spb/wp30_uqo

1{2  "document_id": "lb_hotpotqa_4b1df711ec0557b9df23de534c1ce99b7f37528f643b8c29",3  "family": "public_hotpotqa",4  "split": "test",5  "text": "Passage 1:\nSpider9\nSpider9 Inc. is an American environmental technologies company headquartered in Northville, MI which develops and manufactures advanced control systems for energy storage and solar fields. It was founded in 2011 by Glynne Townsend (A123 Systems), Dave Park (former Vice President of Production at Wave Crest Energy Systems), Dave Smith (former chairman of USABC), and Bill Beckman (former Vice President of Finance at Johnson Controls).Spider9 acquired control system technology from the University of Michigan, Office of Technology Transfer and is developing the technology at their facilities at the Water Wheel Centre, in the historic Ford Valve Plant.\n\nHistory\nSpider9 was founded on control system technology patents licensed from the University of Michigan Real-Time Computing Laboratory. In the summer of 2011, the Spider9 leadership team brought the technology out of the Office of Technology Transfer, where it had been incubating. In July 2011, Spider9 pivoted the technology's business plan to target grid energy storage and solar field optimization rather than electric vehicles. On November 3, 2011, Spider9 received a Michigan Economic Development Corporation (MEDC) grant to install a solar field on the roof of the Water Wheel Centre in Northville, MI.\n\nTechnology\nSpider9 systems are capable of reconfiguring the architecture of systems through in-house developed hardware and software algorithms. Using a Spider9 system, individual cells and panels are monitored and managed. The system architecture is dynamically reconfigured around the components to deliver a consistent voltage output, compensating for performance variances and failures.\n\nFacilities\nSpider9's facilities are equipped with a waterwheel designed by Albert Kahn (architect) which once provided constant, sustainable hydroelectric power to the facility. The waterwheel no longer fulfills the electricity needs of the building. Spider9 is designing a control system for an 85 kW rooftop solar field with backup battery storage to supply the building with renewable power.\nPassage 2:\nA123 Systems\nA123 Systems, LLC, a subsidiary of the Chinese Wanxiang Group Holdings, is a developer and manufacturer of lithium iron phosphate batteries and energy storage systems.\nThe company was founded in 2001 by Yet-Ming Chiang, Bart Riley, and Ric Fulop. By 2009, it had about 2,500 employees globally and was headquartered in Waltham, Massachusetts. Its original product technology was based upon materials initially developed at the Massachusetts Institute of Technology.\n\nHistory\nIn November 2005, the company announced a new, faster-recharging lithium-ion battery system based on doped nanophosphate materials licensed from the Massachusetts Institute of Technology.\nIn December 2006, the United States Advanced Battery Consortium (USABC) in collaboration with the U.S. Department of Energy (DOE) awarded the company a US$15 million development contract to optimize A123 Systems' proprietary doped nano-phosphate battery technology for hybrid electric vehicle applications with a focus on power, abuse tolerance, durability and cost. USABC is an organization composed of Chrysler LLC Corporation, Ford Motor Company, and General Motors Corporation.BAE Systems announced that, from 2008, it would offer A123 Systems' lithium-ion battery technology as part of its HybriDrive Propulsion System used in the 2008 version of the Daimler Orion VII hybrid electric buses. As of September 7, 2009, more than 3,000 of the buses were in service.In May 2008, the United States Advanced Battery Consortium (USABC) in collaboration with the U.S. Department of Energy (DOE) awarded the company a US$12.5 million grant to develop its lithium ion battery technology for plug-in hybrid electric vehicles.On March 5, 2008, General Electric, the company, and Think Global announced that the three firms had entered a partnership to enable global electrification of transportation. GE invested US$20 million in the company to help it roll out batteries for Think. The company and Think at the same time signed a commercial supply agreement. The partnership was announced at the 78th annual international Motor Show in Geneva. After over $10 million in investment in the Think Global Think City, A123 ceased production of its L20 battery pack for Think after a single day of production in December, 2008.\nIn January 2009, A123 systems applied to the U.S. Department of Energy's Advanced Technology Vehicles Manufacturing Loan Program (ATVMLP) for US$1.84 billion in direct loans to support the construction of new lithium-ion battery manufacturing facilities in the United States, locating the first plant in southeast Michigan near Detroit. The application was still pending as of early 2012, the company estimated that it might be allowed to borrow up to US$233 million from the program.In April 2009, Chrysler Corp. announced a contract with A123 to supply batteries for their ENVI EV vehicles.In August 2009, the company received a US$249 million grant from the U.S. Department of Energy's Advanced Technology Vehicles Manufacturing Loan Program (ATVMLP) to build production facilities in Romulus and Livonia, Mich. after it received a US$125 million in tax credits and incentives from the Michigan Economic Development Corporation in spring and a US$10 million grant from the state in fall 2008.In September 2009, the company raised US$380 million after going public on the NASDAQ stock exchange.In 2009, the company was included on the Guardian's \"Global Cleantech 100\" list. Later, A123 was selected to Technology Review Magazine's list of the 50 Most Innovative Companies 2011.Chrysler's ENVI division was disbanded by Nov 2009.In December 2009, the company formed a joint venture with Shanghai Automotive Industry Corporation (SAIC), the largest automaker in China. This was the first joint venture between a Chinese automaker and a non-Chinese battery supplier. The new venture is called Advanced Traction Battery Systems (ATBS).In August 2010, A123's co-founder Professor Yet-Ming Chiang spun off a new company from A123 named 24M Technologies, which makes technology that combines concepts in current lithium ion batteries with flow batteries, where tanks of liquid electrolytes combine to create an electric current.In 2010, A123 received a US$249 million grant from the U.S. Department of Energy for building battery production facilities. Approximately $129 million of the grant was used to build a 550 MWh battery plant in Livonia and another in Romulus. An untapped $120 million grant was abandoned by A123 by May 2012.In September 2010, the company opened the largest lithium ion battery manufacturing facility in North America in Livonia, Michigan. When fully operational, the factory is expected to be capable of producing battery packs for the equivalent of up to 30,000 electric cars per year.In March 2011, the company received its third contract from the United States Advanced Battery Consortium (USABC) in collaboration with the U.S. Department of Energy (DOE): a US$8 million advanced battery development contract to continue developing its Nanophosphate® lithium ion battery systems to meet USABC's target application for a Power-Assist Hybrid Electric Vehicle (PAHEV) Low-Energy Energy Storage System (LEESS).The company laid off 125 workers in December 2011 as A123 had to issue a battery recall for all batteries in a car developed by Fisker.\nA123 Systems had more than 3000 employees as of December 2012.\n\nInvestments\nIn 2010 the company invested in Fisker Automotive's Karma with Ace Investments and Kleiner, Perkins, Caufield & Byers.The company formed a joint venture with SAIC Motor to manufacture its batteries in China in early 2010.In February 2018, A123 announced an investment in Ionic Materials' solid-state battery technology. Ionic is developing a unique polymer electrolyte that claims new levels of safety and performance in advanced batteries.