The past week has been a predictably intense one. The Treasury consultation paper, “The new research and development tax incentive”, has attracted widespread comment, concern and criticism. Some have seen the paper as the harbinger of the end of effective government support for R&D. Others believe that the consultation process is illusory and that the decisions have already been made. MJA has a more tempered view. And it’s a view based on direct dealings with government over the past week.

Kris Gale, Managing Director of MJA, has met with the Treasury and Innovation, Industry, Science and Research officials nominated as the contact points for the consultation process. He is booked in to meet with Senator Carr’s office on Monday, 28 September. He has presented on the topic to three conferences in the last 7 days. Contact has been made with several industry advisory bodies and all members of MJA have been canvassing client companies and other interested third parties for their reactions and views. The month of October will see this program of active engagement continue apace.

Has any good news emerged?

The answer is yes.

The Government officials will reassure stakeholders at the announced public consultation sessions (see details below) that the paper is truly a discussion paper and that the exposure draft of the legislation will take submissions and commentary into direct account.

They have acknowledged that the delay in issuing the paper has placed pressure on the timetable for the delivery of the new legislation and allowances will need to be made. They indicated that the main source of the delay was the fact that the paper spent considerable time in the offices of Senator Carr, Mr Swan and Mr Rudd and that this is a reflection of real ministerial engagement.

Assurances were also given that the ‘additionality and spillovers test’ referred to in Paragraph 48 of the paper will not translate into a legislative requirement and that this will be confirmed at the consultation sessions. Further metrics around the issues raised such as the meaning of a revenue neutral program over the next 4 years will also be provided.

Finally, it is now clear that the Refundable Tax Credit will be available to foreign-owned R&D in contrast to its announced preclusion in the May Budget.

So what is the Big Issue in the paper?

Without doubt, the main concern raised by the paper was the announcement of the fact that the definition of R&D will be changed in order to reduce the expenditure available to be claimed against the Credit. This was deemed necessary to achieve budget outcomes and justified on a policy basis of focusing support on the areas of highest net benefit and redirecting support to the SME sector.

In announcing the changes, the paper curiously made use of the “old school” terminology of core (cf. SIE) and supporting (cf. directly related) activities. It was indicated that core activities will need to contain innovation AND technical risk, rather than just one of these elements. Further, limitations are to be brought in with respect to supporting activities and the paper sought responses to a suggested list of possible restrictions.

In the next fortnight, MJA will circulate its draft response to the paper which will analyse our concerns with this ‘Big Issue’ in detail. However, we would like to take this opportunity to sound the alarm now.

The Government announced on Budget night that the R&D Tax Credit will replace the “complex and outdated” R&D Tax Concession with a

“…simplified R&D Tax Credit which cuts red tape and provides a better incentive for business to invest in research and innovation.”

The Issues Paper makes the case for the Credit delivering a simpler program by highlighting the following:

 “Paragraph 9.….Companies will no longer need to distinguish between their base and incremental expenditure on R&D in working out their claim.”

Yet, under the proposed changes, companies will have to distinguish between their core and supporting activities in working out their claim with the direct result of a restricted level of support for supporting activities.

So much for a simpler R&D tax program. Changing the definition of R&D will, by the few strokes of a pen, introduce an unprecedented level of complexity, attendant uncertainty and compliance burden into the program.

The case for definitional change is simply not made out in the paper. No concrete evidence is given. The very thin examples in Attachment A are misleading in their conclusions. No modelling is being offered up to amplify the cost concerns. Given these factors, MJA believes that the Big Issue needs to be thoroughly explored with relevant stakeholders as soon as possible.

If cost control is the political outcome required, MJA believes that the real focus needs to be on reviewing expenditure provisions. Changing the well understood, internationally competitive definition of business R&D will cruel the prospects of all companies involved, whatever industry they are in and whatever their size. In fact, it will be the technology-intensive SMEs who will be hit the most as they are the companies that spend large proportions of their operating budgets on R&D compared with the mature sectors who have the largest claims in numerical dollars but modest claims in terms of proportions of  overall operating cost.

It is well known that Australia currently sits on the lower end of OECD Business Expenditure on Research and Development (BERD) comparisons. Changing the definition of claimable R&D along the lines proposed means that we should be expecting snakes not ladders in our BERD future.

