With year-end approaching, it's time for businesses to proactively plan for and execute on tax opportunities to help ease their 2025 tax burden. New this year is the One Big Beautiful Bill Act (OBBBA), which contains numerous tax law extensions as well as new provisions that may be impactful. Businesses, in tandem with their tax advisers, can take advantage of a variety of opportunities highlighted throughout this guide.
Dig deeper into planning surrounding accounting methods, tax deductions, business incentives and tax credits, international tax, transaction planning, real estate considerations, and state and local tax. Each section offers practical perspectives to help you make informed year-end tax decisions.
Contact Ray Polantz, Robert Venables or a member of your Cohen & Co service team to discuss this topic further.
Accounting Methods
Changing accounting methods can result in either immediate tax savings or permanent tax benefits. Some accounting methods can be established or changed when a taxpayer files its annual tax return, either through elections or automatic method changes. Other changes must be applied for prior to year-end of the tax year for which they will be effective.
Inventory
The costs of inventory will generally be expensed as that inventory is sold or otherwise disposed of. However, by using various inventory methods, taxpayers may be able to accelerate the deduction to an earlier tax year.
Inventory typically represents the largest cost for many businesses and, therefore, represents the largest potential tax deduction. The choice of inventory methods and how inventory will be accounted for will directly affect the cost of goods sold calculation, which will impact taxable income.
Lower of Cost or Market
Business taxpayers with inventory can generally value that inventory either at cost or the lower of cost or market (LCM). A taxpayer using the LCM method can value ending inventory at the market value when that is lower than cost. For these purposes, market value equals the replacement cost of the inventory.
Inventory Write-Offs
Business taxpayers often carry inventory that is obsolete, unsalable, damaged, defective or no longer needed. For financial reporting purposes, inventory is generally reduced by reserves, but for tax purposes a business normally must dispose of inventory to recognize a loss, unless an exception applies. Taxpayers may benefit from a change in their inventory identification and valuation methods to accelerate the related deduction and reduce ending inventory. Taxpayers who dispose of or scrap the inventory by year-end can accelerate the deduction into the current year.
Uniform Cost Capitalization
Certain business taxpayers are required to capitalize specific overhead costs into inventory under the uniform cost capitalization (UCC) rules. These capitalized costs are deducted through cost of goods sold, delaying the deduction of the capitalized costs. Some business taxpayers may be overcapitalizing those overhead costs through their UCC calculation. Costs that might be eligible for immediate expensing include selling expenses and certain warehousing expenses, such as pick-and-pack labor costs. Small taxpayers, those with average gross receipts less than $31 million for the three years ending prior to tax year 2025, are generally exempt from these provisions.
Bad Debts
Business taxpayers often decrease business account receivables by booking a nondeductible reserve for financial statement purposes. Taxpayers may change their method of accounting to deduct wholly worthless and partially worthless debts to the extent specific bad debts are identified. By identifying specific bad debts prior to year-end, a taxpayer should be entitled to a deduction. The taxpayer may be able to complete this process after year-end if the write-off is reflected in the year-end financial statements.
Prepaid Expenses
Business taxpayers typically record prepaid expenses as assets on the balance sheet, and their value is expensed over time as the benefit is received. Taxpayers may have an opportunity to currently deduct some of the expenses they prepay, rather than capitalizing them. Prepaid expenses for which payment is considered economic performance, such as insurance, software maintenance and taxes, are generally deductible if they are fixed and determinable at year-end and the related benefits occur within 12 or fewer months. Identifying which prepaids are eligible for an immediate deduction under the tax rules can help companies determine whether to make certain prepayments before year-end.
Year-End Compensation
Accrual basis taxpayers may be able to deduct accrued compensation items, such as bonuses, commissions, vacation or severance pay, in the current year if the:
- Liability is fixed and reasonably determinable at year-end,
- Employee has performed the services, and
- Payment is made within 2 ½ months after year-end.
Any compensation contingencies existing at year-end will cause the liability to not be fixed and determinable, and therefore not deductible in the current year. Taxpayers should consider taking steps to fix bonus and other compensation liabilities at year-end, such as a board resolution or other formal policy that establishes a fixed compensation amount to be paid to employees.
Our Take: Accrual basis employers who meet the related requirements can deduct accrued but unpaid bonus amounts while the employees will report the income in the following year. This does not apply to related party accrued wages, which are not deductible until paid.
