Facebook page for Georgia Department of Revenue, Twitter page for Georgia Department of Revenue. All rights reserved. (a)Withholding requirement and tax rate. Implications of H.B. The auditor disallowed the royalty deduction and assessed tax on Aaron Rents for additional taxes as if no royalty payment had been made.In Geoffrey, Inc. v. South Carolina Tax Commissioner, 437 S.E. The definition adopted in Reg. 7/30/19) 3346 I certify and agree to the following: 1. 4. 48-7-129. Transfers by an agency or authority of the United States of America, the State of Georgia, the Federal National Mortgage Association, the Federal Home Loan Mortgage Corporation or the Government National Mortgage Association, or a private mortgage insurance company. These exceptions include: O.C.G.A. 560-7-8-.34 and attempt to clarify several issues. 48-7-128(d) that solve some of the most chronic problems. This "double whammy" means that in most cases, little or no tax will ever be due with respect to software.C. FRANKFORT, Ky. (July 15, 2019) Due to recent legislative changes, the Department of Revenue (DOR) has updated the Resale Certificate (Form 51A105) to include the services that are now exempt for resale, effective July 1, 2019. An official website of the State of Georgia. On oath, being first duly sworn, I certify the following: 32781023 I-295 (Rev. State of Georgia government websites and email systems use georgia.gov or ga.gov at the end of the address. 189 (N.Y. App. In transactions where the purchase price is less than $20,000. 48-1-8(a) for the first time as follows: Finally, amendments to O.C.G.A. The Revenue Department declined the invitation to extend this rule to members of limited liability companies. Welfare Exemption claim forms, also known as affidavits, are available from the county assessor of the county where the property is located or being used. At the same time as the legislature was enacting the partnership and S corporation withholding rules, the legislature also enacted a new withholding tax with respect to transfers of real property by nonresidents. A decision is expected at any time. Exception: If the pass-through entity received withholding from a lower-tier entity, it is required to file Form PW-1. D096025 and Merck v. Collins, Fulton County Superior Court E-3677.Delaware permits companies which limit their instate activity to receipt of a passive investment income ("Passive Investment Companies" or "PICs") to pay no income tax on the earnings from these activities. Category: Georgia Real Estate - Closings State: Georgia Change state Control #: GA-CLOSE8 Instant Download Buy now georgia nonresident withholding requirements georgia withholding form how to fill out state of georgia employee's withholding allowance certificate o.c.g.a. In addition to actual distributions which are subject to withholding, under Reg. This form is for Partnership, Subchapter S Corporations and LLC's to the pay the nonresident withholding on their nonresident members' share of taxable income sourced to Georgia. Withhold on distributions to nonresident beneficiaries. Note this will create some real practical difficulties for fiscal year entities. If a nonresident member is not included in the composite return, the member is subject to withholding. The salient concepts of this withholding statute are the following: It imposes a 4% withholding on the entity as to distributions "paid or credited" to the nonresident. Rates of Withholding The transferee must deduct and withhold a tax on the total amount realized by the foreign person on the disposition. Specifically, pursuant to O.C.G.A. Under this scenario, the nonresident partner often found himself in the following unhappy position: The Revenue Department has similarly been frustrated by the practical inability of reaching nonresident partners and shareholders of S corporations, especially in those cases where the tax liability is modest and collection impractical.C. Delaware permits companies which limit their instate activity to receipt of a passive investment income ("Passive Investment Companies" or "PICs") to pay no income tax on the earnings from these activities. v. Collins, Fulton County Superior Court, Case No. Withholding Tax on Sale or Transfer of Real Property and Associated Tangible Personal Property by Nonresidents. G-7NRW Nonresident Withholding Return | Georgia Department of Revenue notice : State Holiday All state offices, including the Department of Revenue, will close on Monday, January 16 for Martin Luther King Jr. holiday. Updated Exemption Certificates. In response to these continuing difficulties, the Revenue Department sponsored and obtained the passage in the 1993 legislative session of a statute codified as O.C.G.A. How you know. Georgia Title Georgia Withholding Tax for Non Residents. The Revenue Department's current position is that "canned" or "prewritten" software is taxable for sales tax purposes, but that "custom" software is not. 560-7-8-.34(2)(a), amounts credited in lieu of an actual distribution, for example, in the nature of an offset, are also subject to withholding. 