MJA will continue its campaign of direct liaison with the Government to explore the issues raised and work towards a negotiated result that promotes a sensible outcome for business innovation policy.

But what can I do?

Make time to attend the upcoming public consultations. Details are below and bookings can be made through the following link Bookings

Make a submission. It doesn’t have to be a treatise. It does need to express the concerns that you have and it should set out how the proposed changes would affect you, both good and bad. The aim is to be  constructively critical, not destructively so.

In both these matters, don’t rely on your advisers and industry bodies to make all the running this time. You are the Credit’s proposed customers. Your voices are the most influential ones.

And keep talking. Dialogue generates ideas that can then be translated to workable solutions. Please include us in your conversations. We are passionate about effective innovation policy and we would love to hear what you are thinking.

To keep the dabate moving, contact Kris Gale directly on (02) 9810 7211 or using our contact form.

How are we doing?

It’s always helpful to have your feedback on the articles we prepare, and the approach we’re taking in dealings with the government. You can help us by filling out a comment below this post on our website, and giving us any feedback you have on how we’re performing, or how we could improve.

The New Research and Development Tax Incentive

The first thing to note is that the paper, entitled “The new research and development tax incentive”, has been issued by the Treasury. This is a big surprise as Treasury officials did not attend the consultation sessions on the R&D tax concession held last year as part of the National Innovation Review. Furthermore, the two pre-consultation sessions held in June this year were headed up by a representative of the Department of Innovation, Industry, Science and Research rather than a Treasury official.

The impression that Treasury has taken control of the process is reinforced by the fact that responses to the paper, due by Monday, October 26, are to be submitted to the Business Tax Division of the Treasury. This is all a great worry. Is it now the case that the destiny of the Federal Government’s flagship innovation program is no longer in the hands of the government department actually responsible for innovation? This matter will need to be pursued with vigour. The process is subject to a tight timeframe as draft legislation is mooted by the end of the year.

The paper itself is an odd amalgam of decisions apparently already made and areas for discussion where there is no guidance as to what the thoughts of the authorities actually are. It includes a series of unsubstantiated assertions about the operation of the current R&D tax concession and betrays an extremely poor understanding of how business R&D (BERD) occurs. It is easy to get carried away by the disappointing quality of the paper’s analysis and it will predictably attract a firestorm of criticism from the business community with regards to the number of restrictions to eligible activities and expenditures that the Treasury appears to be advocating.

However, now is not the time to panic.

Firstly, there a number of positives to reflect on:

• Increased rates of benefits
• Removal of the complexities associated with the premium
• Extension of the rebate concept
• More generous provisions relating to overseas R&D
• Allowing foreign ownership of generated IP
• Improvements to R&D software rules

Achieving Workable Outcomes

Secondly, the huge concerns raised by the discussion regarding ‘Eligible R&D activity’ in the report need to be vented but then channelled into achieving workable outcomes. The Government needs to be reminded of the main policy game here – improving Australia’s overall R&D effort. There is a need to learn from the lessons from 1996 where the Coalition’s introduction of significant reductions to the R&D Tax Concession led to a collapse of Australia’s BERD over the next 5 years. We are already behind our competitors. Unnecessary restrictions will run the risk of Australia dropping off the back of the pack.

Businesses and Stakeholder Organisations to Have Their Say

Finally, the consultation process must be approached as a real opportunity to turn around the poor performance of the administration in program delivery in recent years. The new Credit, however defined, will fail if it is delivered by the same administrative mindset currently associated with the R&D Tax Concession. The experiences of taxpayers need to be submitted directly to the authorities so that this message is clearly heard.

MJA will be working with its clients, industry bodies and other interested parties to ensure that all the relevant issues are raised in the consultation process. We would be delighted to assist you in this regard in whatever manner you deem appropriate.

To discuss the matters raised in this MJA Update in greater detail, please contact Kris Gale on (02) 9810 7211 or using our contact form

How are we doing?

It’s always helpful to have your feedback on the articles we prepare, and the approach we’re taking in dealings with the government. You can help us by filling out a Comment below this post on our website, and giving us any feedback you have on how we’re performing, or how we could improve.

Most Significant Outcome of the Sessions

The consultation is being headed by a team organised by the Department of Innovation, Industry, Science and Research (DIIRS). MJA has been given an explicit invitation to supply the names and contact details of all interested parties who would like to be involved in the planned face-to-face meetings that will form part of the consultation process. We have direct access to the team leader, Tony Weber, who has agreed to respond personally to all such requests. Please contact Kris Gale using our contact form if you would like to be included in the list of organisations that would like to participate.