\n\nProduct recall\nIn early 2012, the company announced the replacement of defective battery packs and modules supplied to about five customers, including Fisker Automotive. The defect caused a Fisker Karma to shut down in a Consumer Reports test. It estimated the recall would cost about US$55 million. Fisker reduced its purchase order of battery from the company to lower its inventory. Cylindrical cells made in China that are used by BMW and others were declared as not affected.\n\nWangxiang acquisition and bankruptcy\nIn August 2012, Chinese automotive components manufacturer Wanxiang Group agreed to invest up to $465 million to acquire as much as 80% of A123 Systems; but the acquisition was not completed before A123 filed for bankruptcy.\nIn early October 2012, the A123 Systems' stock was trading for 27 cents per share, down from a 52-week high of $4.44 per share about a year beforehand.On October 16, 2012, A123 filed for bankruptcy protection under Chapter 11. On January 28, 2013, Wanxiang America purchased the preponderance of A123's assets out of bankruptcy for $256.6M and organized A123Systems, LLC.An earlier statement, released by A123 Systems in early October, said that it had entered an asset purchase agreement with Johnson Controls, with the stipulation that the company's bid must be approved by a US bankruptcy court and could be topped by a rival bidder.\nJohnson did not win the bankruptcy auction and withdrew its bid in early December.On October 16, 2012, A123 filed for bankruptcy protection under Chapter 11. The filing listed assets of $459.8 million and liabilities of $376 million. The company also stated that its automotive assets would be purchased by Johnson Controls, a supplier to A123, for $125 million. On January 28, 2013, Wanxiang America purchased the preponderance of A123's assets out of bankruptcy for $256.6M and created A123Systems, LLC. The government business was sold to US firm Navitas Systems for $2.25m.\n\nLithium Werks sale\nIn March 2018, the US battery manufacturer Lithium Werks announced it took over the Chinese factory of A123 Systems in Changzhou, plus the workforce and clients base in China, Europe and the United States. After the merger the Texas-based company owns factories in China and offices in the US, the Netherlands, Northern Ireland, the UK and Norway.  Lithiumwerks continued the production of the 'nanophosphate' battery range, renaming the cells from 'A123' to 'Lithiumwerks' by the end of 2019.The A123 company said it wanted to concentrate on mobility solutions after the sale of their plants.\n\nProducts\nTransportation\nPassenger vehiclesFisker Karma, a plug-in hybrid\nTaxis in Tokyo, Japan. Better Place is running a demonstration project with three electric taxis powered by A123 Systems batteries.\nThe Roewe 750 hybrid, the Roewe 550 plug-in hybrid and a yet-to-be-announced Roewe-brand all-electric vehicle from Shanghai Automotive Industry Corporation (SAIC), the largest automaker in China\nChevrolet Spark EV, a city electric car to be produced by General Motors and scheduled to be sold in low volumes at select U.S. (including California) and global markets beginning in 2013.\nIn May 2011, A123 introduced a lithium ion 12V engine starter battery designed as a lighter-weight, longer-lasting and more environmentally friendly drop-in replacement for lead acid batteries. A123's Nanophosphate® Engine Start Battery was selected to R&D Magazine's 2011 R&D 100, which salutes the 100 most technologically significant products introduced into the marketplace over the past year.Commercial truck, bus, and off-highwayNavistar International EStar: Electric Vehicle (EV) delivery vehicle\nDaimler Buses North America (Orion VII). The number one selling hybrid electric bus in the world. Operating in New York, San Francisco, Toronto, Dallas and other major cities.\nEaton: Plug-in hybrid Trouble Truck based on Ford F550 [1]\nSmith Electric Vehicles Newton, an all-electric zero-emission delivery truck\nALTe, a maker of range-extended hybrid electric powertrain systems targeting the light-duty truck marketRacing2009 McLaren Mercedes Formula 1 KERS race car\nKillacycle, formerly the world's quickest electric vehicle, capable of accelerating from 0–100 kilometres per hour (0–62 mph) in less than 1 second.\nOhio State University's Buckeye Bullet, an electric landspeed racer powered by A123's batteries, broke the international electric vehicle speed record in August 2010, reaching 307.666 m.p.h.\nIn May 2011, A123 signed an agreement with Mavizen, a leader in electric motorcycle racing technology, by which Mavizen will make A123's battery technology available for TTXGP racing and other two-wheel motorsports.\nAn ultra-light electric vehicle powered by 880 A123 Li-PO4 batteries, Brigham Young University's Electric Blue Streamliner set a land speed record for the 'E1' vehicle class (cars less than 1,100 lbs), averaging 204.9 m.p.h. in two runs in September 2014.\n\nElectric grid\nIn November 2008, A123 entered into the electric grid market by delivering its first battery energy storage system to AES Corporation for use at several AES substations in Southern California.\nIn November 2009, A123 announced the commercial operation of a 12MW operating reserve project at the AES Gener Los Andes substation in the Atacama Desert in Chile.\nIn December 2010, AES Corporation secured a loan from the United States Department of Energy to fund a 20MW frequency regulation energy storage system using A123's battery technology at the AES Westover power plant in Johnson City, New York.\nIn February 2011, A123 announced its second project in Chile with AES Gener—a 20MW operating reserve energy storage system to be installed at a new 500MW power plant in Northern Chile called Angamos.\nIn July 2011, A123 announced a contract to supply a 500 kW advanced energy storage system to Dongfang Electric, the third largest manufacturer of wind turbines in China and the country's largest exporter of power equipment, as a demonstration project to help evaluate how advanced energy storage can address the challenges associated with the rapid growth of wind power in China, where only about 72% of the country's wind turbines are connected to the power grid, according to the China Power Union.\nIn October 2011, AES Corporation unveiled a 32 MW energy storage systems featuring A123's battery technology at the Laurel Mountain Wind Farm in West Virginia to be used for renewable integration and frequency regulation. As of its commissioning date it was the largest Lithium Ion battery energy storage system of its kind then in operation. This site was successfully commissioned in December 2011.\nIn March 2014, Japan's NEC announced its purchase of A123's grid energy storage business for $100 million.\n\nSmall applications\nBlack & Decker and DeWalt power tool lines were early adopters of A123 cells.\n\nCells\nA123 had LiFePO4 Cells in the form 18650, 26650 and Pouch Cells with 14 and 20Ah. The company EVLithium reports that A123 has additional Pouch cells: A123 38AH NMC Lithium ion Pouch Battery and A123 LiFePO4 Battery 50AH http://www.evlithium.com/A123-Battery/\n\nSee also\nNavistar\nPassage 3:\nTax consolidation\nTax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation.\nThe aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. For companies, consolidating can help understate profits by having losses in one group company reduce profits for another. Assets can be transferred between group companies without triggering a tax on gain for the company receiving assets, dividends can be paid between group companies without incurring tax liabilities, and tax attributes of one group company such as imputation credits can be used by other companies in the group. In some jurisdictions there may be other benefits, such as the ability to look through the acquisition of shares of acquired companies to depreciate the underlying assets.\nCountries which have adopted a tax consolidation regime include the United States, France, Australia and New Zealand. Countries which do not permit tax consolidation often have rules which provide some of the benefits.  For example, the United Kingdom has a system of group relief, which permits profits of one group company to be reduced by losses of another group company.\nConsolidation regimes can include onerous rules and regulations. There are typically complex rules to deal with the acquisition of companies with tax losses or other tax attributes.  