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Shareholders that do not have a strong preference on whether distributions in 2012 are taxed as dividends or capital gain/loss may prefer sale or exchange (capital) treatment in 2012 if they: Shareholders that assume corporate liabilities or receive property subject to corporate liabilities take the liabilities into account in computing their gain or loss.

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The phrase however, has come under criticism, largely by those who stress that so called democratic transitions are little more than transitions to semi-authoritarian rule, as demanded by the international realities of a post-cold war world.