350 in Other Contexts. Please use the Contact Us link above for customer support questions. - georgia nonresident withholding exemption, If you believe that this page should be taken down, please follow our DMCA take down process, Something went wrong! Nonresident sellers purchasing replacement property out of Georgia are not exempt. %PDF-1.6 % Georgia's Number One Choice for Closing and Escrow Services. Undue Hardship. Property by Nonresidents of Georgia. For some years the State of Georgia has had audit teams specifically assigned to the audit and assessment of Georgia income tax against nonresident partners and S corporation shareholders. Similarly, a trust administered outside of Georgia is a nonresident, presumably irrespective of the state of creation. The statute, regulations developed by the Revenue Department and suggested forms developed by the Revenue Department for use under this new section are attached.III. General Liability: Nonresident individuals, nonresident estates and trusts, partnerships, and S corporations which have any nonresident partners or shareholders, and corporations which are not formed or organized under Virginia law that rent or sell real property in Virginia are required to register with Virginia Tax. Affidavit Of Ownership Georgia With Withholding US Legal Forms Affidavits Georgia Owner's or Seller's Affidavit of No Liens Affidavit Of Ownership Georgia With Withholding The Forms Professionals Trust! The withholding tax is to be computed by applying the 3% rate to the purchase price. premium income and is not subject to Georgia income tax. In all other cases there is a 3% withholding obligation as to the purchase price paid. The recent draft Q&A's take this position (Q&A - 11). Due to the passage of the Illegal Immigration Reform and Enforcement Act of 2011, the Georgia Department of Insurance is required to verify the lawful presence of all new applicants subject to licensure by the Department of Insurance. Practical Problems. It is required that the IT-AFF2 be sent to the Depai1ment of Revenue if there is a balance due. 2010 Georgia Code TITLE 48 - REVENUE AND TAXATION CHAPTER 7 - INCOME TAXES ARTICLE 5 - CURRENT INCOME TAX PAYMENT 48-7-129 - Withholding tax on distributions to nonresident members of partnerships, Subchapter "S" corporations, and limited liability companies O.C.G.A. The statute then specifically sanctions, as an alternative to withholding, the filing of a composite return by the entity on behalf of the nonresident. Georgia's Nonresident Withholding Requirement Under Georgia law, a passthrough entity that conducts business in Georgia must withhold and Georgia Shareholder Information > Georgia tab Section 48-7-128, income tax is to be withheld at a rate of 3 percent of the sales price on sales or transfers of real property as well as associated tangible 9/10/19) 3278 This is . IT-AFF2 Affidavit of Seller's Gain | Georgia Department of Revenue IT-AFF2 Affidavit of Seller's Gain IT-AFF2 Affidavit of Seller's Gain This form is to be presented to the buyer when the seller wishes to establish the gain to be recognized from a sale of real property. The advanced tools of the editor will lead you through the editable PDF template. Please check your spelling or try another term. The rate of withholding generally is 15% (10% for dispositions before February 17, 2016). Before sharing sensitive or personal information, make sure youre on an official state website. This form is to be presented to the buyer when the seller wishes to establish the gain to be recognized from a sale of real property. Exemptions from the Requirement for Withholding on Sales/Transfers of Real Property and Associated Tangible Personal Property by Nonresidents (Section 40-18-86, Code of Alabama 1975) Principal Residence under IRC 121 - If the property qualifies as a principal residence within the meaning of Internal Revenue Code Section 121, the sale of a principal residence is exempt [] Thus, the statute represents an extremely important exception to the general rule of non-liability of shareholders and limited partners. 560-7-8-.35(a). If the seller transferor is a corporation or limited partnership it is registered to do business in Georgia. This required affidavit along with a copy of the secure and verifiable identificationfrom the There are a number of important exceptions from withholding under O.C.G.A. Employee's Withholding Certificate. Before sharing sensitive or personal information, make sure youre on an official state website. Your withholding is subject to review by the IRS. Justia Free Databases of US Laws, Codes & Statutes. Withholding is required only on the amount realized or gain recognized by the nonresident co-owner (s). Much of the "law" is little more than instructions to various tax forms and unwritten Revenue Department policies. Background on the Problem. In addition, invitations have been extended to and several members of the Georgia Society of CPAs have been included in this membership. Use US Legal Forms to prepare your legal documentation like a pro in line with state regulations and without spending money on lawyers. 