The following is a summary of the main aspects of the sessions.

Legislation Timetable

July 2009                                 Release of consultation paper

Winter/Spring 2009                   Release of draft legislation

February 2010                          Bill released into Parliament

1 July 2010                              Program commences

Attendees

The meetings were chaired by Tony Weber of DIISR. Peter Thomas, the Chair of the Tax Concession Committee of the Innovation Australia Board, was also in attendance along with officials from AusIndustry, the Australian Tax Office and Treasury.

Over the two sessions, three companies, five industry associations and six advisory firms were involved. This is a small representation and it is to be hoped that a broader cross-section of views is canvassed following the release of the discussion paper.

Summary of Discussion

The Credit will be placed in the 1997 Tax Act.

The government has directed that the program be drafted so that it is simpler and more predictable than the current R&D tax concession. The government also directed that, to keep the new program revenue neutral at a cost of $1.4 billion per year for the medium term, the eligibility criteria need to be “tightened” in order to support only “genuine” R&D.

It was agreed that ‘revenue neutral’ really means ‘kept at the same cost’.

Four approaches are being considered:

• Rewriting/fine tuning the definition of R&D activities
• Extending the concept of expenditure offsets
• Introduction of special sectoral rules
• Introduction of various forms of claim caps.

A key theme of the discussions concerned whether this exercise should be carried out from first principles (i.e. a “clean sheet of paper”) or a reshaping of the existing tenets of the R&D tax concession. A strong consensus emerged from non-government attendees that the latter is preferable. The strongest theme from the floor was that the major strength of the current program was the relative stability of the definition of R&D and that this should not be unnecessarily altered.

The main conclusions that emerged appear to be as follows:

Sectoral rules and claim caps are unlikely to fly.

Definitional change is hard to achieve in terms of the key concepts. Explicitly excluding certain activities was seen as a preferable way to go.

Considerable discussion focused on the SIE/directly related meanings and differences. The attendees fed back to government that the easiest place to rule out “non-genuine” R&D activities is in the list of excluded activities. The hope was expressed that the discussion paper will provide such a list for specific comment and response. The concern was expressed that the negative statements contained in the Cutler Report regarding mining and heavy engineering in terms of “whole of mine ” claims and receipt of “disproportionate assistance” has greatly unsettled the current program. The paper needs to detail what are the real concerns, beyond the numerical dollars involved, that the government harbours about this R&D. If it is truly non-genuine, reasons need to be given.

The extension of the current feedstock expenditure offset definitely appeals to the policy makers.

There is a battle to be fought here. It appears that this is seen as the best way to restrict R&D claims conducted in the production environment by large organisations. The group pointed out that the current offset (introduced in 1996 for political reasons) applies to expenditure on eligible R&D activities, genuine R&D if you will, under the Act. Further incursions may lead to a program that incentivises only R&D that is not seen as likely to commercialise as companies will not ultimately access the incentive in production trials except in the (hopefully) rare instances of technical failure.

A wide range of other issues was canvassed in the two meetings. These included unlimited amendment powers, guaranteed returns provisions, on own behalf provisions, R&D planning requirements and program delivery (including an AusIndustry charter).

Conclusion

The more specific the involvement of companies and industry bodies in the post-July consultation, the better.

There is an accumulation of assumptions, assertions and unsubstantiated opinions that the government administrative bodies are bringing to this process that, if not carefully refuted, could easily result in an R&D tax credit that is available on such a restrictive basis that it will fail to impact the R&D planning processes of corporate Australia, particularly in the large company sector. It needs to be remembered that the Top 100 company groups conduct 75% of Australian business R&D expenditure. These corporates will receive a lower rate of support (10 cents) than SMEs (15 cents) under the proposed credit, they are to be excluded from the refundable component and they are to lose the premium component. If the industrial nature and the commercial focus of the support is lost through definitional change or wide-ranging offsets, the damage to Australian corporate R&D culture could be immense.

We look forward to working with you in shaping a truly effective R&D tax credit through the consultation process.

How are we doing?

