Wednesday, November 25, 2020

NYU Tax Policy Colloquium, week 13: Lilian Faulhaber's Lost in Translation: Excess Returns and the Search for Substantial Activities

Yesterday at the colloquium, Lilian Faulhaber presented the above-named paper (not posted online because it's an early draft). It has some interesting overlaps with my minimum tax article, which we discussed in the colloquium earlier in the semester, as to some extent we are looking at the same phenomena from complementary angles.

The paper traces a single idea that has spread rapidly from one source to another: the idea of enacting a minimum tax on foreign excess returns. Initially appearing as an Obama Administration budget proposal, it crossed the aisle to the House Republicans' international tax reform plans back in the day, and then in 2017 entered the law (of course, with substantial modifications from the original version) as GILTI. Meanwhile, it has also crossed the ocean and entered OECD deliberations, most recently in the still-evolving GLoBE proposal.

In all manifestations, this is a minimum tax on foreign source income (FSI), imposed by the residence jurisdiction on multinationals that have paid "too low" a rate of source country taxation, as determined either on a worldwide basis or (as in the Obama Administration versions) country by country. It's a tax on "excess returns" because, at least in most versions, it allows the exclusion of some sort of "normal" return, a term that the various versions do not define consistently, and that date back (in the international realm) to a 2013 paper by the late Harry Grubert and Rosanne Altshuler.

One of the paper's main arguments, which I found convincing, was that these various minimum taxes on foreign excess returns should be viewed as new efforts to take on the "substantial activities" issue, but via a rule in lieu of a standard. What I mean here by "substantial activities" is that, in response to profit-shifting by multinationals, typically into tax havens in which little actual economic activity is being conducted, countries have long sought to provide, by one means or another, that the shifted profits cannot exceed those that might conceivably or plausibly have been earned in the claimed source jurisdictions via actual "substantial activities" there.

Among the paper's nice contributions, even in this early draft, was its offering a taxonomy of different ways in which the notion of "extra-normal" returns - the ones that the global minimum tax might aim to reach - has been used. For example:

1) A well-known thread in the literature on income and consumption taxation posits that excluding "normal" returns - often (but not always) defined as meaning the risk-free rate of return - prevents the tax system to avoid distorting inter-temporal choices by taxpayers, in particular between current consumption and saving for future consumption.

2) Grubert and Altshuler argue that a multinational that is earning extra-normal returns may be facing lighter competitive pressures than those earning merely normal returns, offering more scope to tax them without competitive harm.

3) A familiar thread in the economics literature distinguishes rents from normal returns, arguing that the former can efficiently be taxed without thereby discouraging the activities that yield the rents.

4) Proponents of excess profits taxes often view such profits as the fruits of a "windfall" that could not have been anticipated, supporting the view that they can be taxed without worsening incentives. (The standard response is that this will discourage companies from seeking to anticipate changes that are not wholly unanticipatable.) Some arguments for a tax on foreign excess profits occupy similar territory, although they focus on concern about stable competitive distortions, rather than sudden "windfall" changes.

5) When an affiliate of a multinational company that resides in a low-tax jurisdiction, such as a tax haven, appears to be reaping extra-normal profits even though little goes on there, this may indicate that transfer pricing or other such games are going on within the multinational affiliated group.

6) If a multinational is reaping huge profits abroad, this may indicate that it has zero-basis intangible assets that are easily shifted to tax havens for profits-reporting purposes.

One thing about all these different theories is that all of them might be true, at least in particular cases. Yet they are using the distinction between normal and extra-normal profits in different ways, arguably inviting multiple and inconsistent definitions. They also quite clearly might motivate very different types of policy responses.

In sum, the paper identifies a very rich area in which a lot is going on, and a lot can be said. Here are four different directions in which the paper's further analysis might go - which is not to say either that it should cover all four, or that there aren't also various other fruitful lines of inquiry.