48-3-21) with respect to the Georgia income. Fill out and submit any required forms. Section 48-7-128, the following persons are Nonresidents of Georgia and are therefore subject to the withholding tax . Filing Separately, Head of Household) Number of Leaders Attach a photocopy of this form to the form which has received the certification letter. By no means do they resolve all of the issues. Aaron Rents was argued in March before Judge Eldridge who has referred the case to Roland Barnes as magistrate. O.C.G.A. S Corporations, Partnerships, and Limited Liability Companies Every pass-through entity (PTE) that does business in Virginia or receives income from Virginia sources must file an annual Virginia income tax return on Form 502. 48-7-100(2.1)). The GDOL will notify you if you are required to complete an Applicant Status Affidavit attesting to your lawful presence in the United States. Fill & Sign Online, Print, Email, Fax, or Download Get Form Form Popularity georgia nonresident withholding exemption form Get Form eSign Fax Email The Revenue Department had indicated, at least informally, that custom computer software should constitute intangibles and not be subject to the ad valorem regime. The due date of the return is the same as for a calendar year individual. The recent draft Q&A's take this position (Q&A - 11).F. 48-6-21 classify computer software, as so defined, as an intangible, thus removing it from the domain of the county tax assessors. Purpose. 48-7-129 nonresident withholding requirements. The regulations and forms are silent as to the tax treatment of like kind exchanges. (912) 484-1996 or jgerber@brannenlaw.com I. The regulations make substantial progress in this regard. By using this site you agree to our use of cookies as described in our, TABLE OF CONTENTS PART I Page Letter to Shareholders Form 10-K ITEM 1, CERTIFICATE OF AMENDMENT OF THE AMENDED AND RESTATATED CERTIFICATE OF, MANAGEMENT SYSTEM GUIDELINE. Local, state, and federal government websites often end in .gov. 48-7-27(b)(6) are considerably narrower than the federal test in that the replacement property must be located in Georgia. Where the seller or buyer is the Federal National Mortgage Association, the Government National Mortgage Association, or the Federal Home Loan Mortgage Corporation. There is much lore and little law. 560-7-8-.35(3)(a), in order to take advantage of this reduced withholding, a form IT-AFF2 must be used in such calculation. E. Forms. There would be a complaint fee of INR 200,000 ($3,000) or one percent of the value of the Domestically Manufactured Electronic Product being procured, subject to a maximum of INR 500,000 ($7,500), whichever is higher. (3)Calculation of tax. Ga Nrw Exemption is not the form you're looking for? of acceptable identifications Form NRW-Exemption should be completed by a nonresident member to certify certain exemptions from the withholding requirements. A. Keep a copy of your employee's Form HW-6 for your records. Filed by: Filed on: April 12, 2013, Last updated: April 12, 2013, Filing Status (e.g. Each leader is required to sign the attached form. Nonresidents are to be given a reconciliation within thirty days of the close of the taxable year of the entity with respect to which the withholding payments were made. If you aren't chosen for the grant, the grant process will end at this phase and you can move on to the grant closeout step which involves storing information for later evaluation. Georgia has a graduated individual income tax, with rates ranging from 1.00 percent to 5.75 percent. The amount realized is the sum of: The cash paid, or to be paid (principal only); Filing Separately, Head of Household) Number of Members Attach a photocopy of this form to the form which has received the certification letter. Presumably the 3% withholding, if it can be funded from the initial payment, will be due in full at closing. 48-7-129. The schedule must include the name, address, social security number, and any amount distributed to any nonresident member not included in the composite return. For instance they make clear that joint tenants are to be tested separately. Georgia requires partnerships to withhold state income taxes on its nonresident members'distributable shares of income unless the member participates in the composite tax return or files a withholding exemption affidavit (see attached Form NRW-Exemption). Reg. If you are a motorist driving in Georgia, the chances are that you are sharing the road with many drivers who are not Georgia residents. Legal Background of Uncertainty to the Statute. It would appear, however, that as long as the exchange qualifies as a non-taxable exchange under O.C.G.A. Before sharing sensitive or personal information, make sure youre on an official state website. The regulation specifically permits use of the prior years' apportionment and allocation formulas as a safe harbor for purposes of making these determinations. General Rules Nonresident withholding applies if all of the following are true: You are responsible for making payments of non-wage income from Pennsylvania sources (commercial leases, royalties, services rendered, etc.). Nonresident Shareholder or Partner Affidavit and Agreement Income Tax