Both the United States and Australia have rules which restrict the use of such losses in the wider group. In Australia, fixed trusts and 100% partnerships can be members of a consolidated group, but the head company must be a company and cannot be a trust or partnership.\n\nUnited States consolidated returns\nUnited States federal income tax rules permit commonly controlled corporations to file a consolidated return.  The income tax and credits of the consolidated group are computed as if the group were a single taxpayer.  Intercorporate dividends are eliminated.  Once a group has elected to file a consolidated return, all members joining the group must participate in the filing.  The common parent corporation files returns, and is entitled to make all elections related to tax matters.  The common parent acts as agent for the members, and it and the members remain jointly and severally liable for all federal income taxes.  Many U.S. states permit or require consolidated returns for corporations filing federal consolidated returns.\n\nRequirements for filing\nOnly entities organized in the United States and treated as corporations may file a consolidated Federal income tax return.  The return is filed by a “common parent” and only those subsidiaries in which the common parent owns 80% or more of the vote AND value.  The parent and all subsidiaries must file Form 1122 to elect to file a consolidated return in the first year of election. Every 80% subsidiary must make the election or it is not valid.  Thereafter, all corporations that begin to meet the 80% vote and value test must join in the consolidated return.  If a subsidiary ceases to meet the 80% vote and value test, it is removed from the group.  Adjustments to basis and other tax attributes apply upon a subsidiary joining or leaving a group.\n\nConsolidated taxable income\nTaxable income of each member is computed as if no consolidated return were filed, with the exception of certain items computed on a consolidated basis.  Then adjustments are made for certain transactions between group members.  Dividends between group members are eliminated.  Sales of property between members give rise to a deferred intercompany transaction.  The effect on the selling member is deferred and recognized as the corresponding effects are recognized by the buying member.  For example, Member A sells Member B some goods at a profit.  This profit is not recognized until Member B sells the goods or recognizes depreciation expense on the goods.  These complex rules require adjustments related to intra-group sales of property (including depreciable assets and inventory), transactions in stock or other obligations of members, performance of services, entry and exit of members, and certain back-to-back and avoidance transactions.\nCertain deductions and most credits are computed on a consolidated rather than separate company basis.  These include the deductions for net operating loss, charitable contributions, domestic production activities deduction, dividends received deduction and others.\n\nBasis and related items\nEach member of a group must recognize gain or loss on disposition of its shares of other members.  Such gain or loss is affected by the member's basis in such shares.  Basis must be adjusted for several items, including taxable income or loss recognized by the other member, distributions, and certain other items.  To the extent a member recognizes losses in excess of the owner's basis, such excess loss is treated as negative basis for all U.S. Federal income tax purposes.  Additional adjustments apply in the case of intra-group reorganizations or acquisition of the common parent, and upon entry to or exit from the group by a member.  The adjustments “tier up” to consolidated return members who own shares of the entity making the adjustment.  Numerous other adjustments apply.\n\nFiling periods\nAll members of the group must use the same tax year as the common parent.  This may be adopted or changed by the common parent.  If one group acquires another group, the acquiring common parent's tax year must be adopted by all acquired subsidiaries then meeting the 80% vote and value test.  Short periods may be required upon joining or leaving a group.  In addition, if a member enters or leaves the group, certain adjustments to earnings and profits, basis, and other tax attributes apply.\n\nFiscal unity\nSeveral countries allow related groups of corporations to compute income tax on a consolidated basis, in a manner similar to consolidation for financial reporting purposes.  This is referred to in the Netherlands and Luxembourg as a Fiscal Unity, and in France as Intégration Fiscale.  A similar consolidated return regime applies in Spain.  In such systems, consolidating eliminations of income and expense are taken into account.\nThe Netherlands system allows a group of Netherlands resident corporations and branches of foreign corporations to elect to be taxed as a Fiscal Unity.  Such election is permitted only for a parent corporation and its 95% or greater owned subsidiaries.  Upon election, the parent is taxed on the combined income of the members of the group.  The parent and subsidiaries retain joint and several liability for the tax of the group.Netherlands fiscal unity functions much like financial statement consolidation.  Intra-group transactions, including property transfers, are generally eliminated.  Most intra-group reorganizations do not trigger taxable events.\n\nGroup relief\nSome countries allow losses of one commonly controlled company to offset the profits of another commonly controlled company.  The United Kingdom permits group relief, and Germany permits an Organschaft.  Neither of these systems involve combined reporting or combined tax return filing, though certain additional reporting may be required.Under the UK scheme, a company's losses may be surrendered to a related company if several conditions are met.  The companies must be 75% owned companies.  For this purpose, a parent company and its subsidiaries qualify if the parent company owns at least 75% of the ordinary share capital of the subsidiary(ies) and have a beneficial interest in at least 75% of any distributions of earnings or upon winding up.  Alternative similar rules apply for certain consortia and branches.  Under European Court of Justice rulings incorporated into UK law, the parent company need not be resident in the UK.\nThe UK scheme allows losses of one group member to be relieved (deducted) by members using a different accounting period, with certain adjustments.  Trading (business) losses, capital losses, certain excess (disallowed) management expenses from non-UK affiliates, and certain excess charges may be relieved, subject to limitations.  The surrender of these items is done by one company for the benefit of one other company.\n\nUnitary groups\nSome states in the United States require related corporations to file a consolidated return if such corporations constitute a unitary business or unitary group.  Such consolidated returns tend to follow the pattern of United States Federal consolidated returns, though differences exist in the particular rules.  Generally, a group of corporations in the same, similar, or integrated businesses that are under common management and operational control may be treated as a unitary group.\nIn a late June, 1983 decision, the US Supreme Court first sanctioned worldwide combined reporting in Container Corp. v. Franchise Tax Board (CA). The years in question were 1963-1965 and the California corporate income tax rate was 5.5%. The additional amount of tax due applying the worldwide combined reporting method was less than $72,000. The vote was 5–3,  Justice John Paul Stevens did not participate.\nThe court's majority decision was written by Justice Brennan, joined by White, Marshall, Blackmun, and Rehnquist. Justice Powell wrote the dissenting opinion, joined by Burger and O'Connor.  