It’s always helpful to have your feedback on the articles we prepare, and the approach we’re taking in dealings with the government. You can help us by filling out a Comment below this post on our website, and giving us any feedback you have on how we’re performing, or how we could improve.

R&D tax credits to offer higher rates of benefit to broader range of companies

MJA’s Managing Director, Kris Gale, was invited to attend a budget lock down hosted by the Minister for Innovation, Industry, Science and Research, Senator Kim Carr and the Minister for Small Business, Craig Emerson. The highlight was the announcement of a new R&D tax credit system which, along with a range of other initiatives, is a positive  response to the Cutler Report. At the same time, the government released a new white paper, Powering Ideas: An Innovation Agenda for the 21st Century (PDF).

In an overall sense this is a pro-innovation and pro-business budget

In an economic environment that has required some cuts to some government programs, balanced with appropriate stimulus activities, innovation investment has clearly been recognised  for its economic benefits.

The government has announced an R&D tax credit with two levels of assistance:

• a 45% refundable credit for companies with turnover of less than $20 million (we assume that this will be calculated on a group basis, similar to the current R&D tax offset), equivalent to a 150% tax concession; and
• a 40% non-refundable credit for companies with turnover of more than $20 million and for companies with foreign-owned intellectual property arrangements that conduct R&D in Australia. This is equivalent to a 133% tax concession.

Reacting to these announcements, MJA’s managing director, Kris Gale reflected, “in meeting with Senator Carr, he said he wanted an R&D tax program with ‘winners with no losers’, and that’s essentially what’s been delivered.”

R&D tax credit announcements

The new R&D tax credits take effect for income years commencing after 1 July 2010. Of particular significance, the change to an R&D tax credit system means that the rate of support will be decoupled from the corporate tax rate, whether that increases or decreases in future.

In addition, there will be a review of the program eligibility criteria in developing the new legislation and a consultation paper will be released in the next few months. This is a positive process, and we welcome the fact that changes to eligibility were not a part of tonight’s announcements.

One of the strengths of the current R&D definition is that it is based on industrial concepts of R&D. MJA looks forward to working with government to preserve this critical feature of the program. 

Groups with turnover less than $20 million

Where a group’s annual turnover is less than $20 million, companies will be eligible for a 45% refundable credit. This is equivalent to a 150% tax concession which is double the rate of support currently available under the base 125% program. This is a significant increase, as the current refundable offset has a group turnover limit of $5 million, and Aggregate R&D Expenditure capped at $1 million.

For the R&D tax credit the turnover limit has been increased to $20 million, and the cap abolished.

As a transitional measure, for the 2009/10 income year, the Aggregate R&D Expenditure cap will be lifted to $2 million to provide more support and flexibility for organisations that currently do not qualify.

The government estimates that 5,500 firms will benefit under these new arrangements.

Groups with turnover great than $20 million

Where group turnover is over $20 million, companies will be eligible for a 40% non-refundable credit, equivalent to a 133% tax concession, again one-third higher than the current basic rate of support.

Further, companies conducting R&D in Australia where intellectual property rights are held offshore (as for the current international premium R&D concession) will also able to access this credit.

Reform to existing programs

Both the current 175% premium and international premium will be abolished in line with the introduction of the new credit system, and the 2009/10 income year will be the last for claims under those programs. It appears that the government definitely reacted to feedback that these programs were unpredictable, didn’t dramatically influence new projects or provide a compelling reason to locate foreign-owned R&D in Australia.

No new competitive grants

In an overall sense the value of the support under these announcements is approximately $1.4 billion, however there were no new announcements in relation to competitive grants for R&D. Whilst there are initiatives for other areas (Commonwealth Commercialisation Institute and Clean Energy), there is no replacement for Commercial Ready and no commentary on additional funding for Climate Ready.

This means that discretionary grant-based R&D funds for classic projects appear to be at an end under the current government.

What questions do you have?

It’s always helpful to have your feedback on the articles we prepare, and the approach we’re taking in dealings with the government. This is particularly the case with a time-sensitive announcement such as the outcomes on budget night.

You can help us by filling out a Comment below this article on our website, and giving us any feedback you have on this initial summary of innovation policy as it relates to the 2009/10 federal budget.

If you post a question relevant to the area we’ll do our best to answer it in the more detailed analysis we will be preparing over the next 24 hours.

But, no one is present to interpret English to English, or Spanish to Spanish.