Tax Deductions
Qualified Business Income Deduction
The Section 199A qualified business income deduction (QBID) provides for a deduction equal to 20% of qualified business income (QBI), subject to certain limitations. The OBBBA permanently extended this 20% deduction, which was previously set to expire for taxable years beginning after December 31, 2025. Eligible taxpayers include individuals, trusts and estates who are partners in partnerships, (including certain LLC members), S Corporation shareholders and sole proprietorships.
Generally, QBID applies only to qualified business income earned by a qualified trade or business (QTB). Any trade or business besides those meeting the definition of a specified service trade or business (SSTB) will be considered a QTB. An SSTB is any business in the fields of health, law, accounting, consulting, performing arts, trading, financial services and others in which the principal asset is the reputation or skill of one or more of its employees or owners. Despite being categorized as an SSTB, related income could still qualify for the QBID if the owner’s income is below certain threshold amounts.
For SSTBs, the deduction will begin to phase out once income exceeds $394,600 (married filing jointly) or $197,300 (all others). For non-SSTBs, if owner income exceeds either $544,600 (married filing jointly) or $272,300 (all others), the QBID is limited to the lesser of: 20% of QBI, or 50% of W-2 wages paid by the business, or the sum of 25% of W-2 wages plus 2.5% of the unadjusted basis of qualified property. As a result of these limitations, maximizing this deduction requires careful planning.
2025 Sec. 199A Deductions
| Tax Filing Status | Deduction | Taxable Income Phase-Out Range |
|---|---|---|
| Married filing jointly | 20% | $394,600 - $544,600 |
| Others | 20% | $197,300 - $272,300 |
SSTBs: The deduction is fully available below the lower threshold, proportionally reduced within the phase-in range and fully disallowed above the upper threshold.
Non-SSTBs: For taxpayer with taxable income above the upper threshold amount, the deduction is limited to the lesser of 20% of QBI, or 50% of W-2 wages paid by the business, or the sum of 25% W-2 wages plus 2.5% of the unadjusted basis of qualified property.
Accelerated Depreciation Provisions
Bonus Depreciation
Taxpayers have historically been able to claim additional first-year depreciation on the purchase of certain eligible assets. This additional depreciation has historically been as high as 100%, although it has been decreasing in recent tax years. The OBBBA permanently extended the bonus depreciation deduction and increased the first-year depreciation percentage to 100% for property acquired and placed in service on or after January 19, 2025.
Sec. 179 Election
Sec. 179 first-year depreciation has historically allowed taxpayers to immediately expense eligible purchases up to a certain dollar amount. The OBBBA increased the expensable maximum amount under Sec. 179 to $2.5 million, reduced dollar-for-dollar by the amount the cost of qualifying property exceeds $4 million. Annual inflation adjustments will occur for years after 2025.
Our Take: Qualified improvement property (QIP) is interior improvements made to a nonresidential building after the date the building was placed in service. Expenditures attributable to the enlargement of a building, elevators or escalators, or the internal structural framework of the building are excluded. QIP has a 15-year MACRS recovery period and qualifies for both Sec. 179 expensing and bonus depreciation.
Sec. 163(j) Interest Expense Limitation
The 2017 Tax Cuts and Jobs Act (TCJA) imposed a limitation on the deduction of business interest expense. Specifically, Sec. 163(j) limits a taxpayer’s deduction of business interest to the sum of:
- Business interest income,
- 30% of adjusted taxable income, and
- Floor plan financing interest.
There are exceptions and exemptions, including one for small taxpayers if their average annual gross receipts for the prior three years do not exceed $31 million (for tax years beginning in 2025.)
Our Take: The current interest rate environment has increased the cost of carrying or acquiring new debt for many businesses. Sec. 163(j) can further increase the cost of financing by limiting the deduction for net business interest expense.
Due to the changes brought about by the OBBBA, the Sec. 163(j) calculation is now based on an adjusted taxable income figure before depreciation and amortization. Taxpayers can now maximize accelerated depreciation provisions without compromising the deductibility of their interest expense.
Additionally, a new OBBBA ordering rule eliminates the planning strategy of capitalizing interest to inventory or other balance sheet accounts to lower the Sec. 163(j) disallowance. The OBBBA requires the Sec. 163(j) limitation to be considered before the application of other capitalization provisions.