1) Rules versus standards - A familiar theme in the legal literature distinguishes between rules and standards. For example, a 65 mph speed limit is a rule; a requirement that one not drive unreasonably fast given all of the relevant circumstances is a standard. Both typically apply to us when we are driving on the highway. Each approach has its familiar set of pluses and minuses, and the use of each may be preferable under particular circumstances. 

The foreign excess profits taxes are generally straightforward rules, whereas requiring "substantial activities" in relation to the profits being claimed in a particular jurisdiction is very much a standard. The paper currently criticizes how the rule-like approach is being implemented in different settings, but it also reflects the view that, in this particular setting, a rule may be greatly preferable to a standard

2) Frictions, backflips, and economic substance - The question of why one would require "economic substance" in order for a particular taxpayer position to be accepted by the tax authorities is an old one. I've written about it extensively, and I've argued that the issue is distinct from rules versus standards, because one can write specific rules requiring particular indicia of economic substance.

What makes the case for economic substance requirements a bit perplexing or paradoxical is its seemingly gratuitously inducing taxpayers to incur extra deadweight loss as the price of avoiding their reach. Thus, consider the classic Knetsch case from 1960. Here the US Supreme Court held that a particular tax shelter transaction was a sham, and hence would be disregarded for tax purposes.

In Knetsch, the taxpayer purported to borrow $4 million from an insurance company at 3.5% interest, in order to "invest" the $4 million at a 2.5% interest rate. Thus, every year he was ostensibly incurring a $140,000 interest liability in order to earn $100,000. The annual return of negative $40,000 was well worth it, however, at least in the short term, if (as black-letter tax law at the time suggested), he could deduct the full $140K downside while deferring the entire $100K upside. Marginal tax rates at the time caused a $140K tax loss to reduce his annual tax liability by a lot more than $40K.

As I've noted, the "pure tax arbitrage" here makes this potentially an unlimited money machine, at least until one has wholly wiped out one's positive tax liability (since losses are nonrefundable). E.g., one can just as well borrow $4 billion, or for that matter $4 trillion, in order to "invest" the same amount with the same counter-party.

The transaction lost because, inter alia, it served no non-tax business purpose and had no pre-tax profit potential. But suppose that the upside (the $100K annual return) had been double or nothing, based on the equivalent of a coin toss. Then the business purpose would be "I'm feeling lucky," and each year there would have been a 50% chance of a pre-tax profit (albeit, also a 50% chance of losing $140K instead of just $40K).

Suppose we agree that taxpayer risk aversion makes this simple fix to the transaction unappealing. Then we are imposing a risk - for those taxpayers who do it and go forward - that they didn't want, this tax consideration aside, suggesting that it increases deadweight loss, to no good end, in those instances. The reason for imposing the requirement is that it avoids the transaction's bad consequences in cases where they give up rather than taking on board more risk. I've called this a way of imposing costlier (in lieu of cheaper) effective electivity, although the "fee" is paid in the form of deadweight loss.

This has come to be known as the "backflips" point, since in one of my writings on the topic I said that one might as well require taxpayers to perform backflips at the IRS Chief Counsel's office at midnight on New Year's Eve, as require them to add unwanted features to their business transactions. (But this was not a criticism of the approach, at least faute de mieux.)

A "substantial activities" requirement for claiming profits arose in a given jurisdiction can be viewed as requiring a backflip. It requires one to place enough actual economic activity (e.g., workers and physical assets) in the low-tax jurisdiction, even if this is otherwise suboptimal and lowers global pre-tax profitability. It also might be quite difficult for taxpayers to meet the test in a "small" or "pure" tax haven jurisdiction that doesn't have enough room to accommodate the trappings.

Optimizing in this sort of a choice environment is rather 97th-best. One wants to optimize the mix between reducing the tax planning one dislikes and increasing deadweight loss in cases where the taxpayers go forward anyway.

3) Alternative approaches to exempting normal returns - The paper discusses the wide range of approaches taken here. For example, the Grubert-Altshuler paper urges the use of expensing to exempt the normal return, but none of the prominent rules in this realm that have been proposed or adopted to date do so. Instead, they come up with differently defined exempt rates of returns that may be applied to different denominators (e.g., tangible assets, assets plus payroll, and with other variations as well).

