in religious, ethnic, or tribal terms. These group-based identities often help determine our position in the social and political hierarchy of a society and also condition people's attitudes and perceptions toward us as we go about our daily business. These stereotypes and homogenous characterizations create obstacles for the realization of equality. They are also the substance of discrimination and often the basis for power and privilege. Our subjective sense of identity is greatly determined by IMAGE FORMULA8 this objective experience as it interacts with our everyday life and conditions the way we think about ourselves. Our group-based identity often goes to the core of our sense of self and our desire for dignity. For many women, their sense of identity arises as a result their experience as women, living within groups primarily governed by men. Though their sense of self and dignity comes from how the wider society treats women, they often have to face discrimination within local groups. They may have to submit to discriminatory practices and laws, as well engage in rituals, customs, and habits that reinscribe the subordinate status of women within the hierarchy of their religious, ethnic, or tribal identity. Many women acquiesce because they see their group identity as the most important aspect of their lives. Others resist, only to be branded as traitors or \"bad women\" who bring the group into disrepute. For outsiders, especially women's activists interested in pursuing gender equality, discrimination within minority groups and third world societies poses a profound set of challenges. On the one hand, the feminist movement has always seen itself as an ally of third world societies and minority groups","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"8 1","pages":"483"},"PeriodicalIF":1.5,"publicationDate":"2002-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"87877470","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Democratizing the WTO","authors":"Jeffery C. Atik","doi":"10.2139/SSRN.250331","DOIUrl":"https://doi.org/10.2139/SSRN.250331","url":null,"abstract":"As the WTO accretes power, challenges to its authority will only increase. The phrase \"democracy deficit\" has been used in different literatures, as applied to different institutions, to express a structural isolation from popular input. It is often, though not always, used as a critique. The WTO is afflicted with at least three forms of \"democracy deficit:\" 1. Supranationalism. The WTO receives no direct democratic input; rather WTO policies and authority are determined, through various means, by its member states. 2. Judicial lawmaking. Much WTO lawmaking occurs in the context of dispute resolution. Dispute panelists, like judges, are isolated from ordinary politics. The WTO Dispute Settlement Body enjoys a form of judicial supremacy that is democratically suspect, particularly since there is no legislative check on Dispute Settlement Body activism. 3. Political capture. Foreign relations generally, and especially international trade policy, are more subject to capture by special interests than is domestic policy. This undercuts the likelihood that national governments will adequately transmit the concerns and values of their people. Institutions such as Fast Track suspend ordinary democratic processes in the international trade area.","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"57 1","pages":"451"},"PeriodicalIF":1.5,"publicationDate":"2001-10-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"76474283","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Fear of Commitment in International Bankruptcy","authors":"Frederick Tung","doi":"10.2139/SSRN.277394","DOIUrl":"https://doi.org/10.2139/SSRN.277394","url":null,"abstract":"This article discusses the difficult questions of conflict and cooperation among national bankruptcy regimes that arise with the failure of a multinational firm. The firm's failure typically leaves assets and unpaid creditors in several jurisdictions, but no overarching international bankruptcy system exists. Instead, the national bankruptcy laws of several states might plausibly apply to the firm's bankruptcy or particular aspects of the case. Though multinational firm failure has become more and more common, states have made precious little progress in regularizing coordination or cooperation among national bankruptcy systems. Uncoordinated territorial competition is the norm, resulting in complex conflicts of law. Scholars and policymakers alike have demonstrated renewed interest in international bankruptcy cooperation. Among academics, the idea of universalist cooperation has long dominated the debate over international bankruptcy reform. Under universalism, the bankruptcy regime of the debtor's home country would govern worldwide. Home country courts applying home country law would exercise extraterritorial jurisdiction to treat all the debtor's assets and creditors wherever located. Despite the academic preference for universalism, however, no universalist arrangements exist in the world. In this article, Professor Tung explores states' reluctance to commit to universalism. While recent scholarly critique of universalism has focused on its hypothetical efficiency, Professor Tung instead discusses political feasibility constraints, an issue that universalist advocates have largely failed to consider. Professor Tung compares the universalist demand for recognition of foreign bankruptcy proceedings with the more straightforward matter of civil judgment recognition. He relies on existing international judgment recognition arrangements as a rough barometer of states' cooperative inclinations with respect to bankruptcy recognition. Jurisdictional limits in the former area suggest even greater reluctance to accede to the broader deference required under universalism, forecasting dim prospects for its widespread adoption. Professor Tung also discusses particular types of states for which universalism may be particularly unattractive. Finally, Professor Tung raises the question whether universalism is even possible among states that might prefer it. Assuming states exist that find universalism attractive, they might find themselves in a prisoners' dilemma, for which ready solutions may be elusive. Prepared for the symposium on Global Trade Issues in the New Millennium at The George Washington University Law School (September 2000).","PeriodicalId":47068,"journal":{"name":"George Washington Law Review","volume":"33 1","pages":"555"},"PeriodicalIF":1.5,"publicationDate":"2001-06-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"87111649","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":3,"RegionCategory":"社会学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}