Charitable Contributions
A C Corporation’s charitable deduction is limited to 10% of its taxable income in the current year. This income figure is calculated before taking the charitable deduction itself and before considering any net operating loss (NOL) carryforwards. If a C Corporation’s donations exceed the 10% threshold, the excess amount can be carried over for the next five tax years. For tax years beginning after December 31, 2025, the OBBBA imposes an additional limitation on charitable contributions of C Corporations in the form of a 1% floor. The amount of a corporation’s charitable contributions is reduced by 1% of the corporation’s taxable income.
Our Take: Because the 1% floor does not take effect until 2026, C Corporations should consider accelerating future planning charitable contributions to 2025 to avoid this floor.
Vehicle Tax Deductions
Standard Mileage vs. Actual Costs
Business taxpayers have two primary options for deducting automobile costs:
- Standard Mileage Rate Method: Under this “cents-per-mile” method, the amount of business miles driven is multiplied by the IRS standard rate for the year. For 2025, this amount is 70 cents per mile.
- Actual Expense Method: This method allows taxpayers to deduct the business-use portion of actual expenses, including fuel, repairs, insurance, registration, lease payments and depreciation.
Our Take: The main advantage of the standard mileage rate method is its simplicity. A business taxpayer will only need to maintain mileage records. The cents-per-mile amount is intended to include amounts for depreciation, fuel, maintenance and insurance.
Vehicle-Related Depreciation
Businesses can take advantage of Sec. 179 and/or business depreciation for purchases of new or used vehicles used more than 50% for business purposes. Different provisions may limit the current deduction amount. Below are the 2025 deduction limitations:
- Passenger Vehicles (less than or equal to 6,000 lbs. gross vehicle weight rating (GVWR): Sec. 179 and/or bonus depreciation can be taken, but luxury auto limitations will apply. For 2025, the first-year limit is $12,200 (without bonus depreciation) or $20,200 (with bonus depreciation).
- Heavy SUVs, Trucks and Vans (6,001 – 14,000 lbs. GVWR): Sec. 179 depreciation is available, but the amount is limited to $31,300 per vehicle for 2025. Bonus depreciation can be taken on the excess amount.
- Very Heavy Vehicles (greater than 14,000 lbs. GVWR): Full Sec. 179 depreciation is available, along with bonus depreciation.
Accounting for Personal Use
If a vehicle is used for both business and personal purposes, only the business use portion is generally deductible. For this reason, when employees use company vehicles personally, the value of that use is considered a taxable fringe benefit and must be included in their income to be deducted by the business. The IRS permits this calculation to be done using either of the following methods:
- Annual Lease Value (ALV) Method: Uses a vehicle’s annual lease value as the fair market value of the total annual use of a company vehicle to determine the amount. The ALV value is determined from an IRS table.
- Cents-Per-Mile Method: Uses the annual IRS rate to determine the amount.
Research and Development (R&D) Expenses
Historically, many taxpayers were able to deduct certain R&D expenditures. However, the TCJA amended the rules for R&D costs incurred for tax years beginning after December 31, 2021. Most recently, R&D costs were required to be amortized over five years if performed in the U.S., or over 15 years if performed outside the U.S.
The OBBBA changed these rules and allows taxpayers to immediately deduct domestic R&D expenses paid or incurred in the tax year beginning after December 31, 2024. Expenses for R&D performed outside the U.S. must still be capitalized and amortized over 15 years.
A special election permits taxpayers to accelerate the deduction for capitalized, but unamortized, costs over a one- or two-year period, starting with their first tax year beginning after December 31, 2024. These costs are generally those capitalized for the 2021 through 2024 tax years.
Our Take: Taxpayers should carefully consider whether or not to deduct unamortized R&D costs over the one- or two-year period. To maximize the related tax benefits, consideration should be given to a taxpayer’s effective tax rate and other tax attributes.
Business Incentives & Tax Credits
Sec. 1202 Qualified Small Business Stock Exclusion
Sec. 1202 provides a tax incentive for investors in select small businesses by allowing certain shareholders to exclude federal capital gain from the sale of Qualified Small Business Stock (QSBS).
The investor must acquire the stock directly from the company in exchange for money, property, or services and hold it for more than five years to qualify for the 100% gain exclusion (for stock acquired after September 27, 2010).