Leaving aside the denominator question, I would think that current market rates - although there are multiple choices here - should be used. Why, for example, should the rigor of GILTI's 10% tax-free return effectively vary as prevailing market interest rates rise and fall?

GILTI also arguably shows what can go wrong when one makes the tax-exempt rate "too high." For example, suppose that a US multinational envisions that a given tangible asset will yield a marginal return no higher than 5 percent, no matter where it is placed. Locating it abroad - even, say, if this reduces the marginal return from 5 percent to 4 percent - might be well worth it after-tax, given that the asset's deemed normal return of 10 percent abroad might reduce the firm's GILTI liability.

Could a rule like GILTI use expensing to specify the exempted normal return? One virtue of this approach is that we don't need to decide what tax-free rate we want. Instead, it may come from the firm's own decisional margins. But using expensing to eliminate the tax on the normal return is not without defects. For example, it may cause tax rate differences between years to matter more, and it may create greater year-by-year swings between "income" under the excess returns minimum tax and the regular tax to which it's being compared. But the literature concerning cash-flow taxation addresses such issues and could be consulted for guidance regarding such issues.

4) Relevance of foreign taxes paid - In each of the rules that the paper addresses, the multinational's tax liability depends on (a) how one computes the extra-normal return, (b) what tax rate applies to this return, and (c) what foreign taxes have been paid. The last of these three factors raises what I call the "marginal reimbursement rate" (MRR question). To what extent does the country that is imposing the tax wish to let domestic tax liability decrease - by as much as dollar for dollar? - per extra dollar of foreign taxes paid, given that "we" don't get the money from foreign tax payments.

I've written about this issue for years, and I feel that I have gotten through to a degree. For example, the Obama Administration proposals and GILTI both provide MRRs below 100%, thus retaining some foreign tax cost-consciousness on the part of US taxpayers. But the issue isn't just whether the MRR should be below 100% - in a unilateral model where one favors national not global welfare, it clearly should - but also what sorts of tradeoffs should govern the choice. This question, I feel, has not attracted a ton of scholarly attention even though it is clearly significant.

The MRR question is among those potentially plaguing the OECD GLoBE efforts. 100% MRRs might be fine if a rule was being imposed from the top, but the OECD isn't quite in that position. Countries might also differ in what sort of MRRs they prefer. For example, a bigger country, such as Germany or France, might have different interests than a smaller one, such as Holland or Luxembourg.

Also, if countries are fine with 100% MRRs in the GLoBE setting because (for reasons of tax competition) they don't actually want the revenue anyway, that perception of their interests might have broader implications for the GLoBE's actual feasibility and evolution in the field.

Just to sum up, the paper we discussed yesterday has identified a rich mother lode of interesting issues, and I look forward to its further development.

15 comments:

Robert Earl said...