Sometimes you need interpretation even in your native tongue

When the Cutler Review of the National Innovation System published its report Venturous Australia in September 2008, one shorthand phrase in the analysis of the R&D tax concession stood out, the reference to ‘whole of mine’ claims. This is what was recommended:

appropriate measures be taken to heavily constrain ‘whole of mine’ and similar claims against the existing R&D Tax Concession program or proposed Tax Credit program.

Unfortunately, from literally interpreting the phrase, many people think they know what ‘whole of mine’ claims are, but the term has no legislative, policy or administrative meaning. In fact, the government has said nothing about the phrase or policy issue at all.

Yet, we have already started to receive questions from AusIndustry on behalf of Innovation Australia as to whether or not particular projects or claims are ‘whole of mine’ claims.

In one case the applicant has been asked why a claimed project is not a ‘whole of mine’ claim, despite the claim being for a very small fraction of one year’s operating costs.

This is the problem of shorthand, and of administrative decision makers interpreting a policy signal from a review  document.

We need to focus on context for interpretation

In our response to the Cutler Review Report we said:

The term, ‘whole of mine’, has recently emerged as a type of shorthand for describing large claims and needs to be removed from the lexicon of the discussion. It adds an emotive element that clouds discussion as to the role that can be played by a tax instrument in innovation policy. A mythology has been built up around these claims that needs to be moved on from in the current debate.

Large claims are definitely made within these industries from time to time but MJA suggests that this is not routinely the case. Our profiling of our client base suggests that large one-off projects are an occasional feature of large, diversified groups such as mining houses and engineering firms. They make up but one component of their substantial, constantly evolving portfolio of innovation activities. Even when they occur, total R&D claims will invariably fall well below 10% of group turnovers in the relevant years.

This context is critically important. Just because large claims are made they do not necessarily demand further scrutiny. Moreover, many smaller companies, including those in the biotechnology, medical research and software sectors routinely have periods of R&D intensity that equal or exceed those of larger firms.

But you don’t hear an outcry about ‘whole of cure for cancer’ claims.

We need to focus on eligible R&D and eligible expenditures

In either case, ‘whole of mine’ or ‘whole of cure for cancer’, what advisers, government assessors and decision makers need to come back to is an assessment of the principles of eligibility of both the R&D being undertaken and the associated, eligible expenditures.

Under the present rules, R&D is neither more nor less eligible for government support because of the size of the expenditure on the project. This is one of the benefits of having the administration of eligibility of activities separated from the administration of the eligibility of expenditures.

Innovation Australia, in looking at the eligibility of activities, should reach the same outcome as to eligibility regardless of the expenditure involved. In fact, the quantum of expenditure should be irrelevant to the decision making process, and the provision of such information should be optional.

Similarly, the ATO should reach decisions as to the eligibility of expenditures without regard to the nature of the R&D activities undertaken. Whether they assume an activity to be eligible or request assessment of eligibility by Innovation Australia, the outcome should be no different for the taxpayer.

We need an end to the innovation policy vacuum

The Minister for Innovation, Industry, Science and Resources has repeatedly said that “in the twenty-first century, innovation policy is industry policy“. To date, though, most of his actions have been around very traditional industry policy areas: automotive; textile, clothing and footwear; and university research.

The current global financial crisis has affected the speed with which a cogent response to the recommendations of Venturous Australia can be prepared. But if we are going to see a ten year innovation policy announcement from the government it’s going to need some level of consultation and analysis.

Ideally, there will be an opportunity to engage on topics that span policy, politics and administration, as a ten year policy will likely need some level of bipartisan, industry and administrative support to be well received and executed.

Most of all we need fair interpretation for program certainty

It is unfair that applicants for the R&D tax concession need to address a loaded and vague term like ‘whole of mine’ when defending their claims.

It is even more unfair when they need to do so because administrative decision makers are interpreting future policy signals from a government-initiated review of the National Innovation System when there is no policy response.

Just imagine if this level of misinterpretation was at work in the United Nations General Assembly.

Perhaps there would be demand for people to interpret English to English after all!

How are we doing?

It’s always helpful to have your feedback on the articles we prepare, and the approach we’re taking in dealings with the government. You can help us by filling out a Comment below this post on our website, and giving us any feedback you have on how we’re peforming, or how we could improve.