The OBBBA made several changes to the Sec. 1202 provisions that expand the benefits to a wider range of investors. Current rules now allow partial exclusions on three-year (50%) and four-year (75%) holding periods, in addition to 100% exclusion after five years. The OBBBA also increased the aggregate gross asset threshold to qualify as a “small business” from $50 million to $75 million. It also raises the lifetime cap on excluded gains per issuer from $10 million to $15 million or 10 times the adjusted basis of stock.
Sec. 1202 Gain Exclusions
| Holding Period | Gain Exclusion |
|---|---|
| 3 Years | 50% |
| 4 Years | 75% |
| 5 Years | 100% |
Our Take: Given the expanded benefits now available, taxpayers should consider structuring into an eligible corporation to qualify for Sec. 1202 benefits. When considering such conversions, it is important to consider all the tax and economic consequences that occur after the conversion and throughout the life of the investment, including eventual disposition.
R&D Credit
The R&D tax credit is available to companies developing new or improved business components, including products, processes, computer software, techniques, or formulas that result in new or improved functionality, performance, reliability or quality. There are several different methods for calculating this credit, and facts and circumstances will determine the most appropriate method.
Our Take: Prior to the OBBBA, taxpayers were required to capitalize and amortize R&D costs. Some taxpayers may have been hesitant to claim the R&D tax credit due to the R&D cost capitalization requirement, even though this capitalization requirement was independent of the credit provisions and applied regardless of whether or not a taxpayer claimed the R&D tax credit. Because of this hesitation, many businesses who qualify for the R&D tax credit may not be currently claiming it.
IC-DISC for Exports
Businesses who manufacture or distribute U.S. goods for export, or foreign architectural, engineering or managerial services, may be entitled to tax savings by implementing an Interest Charge Domestic International Corporation (IC-DISC) structure.
A taxpayer that has established an IC-DISC is permitted to pay and deduct a commission to the IC-DISC that is calculated based on qualifying exports and the related net income. This deduction is considered an ordinary deduction whose tax value may be as high as the highest marginal income tax rate of the business. The receipt of the commission is tax-free to the IC-DISC, and when the commission amount is distributed as a dividend payment, it qualifies for the preferential capital gain tax rates.
Our Take: Because the foreign-derived intangible income deduction (FDII) is only available to C Corporations, the IC-DISC is one of the only income tax benefits available for export income of pass-through entity and individual taxpayers.
International Tax
GILTI Regime
The global intangible low-tax income (GILTI) regime is designed to discourage U.S. multinational companies from shifting profits to low-tax jurisdictions. It requires an annual income inclusion for U.S. shareholders of certain foreign corporations and is intended to capture excess returns on foreign corporation intangible assets (even though it applies broadly to all income). The effective corporate tax rate on GILTI has been 10.5%, which is achieved through a 50% allowable deduction.
The OBBBA increases the effective corporate tax rate on GILTI to 12.6% for tax years beginning after December 31, 2025, by reducing the allowable deduction from 50% to 40%. The related foreign tax credit limitation is increased from 80% to 90%.
The bill also eliminates the net deemed tangible income return (NDTIR), which had allowed a 10% return of qualified business asset investment (QBAI) to be excluded. With that removal, GILTI now captures all income, including income from tangible assets, and is renamed “net CFC tested income” to reflect this broader base.
Global Intangible Low-Taxed Income*
| Tax Year | Sec. 250 Deduction | U.S. Effective Tax Rate | NDTIR Exclusion | Foreign Tax Credit Limit | Effective Foreign Tax Rate to Eliminate U.S. Residual Tax |
|---|---|---|---|---|---|
| 2025 | 50% | 10.5% | 10% QBAI | 80% | 13.125% |
| 2026 and beyond | 40% | 12.6% | N/A | 90% | 14% |
* For 2026 and beyond, renamed to “net CFC tested income” (NCTI).
FDII Deduction
The FDII deduction incentivizes domestic corporations by providing a tax deduction for income derived from providing tangible and intangible products and services to foreign markets. For 2025, a corporation can claim a 37.5% deduction, which results in a 13.125% effective tax rate.