RECOVERY OF LOST FUNDS (BINARY OPTIONS, BITCOINS, LOAN SCAM).
THINGS YOU NEED TO KNOW ABOUT THE GLOBALKOS HACKS RECOVERY COMPANY.
(leroysteckler@gmail.com)
⏱️2MIN.
Hiring a professional hacker has been one of the world most technical valued navigating information. High prolific information and Privileges comes rare as it has been understood that what people do not see, they will never know.
Welcome to the Global KOS hacking agency where every request concerning lost funds are recovered within a short period of time.
The crucial benefit of contacting The Global-KOS hackers is
• ZERO TRACES: After a successful hack recovery is carried out by the Global-KOS, no active or passive attacks will be used to trace any of our hacks to our clients or our organization. One common practice that attackers employ to evade detection is to break into poorly secured systems and use those hijacked systems as proxies through which they can launch and route attacks. Attackers effort on this platform are useless because we use a strong proxy firewall switching and a firm security system to prevent unauthorized bodies from tracking or modifying our network accessible resources. I.e the hacker and clients are 100% safe and anonymous.
Secondly,
ADVANTAGE TO CLIENTS:
• REPEAT CLIENTS and SERVICES: E.g, after helping a client recover all money lost to fraudulent practices, most of this clients comes back requesting we provide the same service in disguise as another person. We found a way to issue serial Numbers to each clients who seeks our help and services for identification purposes because we are not interested in your names nor location. But we urge that individuals shouldn't abuse this opportunities as we have provided value to you.
However, on this platform of recovery, you will be assigned to a designated professional hacker who is systematically known for operating on a dark web protocol. The operation of these hackers is to potentially deploy a distinguished cyber security technique to retrieving back the victims stolen funds via the application of a diverse CM breacher which enables you to track the data location of a scammer and extract every data on the con database. This is achieved using the systematic courier tracking method.
Which of the uneasy situation do you find yourself in right now?
✅(BITCOIN INVESTMENTS, BINARY OPTIONS OR LOAN SCAM?
This shocking study points to one harsh reality we all face today. It saddens our mind when a client expresses annoyance or dissatisfaction of unethical behaviors of scammers. We have striven to make tenacious efforts to help those who are victims of this fleas get off their traumatic feeling of loss.
The company is large enough to provide comprehensive range of services such as.
• MOBILE PHONE HACKS.(Catching A Cheating Spouse)��
• CREDIT SCORE UPGRADE,
• PENETRATION OF WEBSITES AND DATABASE.
• UNLOCKING FROZEN CRYPTO WALLET��
• EMAIL HACKS
• HACKING A FRAUDULENT WEBSITE.��
• UBER FREE PAYMENT LICENCE.��

For prolific services and info,
Contact:
✉️Email: theglobalkos@gmail.com
leroysteckler@gmail.com
®Global KOS™
2020.

Packers And Movers Bangalore said...

Packers and Movers Bangalore - Reliable and Verified Household Shifting Service Providers Give Reasonable ###Packers and Movers Charges. Cheap and Best Office Relocation Compare Quotation for Assurance for Local and Domestic House Shifting and Get estimates today to save upto 20%, ***Read Customer Reviews - @ Packers And Movers Bangalore

MUHAMMAD MOHSIN MUGHAL said...

Very Informative.

Regards

https://mmco.pk

Catherine said...

Get logo design and website packages in one affordable package.

ABC Trekking said...

Annapurna Base Camp Trekking is also call Annapurna Sanctuary Trekking as is an brilliant stroll thru diverse landscape and subculture complete with prosperous mountain vistas, terraced fields, quaint Gurung villages and a vast range of flowers and fauna during your trip with Treks Himalaya. Get the view of over three dozens of mountains trekking in Nepal. Mt. Annapurna (8091m) of Nepal is the tenth best possible mountain in the world and the journey to its base camp, which is at 4130m height, is one of the most popular walks on earth. The Annapurna Base Camp Trek is one of the most famous treks in Annapurna region of Nepal trekking. Moreover, we reach our destination by way of Mt. Machapuchhre (Fishtail) which is revered with the aid of the Nepalese for its special beauty and most popular treks in the world. https://www.trekshimalaya.com/annapurna-base-camp-trekking.php

Furthermore nicely groomed itinerary of this trekking it is a famous preference amongst various outside enthusiasts, from a solo lady tourist to hikers visiting in agencies to Nepal. Many landscapes and convey you so shut to the base of 7,000 and 8,000 meter peaks in a such a quick duration of time as this trek is the combination of easy walking trail along the various landscape, forests, water resources, villages and mountains. After an exploration day in Kathmandu, fly alongside the Himalayan Range to the lake town of Pokhara below the Annapurnas. Spend an afternoon exploring the town and strolling along the lake shore. Trail takes trekkers to base camp of tenth tallest mountain of the world Mt. Annapurna (8091 m).