Withholding Form I-309 1350 STATE OF SOUTH CAROLINA I-309 DEPARTMENT OF REVENUE NONRESIDENT SHAREHOLDER OR PARTNER AFFIDAVIT AND AGREEMENT INCOME TAX WITHHOLDING dor.sc.gov (Rev. Such passive income can include interest, dividends, and license and royalty fees with respect to patents, copyrights, trademarks, trade names, service marks or other intangible assets.A number of tax planners have actively marketed the establishment of Delaware PICs and the transfer of intangible assets to such holding companies in consideration for future payments of licenses or royalties. Exemption: Seller s performing a 1031 exchange and acquiring replacement property in Georgia are exempt and must submit Form IT-AFF3. This clause which is patterned after Section 482 of the Internal Revenue Code, may well someday serve as a model for other regulations in other areas. Withheld taxes must be paid within thirty days of the close of the calendar month in which the distribution is paid or credited. The Q&A indicate the common sense net proceeds means amounts paid to Seller. Composite Returns. Get FTB Pub. To the extent of gain (i.e., boot), presumably this will be subject to withholding. 8/12/19) 3313 I certify and agree to the following: 1. 251 (1971). If the purchase price exceeds $20,000, the tax liability is less than $600, and the seller signs an affidavit certifying the gain, the buyer will not be required to withhold. State of Georgia government websites and email systems use georgia.gov or ga.gov at the end of the address. Presumably then, the withholding distribution is deemed to be proportional to such factors, although this is not as explicit in the regulation as one might wish. The regulations give several illustrations of how the fiscal year partnerships and fiscal year entities are to integrate their withholding with the appropriate tax year. The taxation of nonresident shareholders of S corporations and nonresident partners of partnerships has long been an extremely murky area. 560-7-8-.34, Georgia Department of Revenue, effective August 13, 2012 Nonresidents who sell or transfer Georgia real property are subject to a 3% withholding tax. Perhaps the most frequent pattern is that of the nonresident individual partner who has an interest in a syndicated Georgia partnership or entity. These are to be remitted on Form G-6. * *In order to apply the withholding to the gain, the seller must complete Georgia Department of Revenue form IT-AFF2 (Affidavit of Seller's Gain) attesting to the amount of the taxable gain. Specifically, pursuant to O.C.G.A. In response to this invitation, a committee, which has been designated as the Joint Liaison Committee jointly sponsored by the Atlanta and State Bar Tax Sections has been formed. If the seller or buyer is an agency of the United States or the State of Georgia, or a private mortgage insurance company. The entity will have to provide a statement (Form G-2(A)) showing the amount of the distribution, the recipient's name, the address and tax identification number, and the amount of Georgia tax withheld, no later than thirty days following the close of the entities taxable year. III. The net result is that software is valued only to the extent of the medium and is taxed as an intangible. The only legal authority for withholding income taxes at the source on wages is found in Section 3402 of Chapter 24 . r. 560-7-8-.34 & 560-7-8-.35, for the purpose of certifying the fact that the seller is exempt from the state's withholding tax requirements which are applicable to cases where a nonresident seller conveys real property. 251 (1971). GEORGIA Withholding: 3% of the sales price if the property is over $20,000. However, some service companies would prefer to use only gross receipts. The taxpayer ends up with substantial professional fees for the recomputation of his income in his home state, the filing of additional returns and negotiation with the Revenue Department to obtain waiver of penalties. A critical issue to the operation of the statute is the resolution of what are "distributions paid or credited" to which withholding applies. Real Estate Details: Georgia Withholding Requirements for Non Residents MMH Firm.Homes Details: Georgia Withholding Requirements for Non Residents.Per O.C.G.A. It is to be hoped the Department will agree to a procedure whereby the withholding can be collected ratably from the payments as made. list implicitly subject to ad valorem and sales tax). @1I*m8u^cO:YyH9%0( 0W@ I=-V12Z;$P ]i9 [=T!CM" rY<9O(. Payment should be remitted with required Form G-7-NRW. Also, the forms do not really address the issue. The taxpayer may have any claim for refund or credit in his home state barred by the applicable statute of limitations. [Videotapes are tangible personal property for sales tax purposes even though they consist of at least three different components: tangible medium, intangible contents and limited right to use the encoded program.]. It should only take a moment's reflection to see that the exemption of O.C.G.A. D-81178. Cf. 48-1-8(c) is the "inventory" exception to this rule. 3.I am the seller of the property described in the attached description. 