The OBBBA brought about changes to this deduction effective for tax years beginning after December 31, 2025. The requirement to reduce deduction eligible income by 10% of the qualified business asset investment (QBAI) is eliminated. With this change, FDII now includes returns from tangible assets and is renamed “foreign-derived deduction eligible income” (FDDEI), reflecting both the broader base and the shift away from intangible returns. In addition, the deduction will be 33.34% for tax years beginning after December 31, 2025, equating to a 14% effective tax rate on eligible export income.
Foreign Derived Intangible Income*
| Tax Year | Sec. 250 Deduction | NDTIR Reduction | Effective Tax Rate |
|---|---|---|---|
| 2025 | 37.5% | 10% QBAI | 13.125% |
| 2026 and beyond | 33.34% | N/A | 14% |
* For 2026 and beyond, renamed to “foreign derived deduction eligible income” (FDDEI).
Avoiding Accidental Permanent Establishments
Taxpayers who are doing business in foreign countries are potentially liable for local income tax for the income earned in that foreign country. For countries with which the U.S. has an income tax treaty, a fixed place of business (or permanent establishment) must exist to create an income tax liability. The presence of an office or other building has traditionally created a permanent establishment. However, employees exercising the authority to conclude contracts will often create a deemed permanent establishment. U.S. businesses should evaluate their business activity outside the U.S. to determine if the activity has unintentionally created a permanent establishment and a local country income tax liability.
Our Take: For countries in which the U.S. does not have an income tax treaty, a very low level of activity could potentially create a taxable presence. Notable countries that do not have an income tax treaty with the U.S. include Argentina, Brazil, Hong Kong, Taiwan and Vietnam.
Transaction Planning
The gain from the sale of a business can be taxed in different ways for tax purposes, depending on the structure of the deal. A buyer generally prefers to purchase assets because it can avoid assuming certain target company liabilities and is permitted to step-up the basis of assets, which can lead to increased depreciation and amortization. On the other hand, a seller often prefers an equity sale because some or all the gain can be taxed at preferential capital gain rates. Certain tax provisions will allow for an equity sale for legal purposes and an asset sale treatment for income tax purposes. The way the transaction is structured — whether as an asset or equity sale — can significantly impact the tax paid on the transaction.
Real Estate Considerations
Interest Expense Limitation and Real Property Trade or Business Exception
The Sec. 163(j) interest expense provisions may limit a taxpayer’s ability to deduct current year business interest expense. This can be especially problematic for real estate taxpayers who incur interest expense but may have little taxable income (often due to the accelerated depreciation provisions). There is a real property trade or business exemption available that will affect future depreciation but may ultimately reduce the tax burden imposed by the Sec. 163(j) limitation.
Cost Segregation Studies
A cost segregation study will appropriately categorize business property across a variety of often shorter asset class lives, which often results in accelerated depreciation deductions. Cost segregation studies on new development or renovations to existing real property often can reduce both federal and state tax and therefore increase cash flow.
Our Take: The potential benefits of a cost segregation study may be enhanced since the OBBBA increased bonus depreciation to 100% for property placed in service on or after January 19, 2025. Furthermore, the OBBBA changes to the Sec. 163(j) interest expense provisions may allow taxpayers to increase depreciation deductions without fear of worsening their Sec. 163(j) interest expense calculation.
Revisit Repair Regulations
Real property owners can take advantage of immediate expensing if improvement costs are considered repairs rather than betterments, restorations or adaptations, which generally are required to be capitalized.
Write-Off of Abandoned Project Costs
During the pre-development phase of a property, real estate developers can incur significant costs related to engineering, architecture and other services. If projects are abandoned, they may be eligible for immediate write-off.
Qualified Opportunity Zones (QOZs)
The TCJA established an opportunity for taxpayers with capital gains to potentially defer these gains if they reinvest in a Qualified Opportunity Zone (QOZ). The qualifying capital gain is deferred until the investment is either sold or exchanged, or December 31, 2026, whichever is earlier. The OBBBA makes the QOZ program permanent but with several changes, including narrowing the definition of “low-income community.” These changes generally take effect January 1, 2027.
Our Take: Taxpayers interested in taking advantage of this opportunity but cannot directly invest in a QOZ may have the ability to invest in a fund that is investing in a QOZ.