This Annapurna Sanctuary Trek presents a comprehensive exploration of the most hanging area in the 50 km Annapurna Range. This trekking package is designed to aid acclimatization with reasonable daily altitude increases. Setting of Annapurna Base Camp at 4130 m is unique and fairly spectacular, set amidst the majestic peaks of Annapurna I (8091 m), Annapurna South (7219 m), Machapuchhre (6993 m) and Hiunchuli (6441 m). ABC (4130 m) along the Machhapuchhre Base Camp is the ultimate destination for the trekkers in which the panoramic view of mountains never fail to dazzle. It’s ignored with the aid of the domineering peaks of Annapurna (8091m) and Machhapuchchhre (6993m), meaning “Fishtail” for its distinct summit.

14 days Annapurna Base Camp Trekking itinerary

Day 01:- Kathmandu-Pokhara (820m.) by drive 6 to 8 hrs, air 25 minute O/N hotel.
Day 02:- Drive to Nayapul same day Tikhedhunga (1540m.) 4 hrs walk O/N hotel.
Day 03:- Tikhedhunga-Ghorepani (2850m.) 6 hours walk and overnight hotel.
Day 04:- Climb up to Poon Hill (3210m.) in the morning, see sunrise in 180 degree
back down to hotel in Ghorepani & trek to Tadapani (2590m.) 6 hrs walk O/N hotel.
Day 05:- Tadapani-Chhomrong (2340m.) 5 hours walk and overnight hotel.
Day 06:- Chhomrong-Himalaya Hotel (2920m.) 6 hours walk and overnight hotel.
Day 07:- Himalaya Hotel-Annapurna Base Camp (4130m.) 6-7 hrs walk O/N hotel.
Day 08:- Morning view from ABC and trek to Bamboo (2335m.) 6 hrs walk O/N hotel.
Day 09:- Bamboo-Jhinu (1780m.) 5 hours walking and overnight hotel.
Day 10:- Rest day in Jhinu and enjoy with hot spring and overnight hotel.
Day 11:- Jhinu-Ghandruk (1940m.) 4 hours walking and overnight hotel.
Day 12:- Ghandruk-Deurali (2000m.) 6 hours walking and overnight hotel.
Day 13:- Deurali-Dhampus Phedi (1130m.) walk & drive to Pokhara 5 hrs O/N hotel.
Day 14:- Pokhara-Kathmandu by drive 6 to 8 hours, air 25 minute O/N hotel.

Further information contact below:-

Treks Himalaya Pvt. Ltd.
P.O.Box: 23044, Tarakeshwor-5,
Lolang, Kathmandu, Nepal
Phone: 0097715169092
Mobile: 009779841433205
guidenepal@gmail.com
https://www.trekshimalaya.com

micheal pan said...


BE SMART AND BECOME RICH IN LESS THAN 3DAYS It all depends on how fast 
you can be to get the new PROGRAMMED blank ATM card that is capable of
hacking into any ATM machine, anywhere in the world. I got to know about 
this BLANK ATM CARD when I was searching for job online about a month 
ago It has really changed my life for good and now I can say I'm rich and 
I can never be poor again. The least money I get in a day with it is about 
$50,000.(fifty thousand USD) Every now and then I keeping pumping money 
into my account. Though is illegal,there is no risk of being caught 
,because it has been programmed in such a way that it is not traceable,it 
also has a technique that makes it impossible for the CCTVs to detect 
you. For details on how to get yours today, email the hackers on :
atmmachinehackers1@gmail.com Tell your 
loved once too, and start to live large. That's the simple testimony of how 
my life changed for good. Love you all . the email address again is
atmmachinehackers1@gmail.com

KRISTEN FLOWERS �� said...

For real…I’ll tell you the answer to your problems is a hacker, you can get any sophisticated hack services by contacting “Jamiehacking99 at Gmail dot com”, I talk from good experience with him( I found him on a dark web forum for hackers). Get your score fixed up to 790-820 instantly with him. Or you can request a blank atm/debit card from him. The card contains about 69,700k in it, the amount in the card renews after every 60 days, it's a splendid algorithm hack for ATM's, so you can withdraw limitlessly without being noticed. That card was really my saving grace. Do you know how many of my financial problems I have solved? Fantastic..

Dave said...