In the last working week of 2008 we received draft guidelines for R&D planning from AusIndustry for discussion. R&D planning has been a requirement of the R&D tax concession since 2001 and is actually part of the definition of R&D activities in the Income Tax Assessment Act 1936.

There are serious deficiencies with the current R&D Planning Guidelines, despite the consultations prior to their introduction, but they have proven to be workable since their introduction.

R&D Planning Should be a “Carrot” not a “Stick”

MJA has a long track record of supporting a component of the R&D tax concession that links R&D activities to business strategy. In fact, our first submissions on this point were made way back in 1995.

Initially, our recommendation was for companies that commit to R&D planning to be rewarded with higher rates of deduction (a “carrot”), rather than the “stick” approach adopted by government. Instead we have a system that rewards form over substance and tends to see R&D plans as a compliance documents, where the absence of a plan can lead to a claim being denied.

And so the government set out, in response to the June 2007 New Elements of the R&D Tax Concession Evaluation Report, to simplify and streamline the R&D planning process.

But “simplified and streamlined” actually increases compliance costs

The government, in requesting feedback on the draft guidelines, said “[t]he draft guidelines are simplified and streamlined in comparison to the existing guidelines”. Whilst this is true in that the document is shorter, implementing the draft guidelines in their current form has the potential to significantly increase compliance costs without delivering any further business value.

Our principal objection to the new planning guidelines is that they force compliance questions about the eligibility of possible, future, planned activities into a rigorous legalistic framework to be addressed in advance of work being undertaken.

Under the current guidelines it is sufficient to outline the program of R&D activities, the intended “Innovation” or “High Levels of Technical Risk” in the activities and the objective of the R&D project. A form was provided, but it was not intended to be prescriptive. These requirements, although favouring form over substance, were sufficient to identify potentially eligible projects (including some that may or may not be undertaken, let alone claimed).

Further proposed changes, dealing with authorisation procedures, estimation of expenditure by planned R&D activity, accompanied by a lack of detail on planning updates and frequency as well as approval of updates means that the changes proposed are far-reaching and affect organisations whether large or small.

If this guideline is approved it is a victory of means over ends; of bureaucracy over business.

MJA Submission on R&D Planning

We have written a detailed submission to goverment on the proposed R&D planning guidelines. You can download a PDF below, together with the proposed R&D planing guideline and see what the issues are.

AusIndustry Draft R&D Planning Guidelines

MJA Submission on Draft R&D Plan Guideines

Although submissions formally closed on 30 January 2009, we suspect that few corporates or other parties will have responded due to the Christmas/New Year break.

If that’s the case, and you want to make a submission to AusIndustry on these guidelines, please forward your comments either by email to rdtaxcon@innovation.gov.au with the heading “Consultation on proposed R&D Plan Guideline” or by post to:

The Manager
R&D Tax Concession Program Management
AusIndustry
GPO Box 9839
Canberra ACT 2601

How are we doing?

It’s always helpful to have your feedback on the Submissions we prepare, and the approach we’re taking in dealings with the government. You can help us by filling out a Comment below this post on our website, and giving us any feedback you have on how we’re peforming, or how we could improve.

What does this mean for business innovation?

Well, the research strongly supports the position that those who stay the course with their innovation programs in times of downturn inevitably prosper as the economy turns the corner. In fact, it’s an ideal time to innovate as prosperity sees companies fully occupied with keeping up with the demands of customers, leaving little time to pursue product and process initiatives.

This is all well and good but we all know that there is always a huge drive to cut costs in times such as these. Innovation budgets are often first up against the wall. So the call now is for innovation champions to take up the cudgels and argue their cases for support more vigorously than ever.

And it’s a similar call that needs to be put to the Federal Government.

We have already seen the Government’s White Paper response to the Cutler Report (Venturous Australia) delayed until early 2009. Government must fight the urge to further delay the consideration of the reforms proposed in Cutler and in the subsequent responses provided by stakeholders. The whispers we hear of the ultimate reforms being delayed until 2010 must not be allowed to gain in volume.

The New Year will see MJA campaign vigorously on these matters.

We will do our utmost to keep the review process to timetable. We look forward to sharing our thoughts with you and receiving your counsel on the best way forward.

In the meantime, we hope that the holiday break gives you some brief respite from the economic collywobbles. We wish you and your family all the best for Christmas and the New Year from all of us here at MJA.

See you in 2009!