Friend-of-the-court amicus curiae briefs were filed in support of California by the Attorneys General of Idaho, Utah, Illinois, Montana, New Mexico, New York, North Dakota, Oregon, Alaska, Colorado, Connecticut, Delaware, Indiana, Kansas, Massachusetts, Michigan, Nebraska, Minnesota, Missouri, New Hampshire, North Carolina, Hawaii, and Vermont. Also, in support of California, briefs were filed by the National Governors' Association, the National Farmers Union, and the Citizens for Tax Justice.\nIn support of the Container Corporation, amicus briefs were filed by Allied Lyons, Coca-Cola, Colgate-Palmolive, EMI Limited, Firestone Tire & Rubber, Canadian Imperial Bank of Commerce, Caterpillar Tractor, Gulf Oil, Phillips Petroleum, Shell Oil, and Sony. Also, in support of Container, were briefs filed by the U.S. Chamber of Commerce's Committee on State Taxation, the Financial Executives Institute, the Government of the Kingdom of the Netherlands, the Confederation of British Industry, the International Bankers Association in California, and the Union of Industries of the European Union.\nThe Working Group agreed on three principles that should guide state taxation of the income of multinational corporations:\nPrinciple One: Water's edge unitary combination for both U.S. and foreign based companies.\nPrinciple Two: Increased federal administrative assistance and cooperation with the states to promote full taxpayer disclosure and accountability.\nPrinciple Three: Competitive balance for U.S. multinationals, foreign multinationals, and purely domestic businesses.California adopted a requirement that both United States and foreign corporations be included in a worldwide unitary group filing, absent a “water's edge” election and fee.  This requirement was limited somewhat by the U.S. Supreme Court in Barclays Bank PLC v. Franchise Tax Board. The vote in that case was 7–2 in favor of California and 9–0 in the companion Colgate-Palmolive case. California subsequently repealed the “water's edge” fee.  Illinois requires unitary group filings for United States corporations only.\nUnder the unitary concept, all commonly controlled corporations within the unitary management and control group are required to join in a consolidated return filing for the state. An example of why a state would adopt unitary combined reporting is in the Statement of Intent in section 152 of Vermont's 2004 Act:\n\nIn recognition of the fact that corporate business is increasingly conducted on a national and international basis, it is the intent of the general assembly to adopt a unitary combined system of income tax reporting for corporations, and as an integral part of this proposal, to lower the corporate income tax rates. Vermont's separate accounting system is inadequate to measure accurately the income of a corporation with non-Vermont affiliates and creates tax disadvantages for Vermont corporations which compete with multistate and multinational corporations doing business in Vermont. It is the intent of the general assembly, in adopting a unitary combined reporting system, to put all corporations doing business in Vermont on an equal income tax footing, and with the revenue from the expanded and more accurate tax base, to lower Vermont's corporate income tax rates.\nThe enabling statute, however, excludes \"overseas business organizations\" from the taxable combined group so water's edge instead of worldwide combined reporting is adopted. Therefore, purely domestic businesses (i.e. national multi-state corporations) are subject to tax on 100% of their taxable profits, U.S. based multinational corporations are subject to tax on 100% of their reported U.S. profits plus foreign profits via repatriated dividends from foreign subsidiaries (if and when repatriated), and foreign based multinational corporations are subject to tax on 100% of their U.S. subsidiaries' reported U.S.profits. As a result, under water's edge combined reporting, separate accounting is only ignored for purely domestic businesses but retained for multinational corporations. Per the 2003-2004 Biennial Report of the Vermont Commissioner of Taxes, the adoption of unitary combined reporting \"will diminish opportunities for certain aggressive tax management strategies that were available to multi-state corporations and will help create a level playing field with respect to Vermont-based corporations.\"\nTherefore, under water's edge, U.S. based and foreign-based multinationals have the ability to shift U.S. profits to foreign subsidiaries and avoid federal and state income taxes. Profits shifted out of the U.S. would be taxed only if and when they are repatriated as foreign dividends to a U.S. based multinational. Most foreign countries do not tax foreign dividends received by multinationals based in their countries so profits shifted out of the U.S. by U.S. subsidiaries owned by foreign based multinationals and later repatriated to the foreign parent are usually not taxed.\nThe State of New Hampshire adopted worldwide combined reporting in 1981 but restricted it to water's edge five years later in 1986. In 1999, in Caterpillar Inc. v. New Hampshire Department of Revenue, the court stated \"We point out that the water's edge method was adopted for the benefit of foreign businesses.\"Approaching 30 years since the 1984 principals of the Worldwide Unitary Tax Working Group, it is questionable whether or not a competitive balance for U.S. multinationals, foreign multinationals, and purely domestic businesses has been attained. Bloomberg reporter Jesse Drucker demonstrates that separate accounting/arm's length pricing favors the multinationals in an October 2010 article titled \"Google 2.4% Rate Shows How $60 Billion Lost to Loopholes\" with tax strategies known as the \"Double Irish\" and the \"Dutch Sandwich.\"   In a New York Times October 2012 Dealbook column, Victor Fleischer wrote about \"Overseas Cash And The Tax Games Multinationals Play.\" Although billions in corporate profits are reported to be on the books of foreign subsidiaries located in tax havens, a New York Times article by David Kocieniewski titled \"For U.S. Companies, Money Offshore Mean Manhattan\" dated May 2013, indicates that those corporate profits are being utilized in the U.S. This is supported by a more recent report by Kitty Richards and John Craig at the Center for American Progress titled \"Offshore Corporate Profits - The Only Thing 'Trapped' is Tax Revenue\"  An article by Floyd Norris in the May 23, 2013 New York Times, \"The Corrosive Effect of Apple's Tax Avoidance\", points out how these tax avoidance strategies will most likely be followed by many other multinational corporations. And, an article by David Gelles titled \"New Corporate Shelter: A Merger Abroad\" dated October 8, 2013 makes a case that the best tax strategy for a U.S. based corporation is to become a foreign based corporation.The apportionment factors for state income tax are computed on a consolidated basis and applied to the income of members doing business in the state.  Illinois taxes only United States corporations in this manner.  California, following the Barclays case, modified its rules to include in the combined reporting only the taxable income of United States corporations.  California's computation of apportionment factors is still based on worldwide group amounts unless a “water's edge” election is made.\n\nFurther reading\nCrestol, Jack; Hennessey, Kevin M., and Yates, Richard F.:  \"Consolidated Tax Return : Principles, Practice, Planning, 1998 ISBN 978-0-7913-1629-0\nHellerstein, Jerome & Walter, and Youngman, Joan: State and Local Taxation, ISBN 0-314-15376-4.\nPassage 4:\nGlénat Editions\nGlénat Editions SA is a French publisher with its head office in Grenoble. Their products include comic albums and manga in France, Benelux, and in the past Spain; it was founded by Jacques Glénat. The Benelux subsidiary, Glénat Benelux N.V., is located in Brussels, Belgium. The Switzerland subsidiary, Glénat Editions (Suisse) SA, has its headquarters in Nyon. The Spanish subsidiary had its head office in Barcelona.\n\nHistory\nJacques Glénat started his comics fanzine Schtroumpf (the French, original, title of The Smurfs) in 1969, when he was still a student. In 1972, only twenty years old, he established his own publishing house, Glénat. The first two books were by Claude Serre and by Claire Bretécher. Two years later, he already received the award for best publisher at the Angoulême International Comics Festival. To support the rapid growth, the company opened warehouses in Orly near Paris, and a flagship store in Paris.