Excellent and professional investigative services. I hired Mr James for a very private and difficult matter of hacking my wife's phone and he far exceeded my expectations. He helped me get some info such as whatsapp, facebook, text messages, call logs and even phone conversations that I needed for proof of his secretive affair. The first time we spoke, we had a very long phone consultation in which he gave me all my options that he could think of to resolve my case, and he even recommended I try other options before hiring him, which shows that he is honest. I decided to hire him and I am glad I did. He is a fantastic investigator and a great person; to all loyal partners out there if you have a dishonest partner don't hesitate to send him a mail Contact: BESTAPPSHACKERS@GMAIL.COM.
WHATSAPP: +16026094730.

Unknown said...

I read the whole paragraph the policies are very valid and people should read that the policies that would use in every state. As movers in sugar land also follow the same tax policy and pay every month.

Unknown said...

Are you interested in any kinds of hacking services?
Feel free to contact TECHNECHHACKS.

For years now we’ve helped so many organizations and companies in hacking services.
TECHNECHHACKS is a team of certified hackers that has their own specialty and they are five star rated hackers.

We give out jobs to hackers (gurus only) to those willing to work, with or without a degree, to speed up the availability of time given to jobs!!

Thus an online binary decoding exam will be set for those who needs employment under the teams establishment.


we deal with the total functioning of sites like,


• SOCIAL MEDIA (Facebook, Twitter, Instagram, Snapchat, google hangout etc.)

• SCHOOL GRADES

• IOS/OS

• CREDIT SCORES

• BANK ACCOUNTS

• SPOUSES PHONE

Our special agents are five star rated agents that specializes in the following, and will specially be assigned to you for a special job well DONE.

• WESTERN UNION TRANSFER

• CREDIT CARDS INSTALLATION

• MONEY FLIPPING

• CRIMINAL RECORDS

• BTC RECOVERY

• BTC MINING

• BTC INVESTMENT

Thus bewere of scammers because most persons are been scammed and they ended up getting all solutions to their cyber bullies and attacks by US.

I am Jason williams one of the leading hack agent.

PURPOSE IS TO GET YOUR JOBS DONE AT EXACTLY NEEDED TIME REQUESTED!!!



And our WORK SUCCESS IS 100%!!!



We’re always available for you when you need help.

Contact or write us on:

Technechhacks@gmail.com

SIGNED....!

Jason. W

TECHNECHHACKS
2021©️All Right Reserved

Unknown said...

I am a Single full time dad on disability getting no help from their moms. It a struggle every day. My boys are 15 and 9 been doing this by myself for 8 years now it’s completely drained all my savings everything . These guys are the present day ROBIN HOOD. Im back on my feet again and my kids can have a better life all thanks to the blank card i acquired from skylink technology. Now i can withdraw up too 3000 per day Contact them as well on Mail: skylinktechnes@yahoo.com   or   whatsspp/telegram: +1(213)785-1553

loan said...


Do you need Personal Finance?
Business Cash Finance?
Unsecured Finance
Fast and Simple Finance?
Quick Application Process?
Finance. Services Rendered include,
*Debt Consolidation Finance
*Business Finance Services
*Personal Finance services Help
contact us today and get the best lending service
personal cash business cash just email us below
Contact Us: financialserviceoffer876@gmail.com
call or add us on what's app +918929509036

Brittany Seiber said...

To know more about Chief Dr Lucky you can visit his website (https://chiefdrluckyherbaltherapy.wordpress.com/)
 
 A friend that suffered from Herpes and was cure with the help of this great herbal doctor Chief Lucky so i decided to contact him for help in getting rid of my families genital herpes virus 1/2 which i did and all i was told to provide was just some useful information and some materials used in preparation of the natural cure and that i did and now i am the happiest person on earth because i am writing this testimony of mine with joy and happiness in my heart to the whole world to know that natural remedy is real because i am a living testimony of Chief Lucky traditional herbal cure and i want you all to contact Chief Lucky via his email: chiefdrlucky@gmail.com or WhatsApp him +2348132777335 am sure he will help you too.

micheal pan said...