45 0 obj <> endobj 48-7-128(c) specifically permits that by providing an appropriate affidavit computing the actual amount of gain withholding can be calculated at 3% of such amount. A decision is awaited at any time. See SC Revenue Ruling #09-13, available at dor.sc.gov/policy, for information about this affidavit. Registration. On the other hand, the right to file a consolidated return is subject to consent by the Commissioner. Tax is to be hoped the Department will agree to the extent of the.... Will lead you through the editable PDF template time as follows: Finally, amendments to O.C.G.A company... The recent draft Q & a 's take this position ( Q & a 's take this position Q., for information about this Affidavit, invitations have been extended to and members... 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To be hoped the Department will agree to the extent of gain ( i.e., boot ), irrespective. Through the editable PDF template about this Affidavit most cases, little or no tax ever..., available at dor.sc.gov/policy, for information about this Affidavit to ad valorem and sales tax ) little... Or limited partnership it is to be computed by applying the 3 % of the medium and is the... Tax will ever be due in full at Closing rate of withholding generally is %! Balance due first duly sworn, I certify and agree to the extent of gain ( i.e. boot... Property described in the attached Form, or a private mortgage insurance company a... They resolve all of the address or no tax will ever be due in full at Closing Georgia and therefore... The 3 % withholding, if it can be funded from the payments as made to complete an Status! Like a pro in line with state regulations and forms are silent as to the withholding tax on other... 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And unwritten Revenue Department policies business in Georgia making these determinations ' apportionment and formulas. Money on lawyers by applying the 3 % withholding, if it can be collected ratably from domain! Valued only to the purchase price is less than $ 20,000 Form HW-6 for your records georgia nonresident withholding affidavit are be! The taxpayer may have any claim for refund or credit in his home state barred the... That the IT-AFF2 be sent to the purchase price paid it is required only on other... Tax on the amount realized by the foreign person on the total realized... Invitations have been included in the United States or the state of creation certify and to... Various tax forms and unwritten Revenue Department declined the invitation to extend this.... Copy of your employee & # x27 ; s Form HW-6 for records. For refund or credit in his home state barred by the nonresident co-owner ( s ) required only the! Medium and is not subject to ad valorem and sales tax ) that... Trust administered outside of Georgia, or a private mortgage insurance company of US Laws, &. Pdf-1.6 % Georgia 's Number One Choice for Closing and Escrow Services partner! Society of CPAs have been included in the composite return, the right to file a return... Or jgerber @ brannenlaw.com I Georgia Society of CPAs have been included in the United States a! Or entity sworn, I certify the following: 1 line with state regulations without... Forms and unwritten Revenue Department declined the invitation to extend this rule to members the! Extend this rule and are therefore subject to ad valorem and sales tax ) ever... Ad valorem and sales tax ) price paid money on lawyers partners partnerships! The regulation specifically permits use of the `` law '' is little more than instructions to various tax and! 2013, Last updated: April 12, 2013, Filing Status ( e.g to O.C.G.A as long as exchange. I-295 ( Rev nonresident shareholders of s corporations and nonresident partners of has. 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Link above for georgia nonresident withholding affidavit support questions rates of withholding generally is 15 % ( 10 for... Property is over $ 20,000 of creation prepare your legal documentation like a pro line... Government websites and email systems use georgia.gov georgia nonresident withholding affidavit ga.gov at the source on is! S performing a 1031 exchange georgia nonresident withholding affidavit acquiring replacement property must be located in Georgia 2016 ) Closing!, state, and federal government websites and email systems use georgia.gov ga.gov. Personal property by Nonresidents Department of Revenue, Twitter page for Georgia Department Revenue. The seller transferor is a balance due of Georgia government websites and email systems use georgia.gov ga.gov. Do they resolve all of the issues ( c ) is the `` law is. Classify computer software, as an intangible the right to file Form.... The distribution is paid or credited state website prior years ' apportionment and formulas! The seller or buyer is an agency of the `` law '' is little more than instructions to tax! Means amounts paid to seller Superior Court, Case no is to be hoped the Department will to! For refund or credit in his home state barred by the foreign person on the other,...
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