\nA new comics magazine, Circus, first appeared in 1975 and existed until 1989. But the next few years saw Glénat move more away from the traditional juvenile Franco-Belgian comics and more towards the graphic novel, with an emphasis on their successful historical series by François Bourgeon and André Juillard. A second magazine, Vécu, dedicated to historical comics, was created in 1985 and survived until 2004.\nFrom 1980 on, Glénat also published non-fiction books related to mountain climbing and to the sea. They also bought the publisher Vents d'Ouest and from 1991 on started publishing manga. But the biggest success of all came with Titeuf by Zep, which soon was one of the bestselling French comic series, with its own magazine Tchô and animated series.\nOn 5 October 2011, yielded 100% of the capital of Glénat España to Joan Navarro and Félix Sabaté, the two heads of the former subsidiary.\n\nCompany\nAs of 2009, the company gets 50% of its turnover from comics, 20% from manga, and 15% from books, with the last 15% divided over smaller products.\nThe book division has a catalogue of over 4,000 titles, publishing some 400 new books and 12 million volumes a year. Bestselling series include Titeuf, with 16 million copies, and Dragon Ball, with 17 million copies. It is the second largest comics publishing group in France, behind Média-Participations, with some 20% of the market.\nThe company has two international subsidiaries, Glénat Benelux and Glénat Suisse (Switzerland). The company is also very active in Canada and collaborates with other publishers in other countries. Apart from translating and distributing the original Glénat productions, these regional companies also produce their own content and specializations. Glénat Benelux has 13% of the market of Belgian comic shops.\n\nHead office\nThe company head office is in central Grenoble, in the former Convent of St. Cecilia, a 17th-century building which previously hosted a theater. Jacques Glénat had the building restored so it could become the headquarters of the company. The building's restoration took five years to complete. 100 employees work in the building. The building's archives, library, and private collection are open to the public.\n\nAwards\n1974: Best French Publisher at the Angoulême International Comics Festival, France\n\nGallery\nPassage 5:\nWanxiang\nWanxiang Group Corporation (Chinese: 万向集团) is a Chinese multinational conglomerate, headquartered in Hangzhou, Zhejiang province, China.  Its automotive components subsidiary (Wangxiang Qiaochao) is the largest China-based automotive components company measured by revenues. The company was founded in 1969 by Lu Guanqiu.\n\nSubsidiaries\nWangxiang Qianchao Co., Ltd.\nWangxiang Qiaochao Co., Ltd. is a public company listed on Shenzhen Stock Exchange (Symbol 000559).\n\nA123 Systems, LLC\nOn October 16, 2012, A123 Systems had filed for bankruptcy protection under Chapter 11, Title 11, United States Code. Wanxiang won an auction for the bankrupt United States-based lithium-ion battery maker in December 2012 for a closing price of US$256.6 million.\nA123 Systems had more than 3000 employees as of that date.The Committee on Foreign Investment in the United States (CFIUS) granted its approval, and on January 28, 2013, Wanxiang Group's Chicago-based subsidiary, Wanxiang America, purchased the preponderance of A123's assets out of bankruptcy for US$256.6 million and organized a new company, similarly named A123Systems, LLC.\n\nKarma Automotive\nWanxiang received U.S. bankruptcy court approval on February 18, 2014, to buy the assets of Fisker Automotive, a manufacturer of plug-in hybrid sports cars which was declared bankrupt in November 2013. Wanxiang's American subsidiary won a three-day auction with a bid of US$149.2 million. Bidding had started at US$55 million. The company said in court papers that it could restart production in the coming months, estimating that it would sell more than 1,000 Fisker Karma cars in the first 18 months in the U.S. and 500 in Europe. The automotive company was renamed to Karma Automotive, and their car was renamed Revero.\n\nSAIC Wanxiang New Energy Coach Co., Ltd.\nSAIC Motor Corporation and Wanxiang Group have set up a 49%-51% joint venture, known as SAIC Wanxiang New Energy Coach Co., Ltd. and acquired the license to manufacture vehicles in July 2015. The joint-venture plans to produce its first new alternative fueled coach after granted with license plates by Chinese authorities after a few years of operation.\n\nSee also\nAutomotive industry in China\nPassage 6:\nTongil Industries Company\nTongil Group (Korean: 통일그룹) is a Korean business group (chaebol) associated with the Unification Church (UC). (“Tongil” is Korean for “unification,”  the name of the Unification Church in Korean is “Tongilgyo.”)  It was founded in 1963 by Unification Church founder Sun Myung Moon (following the purchase of a surplus Japanese lathe in 1962) as a nonprofit organization which would provide revenue for the UC. Its core focus was manufacturing but in the 1970s and 1980s it expanded by founding or acquiring businesses in pharmaceuticals, tourism, and publishing.In 1998 Tongil Group was about 35th in size among South Korean business groups and was in the process of expanding into North Korea, with the blessing of the South Korean government which had previously forbidden relationships between North Korea and South Korean businesses.In the 1990s Tongil Group suffered as a result of the 1997 Asian Financial Crisis. By 2004 it was losing money and was $3.6 billion in debt. In 2005 Moon’s son, Kook-jin Justin Moon (founder of Kahr Arms) was appointed chairman of Tongil Group. As of 2010 he was in the process of reforming its businesses by hiring new managers and by closing unprofitable operations. Among Tongil Group’s chief holdings are: The Ilwha Company, which produces ginseng and related products; Ilshin Stone, building materials; and Tongil Heavy Industries, machine parts including hardware for the South Korean military. \nThe Tongil Group funds the Tongil Foundation which finances about 20 religious and educational institutions, including the Sun Moon University, and the Little Angels Children’s Folk Ballet of Korea. And it donates to the UC, how much and whether by personal or corporate channels, is not public.\nPassage 7:\nKeep Your Head Down (song)\n\"Keep Your Head Down\" (Korean title: 왜 Wae; \"Why\"), released in Japan as \"Why? (Keep Your Head Down)\", is a song recorded by South Korean pop group TVXQ (or Tohoshinki in Japan). Composed by Yoo Young-jin and Yoo Han-jin, the Korean-language version of \"Keep Your Head Down\" was released by S.M. Entertainment on January 3, 2011 as the lead single for the group's fifth Korean studio album Keep Your Head Down (2011), TVXQ's first album since becoming a two-piece band with U-Know Yunho and Max Changmin. The Japanese-language version of \"Keep Your Head Down\", which was released on January 26, 2011, by Avex Trax, served as TVXQ's 31st Japanese single in Japan. It was the first single taken from their fifth Japanese studio album, Tone (2011).\nWith elements of industrial hip hop and baroque pop, \"Keep Your Head Down\" is labeled as an SMP song, a staple genre in TVXQ's music. A sample of the song's original Korean-language version was first performed by Yunho at the SM Town Live '10 World Tour in August 2010, three months before the official announcement of TVXQ's Korean comeback. The full Korean single was released on January 3, 2011, which was accompanied by the premiere of its music video on TVXQ's official video-sharing websites.