Qualified Opportunity Zone (QOZ) Program
| Feature | Old Law (Pre-OBBBA) | New Law (Post December 31, 2026) |
|---|---|---|
| Program duration | Expires December 31, 2026 | Permanent |
| Zone designations | One-time (2018) | Every 10 years |
| Deferral period | Until December 31, 2026 | Rolling 5-year periods |
| Basis step-up | 10% (5 years), 15% (7 years) | 10% (5 years) only |
| Rural benefits | None | 30% step-up, reduced thresholds |
| Reporting requirements | Limited | Mandatory with penalties |
| Exit benefits | 100% exclusion (10+ years)* | 100% exclusion (10–30 years max) |
* Maximum holding period cannot go beyond December 31, 2047.
State & Local Tax
State Income Tax Conformity with Changing Federal Legislation
State conformity with federal provisions varies widely by state. Some automatically conform to federal tax law changes, while others must enact specific legislation to adopt the federal law changes. Historically, when federal tax provisions have changed, many states ultimately indicate whether or not they will conform. Businesses should continue to monitor 2025 and 2026 state legislation around tax conformity with federal changes, such as from the OBBBA, that could materially impact state tax liability.
Sales/Use Tax
In many states, sales of tangible property are subject to sales tax, unless an exception exists. Services have traditionally been classified as nontaxable; however, more states are expanding the taxation of certain services and digital purchases. It is important businesses create policies to identify purchases that are taxable versus exempt to help ensure they are not under or overpaying their sales/use tax liabilities.
Many sales tax exemptions require the seller to collect and maintain valid exemption certificates. It is imperative businesses create procedures identifying when they are required to collect sales tax on taxable sales and a process to collect and manage exemption certificates. To the extent that has not occurred, the business has potential exposure if selected for a state tax audit.
Nexus Considerations
State tax nexus has become increasingly more complex since the Wayfair decision and in the wake of increased remote work. Wayfair, while intended for sales tax, has affected nexus standards for state and local income tax, attempting to remove the physical nexus test for filing determinations and applying economic nexus standards in numerous jurisdictions.
In addition to Wayfair, we saw many businesses shift to hiring more remote employees, post-COVID, which has complicated state tax filings for employers. Employers must not only analyze payroll tax responsibilities within each jurisdiction but also consider the activities of each remote employee to understand when a state or local income tax filing may be required. Remote work may impact statutory credits and/or negotiated incentives. These benefits are often tied to the creation or retention of jobs within a particular jurisdiction, and businesses must analyze the tax impact of a shifting workforce.
State tax nexus studies have become an increasingly important tool in tax planning and risk mitigation. Nexus studies not only help taxpayers understand their filing requirements, but also assist with identifying and remedying exposure in prior periods and necessary additional filings.
Our Take: Public Law 86-272 is a provision that generally limits income tax nexus for businesses whose employees are soliciting sale of tangible personal property. Companies should pay close attention to the job responsibilities of remote employees, because the remote approval of orders or the performance of services could negate a company’s existing PL 86-272 protection.
Pass-Through Entity Tax (PTET)
The TCJA limited the deduction for state and local tax payments on personal income tax returns. In response to this limitation, many states have adopted PTET legislation, which allows pass-through business entities to elect to pay and deduct state income taxes.
The individual shareholders and partners effectively deduct the state taxes by recognizing lower pass-through income, thereby avoiding the TCJA limitation. State PTET election, payment and filing requirements vary widely in those states that offer this opportunity. Business owners should carefully consider their tax position in each jurisdiction prior to year-end to determine if a federal tax benefit exists.
Our Take: Even though the OBBBA increased the state and local tax deduction to $40,000 for individual taxpayers, many will continue to benefit from participating in PTET returns if state and local deductions continue to exceed even the increased limitation amount. For taxpayers with adjusted gross income (AGI) above $500,000, this increased deduction will phase back down to the historical $10,000 amount.
Conclusion
The takeaway message for year-end tax planning is to be proactive. The tax code, including provisions in the recently passed OBBBA, offers businesses numerous tax savings opportunities. Tax efficiency does not often occur by chance; rather, taxpayers and advisers deliberate in their tax planning approach can enjoy the most tax savings. Work with your tax advisers now and throughout 2026 to proactively manage tax obligations and work toward achieving substantial savings that can positively impact your bottom line.
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Thank you to Jon Dittrich, James Kaptur, Ray Polantz, Hannah Prengler, Dave Sobochan and Robert Venables for contributing to this publication.