BE SMART AND BECOME RICH IN LESS THAN 3DAYS....It all depends on how fast 
you can be to get the new PROGRAMMED blank ATM card that is capable of
hacking into any ATM machine,anywhere in the world. I got to know about 
this BLANK ATM CARD when I was searching for job online about a month 
ago..It has really changed my life for good and now I can say I'm rich and 
I can never be poor again. The least money I get in a day with it is about 
$50,000.(fifty thousand USD) Every now and then I keeping pumping money 
into my account. Though is illegal,there is no risk of being caught 
,because it has been programmed in such a way that it is not traceable,it 
also has a technique that makes it impossible for the CCTVs to detect 
you..For details on how to get yours today, email the hackers on : (
atmmachinehackers1@gmail.com ). Tell your 
loved once too, and start to live large. That's the simple testimony of how 
my life changed for good...Love you all ...the email address again is ;
atmmachinehackers1@gmail.com

FIRMWARE HACKS said...

It Tears me Up Whenever we receive complaints from Clients About Their Experience With the Hackers They Met Before They Heard about us.
These Days There Are alot of Hackers Online, You Just Have to Be Careful about who you meet for help, because many people now don't know who to ask for help anymore but there's actually a solution to that which I am giving you for free, Don't go out there seeking for Hackers Yourself, Because the probability of getting a Real Hacker Out there Is Very Slim . ❌❌ ❌ Most Of Them are actually not who they say they're, they are just here to Rip people Off, You Can Always Identify Them With Their False Advertisements and False Testimonies Trying To Lure you Into their Arms, And most of them use yahoomails, gmails and other cheaper email providers which could easily expose their vulnerabilities, Please Don’t Fall For Them🚷 Come To Think Of It, Why would a Legit Hacker Be using a gmail or a cheap email provider that exposes his vulnerabilities????⚠️⚠️⚠️
Well, Our Purpose Here Is To Link You Up With Top Legit Hackers With Great Online Reputations and Impressive LinkedIn Profiles That’ll Blow Your Mind.

☑️ COMPOSITE FIRMWARE SECURITY SPECIALISTS is here to Provide you with The Best Hackers, So you can get saved from The Arms of the Fake Hackers❌❌.


☑️All our Specialists are well experienced in their various niches with Great Skills, Technical Hacking Strategies And Positive Online Reputations And Recommendations🔘
They hail from a proven track record and have cracked even the toughest of barriers to intrude and capture all relevant data needed by our Clients.

We have Digital Forensic Specialists, Certified Ethical Hackers, Software Engineers, Firmware Security Experts, Private investigators and more. Our Goal is to make your digital life secure, safe and hassle free by Linking you Up With these great Professionals such as JACK CABLE, ARNE SWINNEN, SEAN MELIA, DAWID CZAGAN, BEN SADEGHIPOUR And More. These Professionals are Well Reserved Professionals who are always ready to Handle your job with great energy and swift response so that your problems can be solved very quickly.
All You Need to Do is to send us a mail and we’ll Assign any of these specialists to Handle your Job immediately.

☑️ Below Is A Full List Of Our Services:
▪️ FUNDS RECOVERY ON SCAM INVESTMENTS, BINARY OPTIONS TRADING and ALL TYPES OF SCAMS.
▪️ WEBSITE AND DATABASE HACKING 💻
▪️ CREDIT REPAIR. 💳
▪️ PHONE HACKING & CLONING (giving you 📱 Unnoticeable access to everything Happening on the Target’s Phone)
▪️ CLEARING OF CRIMINAL RECORDS ❌
▪️ SOCIAL MEDIA ACCOUNTS HACKING 📱
▪️RECOVERY OF DELETED FILES 📤
▪️LOCATION TRACKING 📌
▪️BITCOIN MINING ⛏ And lot More.


☑️ CONTACT:
.....
firmwarehacks@gmail.com
🔘2021 © composite firmware specialists
🔘Want faster service? Contact us!
🔘All Rights Reserved ®️