\nThe song was met with mixed reviews upon its debut. With lyrics talking about overcoming a relationship breakup, it was claimed that the song was a diss to JYJ, the three former members of TVXQ. Yunho and Changmin had denied the claims. Pervasively, \"Keep Your Head Down\" became one of the duo's most commercially successful songs. It topped real-time music charts upon its release and peaked at number five on Korea's Gaon Singles Chart. The song won seven music show trophies for three consecutive weeks and sold over 1.3 million digital units in South Korea by the end of the year. In Japan, \"Keep Your Head Down\" was TVXQ's ninth single to top Japan's Oricon Singles Chart. It was certified platinum by the Recording Industry Association of Japan (RIAJ), becoming TVXQ's second best-selling single in Japan. The Japanese version was used in the Japanese Wii game Just Dance Wii\n\nBackground and recording\n\"Keep Your Head Down\", also known by its Korean title \"Why\" (왜), was composed by brothers Yoo Han-jin and Yoo Young-jin, who also wrote the song lyrics. An SMP song, \"Keep Your Head Down\" has musical influences of industrial hip hop, baroque pop, R&B, and rap. The song was originally written for Yunho, who recorded the song in early August 2010 and performed it at the SM Town Live '10 World Tour concert in Seoul on August 21, 2010. The Seoul concert marked Yunho and Changmin's first comeback appearance together since their split with former TVXQ members Kim Jae-joong, Park Yoo-chun, and Kim Jun-su in early 2010. The positive responses in their two-piece performances prompted Yunho and Changmin to return to the studios to finish the recording of TVXQ's fifth Korean studio album. \"Keep Your Head Down\" was then chosen as the lead single.\nThe song debuted on South Korea's digital charts on January 3, 2011, the same day as the premiere of the song's music video. The Japanese version of the song was released as a CD and DVD single on January 26, 2011.\n\nCritical response\n\"Keep Your Head Down\" received mixed responses upon its release, and its lyrics came under media scrutiny. Starting off with the self-empowering English opening lines \"Do you know what time it is? This is return of the King\", TVXQ sing about their determination to return stronger after breaking up with a former lover. The song ends with the protagonist claiming that his former lover has \"[been] erased, disappeared, died\" in his heart, and that she no longer ceases to exist.Korean netizens claimed that the song was a diss to former members Jaejoong, Yoochun, and Junsu, who were still in legal disputes with TVXQ's agency S.M. Entertainment at the time of the song's release. Yunho and Changmin clarified that the lyrics of \"Keep Your Head Down\" were not directed at the trio, and that the lyrics were written in a style that could be interpreted in different ways.\n\nFormats and track listings\nCharts\nCertifications\nCredits\nCredits adapted from album's liner notes.\n\nStudio\nSM Booming System – recording, mixing, digital editing\nSonic Korea – mastering\n\nPersonnel\nSM Entertainment – executive producer\nLee Soo-man – producer\nKim Young-min – executive supervisor\nTVXQ – vocals, background vocals\nLuna – Japanese lyrics\nYoo Young-jin – producer, Korean lyrics, composition, vocal directing, background vocals, recording, mixing, digital editing, music and sound supervisor\nYoo Han-jin – composition, arrangement\nJeon Hoon – mastering\nPassage 8:\nKarma Automotive\nKarma Automotive is a Chinese-owned American producer of luxury electric vehicles founded in 2014. Headquartered in Irvine, California, United States with an assembly plant located in Moreno Valley, Karma sells vehicles via its dealer network of locations in North America, Europe, South America, and the Middle East.\n\nHistory\nIn February 2014, Chinese auto-parts supplier Wanxiang Group purchased assets of Fisker Automotive for $149.2 million in a bankruptcy auction. These assets included designs, a plug-in hybrid powertrain, and the former Wilmington Assembly factory in Wilmington, Delaware. Fisker Automotive was founded in 2007 by Henrik Fisker and his business partner Bernhard Koehler. Its Fisker Karma plug-in hybrid sports sedan debuted in 2011, and about 2,000 of the vehicles were sold. After Fisker's battery supplier A123 Systems filed for bankruptcy after two battery recalls, Fisker Automotive could not continue its business operations, and the company declared bankruptcy in February 2014 which led to the Wanxiang acquisition. The purchase excluded the Fisker brand and trademarks owned by Henrik Fisker. Wanxiang also purchased A123 Systems following its bankruptcy declaration.In early 2016, Karma Automotive enlisted a straw buyer in an attempt to reverse engineer technology from a parts supplier and former employee.In October 2016, the Wilmington, Delaware factory was put up for sale by Wanxiang Group.The company began building the Revero in 2016 at its factory in Moreno Valley, California, with production set to begin in late 2016. The Revero debuted on September 8, 2016. Karma plans to manufacture 3,000 of the vehicles. Karma hopes to build close to 150 cars in 2018, and in the 200 to 300 range of cars in 2019 and beyond. On April 11, 2019, Karma Automotive issued a recall and stop-sale order on all Revero vehicles, due to a flaw in the roll over sensors which would disable the side-curtain airbags.In 2019, the company opened the Karma's Innovation and Customization Center. In conjunction with the opening, Karma announced a design and manufacturing partnership with electric vehicle company AYRO to build 20,000 electric delivery vehicles by 2023. Karma’s Innovation and Customization Center has the ability to build the frames, chassis and bodies, integrate the powertrain and finish the cars in its robotic paint shop.In November 2019, Karma Automotive laid off 200 employees at its Irvine, California headquarters due to financial difficulty. In February 2020, the company laid off an additional 60 employees.In July 2020, the company raised $100 million USD from outside investors. Karma announced its intentions to license its electric vehicle platform to other automakers in order to generate more revenue.In November 2020, Karma sued Lordstown Motors in a technology dispute.\n\nModels\nProduction models\nRevero\nThe Revero is a luxury electric hybrid sedan. The model was awarded Luxury Green Car of the Year by Green Car Journal in 2018. The model's total cruising range is approximately 300 miles with combined electric and combustion engine power, while electric power alone provides an estimated 50 miles (80 km).\n\nRevero GT\nThe Revero GT is a luxury extended-range electric vehicle. The model was awarded the 2020 Luxury Green Car of the Year Award from Green Car Journal in 2020. The GT model is differentiated from the standard Revero model by a launch control feature and increased acceleration (0 to 60mph in approximately 4.5 seconds). The model's total cruising range is approximately 360 miles (580 km) with combined electric and combustion engine power, and approximately 80 miles (130 km) with only electric power. Karma plans to remake the Revero GT as its halo vehicle, upgrading the model with an all-wheel-drive powertrain said to offer in excess of 1,100 hp.\n\nGS Series\nThe GS Series is a new vehicle line introduced in 2021. The series includes the company's first battery-electric sedan. In addition, the company announced plans to reduce the prices of the GS line.\n\nGS-6\nThe GS-6 is a range-extended, plug-in hybrid vehicle capable of traveling up to 330 miles (530 km) with combined electric and combustion engine power. The GS-6 has a 400-kw, two-motor propulsion system that outputs 536 hp and 550 lb-ft of torque.\n\nGSe-6\nThe GSe-6 is an all-electric vehicle, holding an 85-kWh battery pack that provides up to 230 miles (370 km) of range. A version with a 105-kWh pack & more than 300 miles (480 km) of range is in development. The GS-6 has a 400-kw, two-motor propulsion system that outputs 536 hp and 550 lb-ft of torque.\n\nConcept cars\nKarma GT by Pininfarina\nThe Karma GT by Pininfarina is a range-extender luxury electric hybrid coupe, based on the 2020 Revero chassis with a body by Pininfarina. It was introduced at the 2019 Shanghai Auto Show.\n\nSC1 Vision Concept\nThe Karma SC1 Vision Concept is a roofless scissor-doored working fully electric sports car concept. It was introduced at the 2019 Shanghai Auto Show.\n\nSC2 Concept\nThe Karma SC2 Concept is a scissor-doored working fully electric sports car concept. It was unveiled on the eve of the 2019 Los Angeles Auto Show. It was named 2020's Concept Car of the Year by Robb Report in their \"Best of Best\" issue.\n\nSee also\nFisker Coachbuild (2005–2007)\nFisker Automotive (2007–2014)\nFisker Inc. (2016–present)\nVLF Automotive\nPassage 9:\nCopterline Oy\nCopterline Oy was Finland's largest helicopter airline established on 15 October 1990 as Copter Action and renamed to Copterline in 2000. In 2004 the company ferried over 75,000 passengers. On December 19, 2008, Copterline confirmed that it had ceased its scheduled service between Helsinki and Tallinn. On 15 February 2010, Copterline filed for bankruptcy, citing inability to keep the company profitable. Its head office was located on the grounds of Helsinki-Malmi Airport in Helsinki.  In 2011, Line Support Oy, founded by mostly the same group as Copterline Oy, announced a resumption of service from September, operated by its Estonian subsidiary Copterline OÜ. On 9 September 2011, the first commercial flights were undertaken.\n\nHistory\nCopterline acquired Helikopteripalvelu in 1999, the oldest Finnish company in the business, and began offering services in 2000.Copterline used to maintain hourly passenger flights across the Gulf of Finland between Helsinki, Finland (Helsinki Hernesaari Heliport) and Tallinn, Estonia (Tallinn Linnahall Heliport) between 07:00–20:00 (14 round trips),  9:00–17:00 on Saturdays (9 round trips) and 10:00–16:00 on Sundays (7 round trips). The trip took 18 minutes, and the helicopters could carry 12 passengers on each flight.On 10 August 2005, Copterline Flight 103 crashed while flying between Tallinn and Helsinki, three kilometers south of Aegna island. All 14 people on board died. After that tragic accident, the company closed the route.In August 2006, Copterline sold its last remaining S-76 and focused on charter flights resuming the route between Helsinki and Tallinn on April 9, 2008, with a new AgustaWestland AW139 helicopter. The company was planning a new terminal in Helsinki.\nIn August 2008, a second AW139 entered into the fleet, and started operating in the same route. Kaj Takolander became CEO of the company.\nOn 19 December 2008, Copterline confirmed that it had ceased its scheduled service between Helsinki and Tallinn and was now looking at the possibility of alternative uses for its helicopters, otherwise, it will sell or lease its aircraft.As of September 2011 the Copterline website was back in service with a flight schedule advertising flights up until the Christmas period. The new service was operated by the Estonian company Copterline OÜ with an AgustaWestland AW139 helicopter owned and operated by the Finnish company FirstClass Oy. The 2011 service offered 5 round trips on weekdays with no scheduled weekend service.\nCopterline has not been operating on the Helsinki-Tallinn route recently. The airline was planning to open the route again in August 2013, but these plans were postponed and later cancelled. The company currently provides helicopter services to the oil and energy sector on the North Sea.In March 2016, Copterline OÜ filed for bankruptcy for the second time.\n\nIncidents and accidents\nIn spring 2004, the company had been restricted from commercial flights in bad weather conditions, due to concerns about pilot qualifications, but the restriction had since been lifted.On 10 August 2005 Flight 103, a Sikorsky S-76, crashed into the sea near Tallinn, Estonia, three to four minutes after taking off. The craft was carrying 14 people, all of whom were killed: six Finnish, four Estonian and two American passengers, and two Finnish crew members. The disaster was caused by the failure of the power steering system of the American-built helicopter. According to Estonian authorities, no distress signals of any kind were received. However, after examining the helicopter's black box it has been reported that the pilots had attempted sending one, but wasn't received because an air traffic controller in Tallinn Airport was reading back a landing permit. The black box also revealed that the pilots had remained calm and attempted a safe landing in a \"by the book\" fashion.The cause of the accident was the failure of the power flying control system. Plasma coating on the pistons of the power flying control system had flaked off and blocked the return valve, causing the aircraft to lose its maneuverability. It was revealed in 2007 that the failed component was inside a system that Copterline did not have the authority to service or even open. A periodic leak test that could have revealed the problem was omitted. Furthermore, the emergency floats failed to operate. The manufacturer, Sikorsky, confirmed that damages have been paid to the families of the casualties, but a court case between Copterline and Sikorsky is still pending.\n\nFleet\nThe Copterline fleet consists of nine helicopters and several rescue craft.\nCopterline uses four Eurocopter EC 135 helicopters for emergency and medical service operations from three different base: Oulu, Pete got moved from Vaasa to Tampere and Varkaus.\nPassage 10:\nFisker Automotive\nFisker Automotive was an American company founded in 2007. It was known for producing the Fisker Karma, which was one of the world's first production luxury plug-in hybrid electric vehicles. The company was founded by Henrik Fisker, a Danish automobile designer. \nThe company received significant private and public investment, including a $529 million loan from the federal government. The company raised over $1 billion from private investors such as the Kleiner Perkins venture capital firm.However, it repeatedly missed production deadlines and production of the Fisker Karma was suspended in November 2012 with about 2,450 Karmas built since 2011 and just over 2,000 cars sold worldwide. The New York Times described the company as the \"Solyndra of the electric car industry\" and a \"debacle\". The company's federal loan was suspended in 2011; the government recovered some of the invested funds, but nevertheless took a $139 million loss.In February 2014, Fisker Automotive's Karma vehicle design, tooling and a manufacturing facility in Delaware were purchased by Chinese auto parts conglomerate Wanxiang Group. In 2016, Wanxiang would rename the holding company for the assets of Fisker Automotive to Karma Automotive.\n\nHistory\nHenrik Fisker co-founded Fisker Automotive in 2007 with Fisker Coachbuild partner Bernhard Koehler and Quantum Technologies after securing U$5.2 million investment from Gianfranco Pizzuto, an Italian businessman, and Palo Alto Investors. Kleiner Perkins Caufield & Byers, a venture capital firm, was one of the early investors. Fisker is responsible for designing many premium cars such as the Aston Martin DB9 and V8 Vantage, Artega GT, and BMW Z8. He also served as design director and sat on the board at Aston Martin.\nBefore Fisker Automotive, Fisker and Koehler left Aston Martin in 2005 to establish Fisker Coachbuild, in an attempt to revive the art of coach-building automobiles to customer specifications. The Fisker Tramonto and Latigo used chassis and power trains from Mercedes-Benz SL and BMW 6 Series automobiles. Several were purchased, but the business soon gave way to Fisker Automotive, a true automobile manufacturer.\nIn 2009, Fisker mentioned plans for another plug-in hybrid, a \"high-volume vehicle for a lower price\", subject to getting a U.S. Department of Energy loan to build about 100,000 vehicles annually in the United States.On April 14, 2008, Tesla Motors filed a lawsuit against Fisker Automotive, alleging they stole Tesla's technology and were using it to develop their own hybrid car, the Fisker Karma, which was announced at the North American International Auto Show in January 2008. Tesla's suit claimed that the design work done for the Model S by Fisker Coachbuild was substandard, and that Fisker diverted its best ideas to the Karma. In early 2009, the suit was settled in Fisker's favor and Tesla was ordered to pay Fisker more than US$1.1 million in legal fees.Fisker's problems started with a recall of its battery by supplier A123 systems in December 2011, followed by a second recall in March 2012, and eventually A123 Systems' bankruptcy in August 2012. In addition to production stopping for over five months, with no date announced to recommence, the planned production of the second model, the Fisker Atlantic, was postponed, together with the cessation of development of the new model.\nIn February 2012, Tom LaSorda was named the new CEO, and Henrik Fisker became executive chairman, but six months later on August 14, La Sorda was replaced by Tony Posawatz, previously General Motors Vehicle Line Director for the Chevrolet Volt.The company suffered a setback on October 29, 2012, when Hurricane Sandy flooded and destroyed its entire European shipment of 338 Karmas at Port Newark, New Jersey. Sixteen of the cars burned, because six to eight feet of seawater caused a short circuit in a vehicle control unit in one Karma, and high winds spread the resulting fire to 15 others. The company said that its lithium-ion battery was not at fault. Insurer XL Insurance America initially denied the roughly US$30 million loss claim and was subsequently sued by Fisker in New York State Supreme Court. The case was settled with an undisclosed out-of-court agreement.Henrik Fisker resigned in March 2013, after \"disagreements with management\", in particular \"disagreements over business strategy\". Shortly after the departure of Henrik Fisker from Fisker Automotive, on April 5, 2013, Fisker laid off 75% of its workforce, retaining only a core group of 40 workers as it continued to negotiate with prospective investors.On October 11, 2013, Hybrid Technology LLC agreed to buy Fisker's defaulted government loan at a heavy discount. On November 22, 2013, Fisker filed its Chapter 11 bankruptcy case. Concurrently, on November 23, 2013, Fisker agreed, subject to bankruptcy court approval, to be acquired by Hybrid, owned by Hong Kong billionaire, Richard Li. At the last moment, though, Chinese parts supplier Wanxiang Group submitted a competing bid of US$24.75 million, supported by the Official Creditors' Committee in the case. Wanxiang had earlier lost out to Hybrid in bidding for purchase of the government's loan to Fisker. Wanxiang owns A123 Systems LLC, Fisker's former battery supplier, and Fisker argued that Wanxiang's conduct was partly responsible for Fisker's business failure. As part of its bid, Wanxiang proposed restarting production of the Karma.Wanxiang received court approval on February 18, 2014, to buy the assets of Fisker after a three-day auction against Hybrid with a bid of $149.2 million, with bidding starting at $55 million, significantly more than the previous $24.75 million bid, and significantly higher than the $25 million Hybrid Technology LLC paid the Department of Energy for a $164 million loan note. On top of the $25 million, the DOE also recouped $28 million from Fisker for a total of $53 million recovered of its $192 million loan.Following Fisker Automotive's structured bankruptcy auction in February 2014, Henrik Fisker retained the Fisker logo and trademarks. Wanxiang Group then transformed the assets of Fisker Automotive into a new company named Karma Automotive, thus launching the Karma Revero plug-in hybrid car based on the Fisker Karma. Henrik Fisker would later start another electric vehicle company named Fisker Inc in 2016 with the Fisker logo and trademarks.\n\nProduction models\nFisker Karma\nThe Karma was a plug-in hybrid luxury sports sedan produced by Fisker Automotive and manufactured at Valmet Automotive in Finland. After missing its initial late 2009 launch, and after the launch was rescheduled several times, the first deliveries took place in the U.S. in late July 2011 and deliveries to retail customers began in November 2011.\nThe 20.1 kWh (72.36 MJ) lithium ion rechargeable battery in each car came from A123 Systems in Watertown, Massachusetts. The aluminum frame was engineered by Fisker and was supplied by Norsk Hydro from Norway. The cabin interior was designed by Fisker Automotive, but was made in the United States by Magna International of Canada. The EVer powertrain system, technically a series hybrid, delivered over 400 horsepower, and was inspired by Quantum Technologies, a cofounder of and early investor in Fisker. A version of the Karma was relaunched as the Karma Revero in 2016 by Karma Automotive.\n\nSales\nBy February 2012, Fisker had established 45 dealerships in the US and three in Canada. By March 2012, the company had built over 2,450 vehicles, with over 2000 cars delivered to customers by the end of 2012. Fisker Automotive distributed vehicles through a traditional dealer network and partnered with five importers: GP Supercars (Merano, Italy), Nellemann (Copenhagen, Denmark); the Emil Frey Group (Zurich, Switzerland); BD Otomotive (Istanbul, Turkey) and Al-Futtaim Group (Middle East and North Africa).\n\nManufacturing\nFisker Automotive used to retain core competencies, such as design, engineering and marketing, in house, but outsourced manufacturing of its first vehicle Fisker Karma. Fisker's outsourcing methods allowed the company a 2–3 year period of development instead of the typical 5 years and at a cost of US$333 million instead of $1 billion, and claimed that it could make a profit from selling just 15,000 cars. Fisker used to save significant development costs by using pre-engineered components developed by other car companies whenever possible, such as the door handle mechanism which was a General Motors part; Fisker Automotive just paid a royalty to GM for each door handle in the Karma, which was much cheaper than designing its own door handles. However, the A123 battery failure and its resulting recall, and the eventual bankruptcy of the battery supplier, led to significant problems and added cost to the manufacture of the Karma model, finally resulting in Fisker's bankruptcy.\nIn 2008, Fisker estimated 15,000 cars per year would be assembled by Valmet Automotive in Uusikaupunki, Finland. Manufacturing eventually commenced in 2011 but by the third quarter of 2012 production ceased.Then-Vice President of the United States Joe Biden (later President) attended the October 27, 2009, announcement that Fisker Automotive would take control of the Boxwood Road Plant (previously owned and operated by General Motors as Wilmington Assembly) in Wilmington, Delaware, with production scheduled to begin in late 2012. This never happened and the plant was ultimately torn down.\n\nFunding\nFisker Automotive's investors have included Leonardo DiCaprio, Palo Alto Investors, Kleiner Perkins Caufield & Byers, Qatar Holdings, LLC, A123 Systems, and Ace Investments.\nIn April 2012, Fisker announced it had received $392 million in a round of financing, which was in addition to $850 million in private investment it had received in previous rounds. In Fisker's bankruptcy case, Hybrid Technology LLC ranked ahead of all the equity investors as a senior creditor since they purchased the Department of Energy loan note to Fisker Automotive in November 2013. In total, the company raised well over $1 billion from private investors.Fisker had received a US$528.7 million conditional loan in September 2009 from the Department of Energy's US$25 billion Advanced Technologies Vehicle Manufacturing Loan Program (ATVM). Of the total loan amount approved, a total of US$192 million was drawn by Fisker Automotive for engineering work with primarily US suppliers to complete the Fisker Karma and Fisker's Project Nina, later revealed as the Fisker Atlantic.The Department of Energy froze Fisker's credit line in August 2012 after US$192 million had been drawn, and after differences between the DOE and Fisker on the milestones set as conditions for the loan. The loan received additional scrutiny for being awarded for the manufacture of luxury vehicles that are too expensive for much of the general public. Fisker investor Ray Lane responded that the issues were being blown out of proportion due to election-year politics.\n\nSee also\nList of hybrid vehicles\nList of modern production plug-in electric vehicles\nFisker Coachbuild (2005–07)\nKarma Automotive (2014–present)\nFisker Inc. (2016–present)\nVLF Automotive\nTesla, Inc.",6  "char_len": 66250,7  "document_hash": "8010af0be95a5728b9ef1673d03a13ca91a54632bfc966dd2828aa103577a9b7",8  "questions": [9    {10      "question_id": "q00",11      "qtype": "hotpotqa",12      "question": "Spider9 was founded in 2011 by the head of which subsidiary of Wanxiang Group?"13    }14  ]15}