Taxes Publications

Taxes Committee Publications

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The Indian approach to taxing virtual presence
This article, by Meyyappan Nagappan, was the Taxes Committee Scholarship Winner 2018. It explores the Indian approach to taxing virtual presence.
France ratifies the MLI and reshuffles the cards of the tax treaty game
The authors offer an insight into the position of France regarding the OECD’s multilateral convention to implement tax treaty-related measures to prevent BEPS.
The agency principle under Indian income tax laws, in reference to non-residents
This article analyses a specific situation involving a representative assessee in the form of an agent of a non-resident and its treatment under Indian law.
Social contributions on gross revenues: non-cumulative regime and debate about the concept of input for PIS and COFINS purposes
An article exploring social contributions on gross revenues: the non-cumulative regime and the debate about the concept of input for PIS and COFINS purposes.
Chile’s approach to the taxation of the digital economy
The digitalisation of the economy poses several challenges for current tax systems throughout the world, both internally and multilaterally. Although the OECD has identified these challenges and several issues which arise from them, no definitive guidelines or approaches have been issued in this regard. As agreeing on and implementing a global solution will not come easily, until a consensus for such a multilateral approach is reached, many countries are taking interim and unilateral measures to approach such challenges. It is in these circumstances that Chile envisages to introduce a new tax on digital services.
Class III policies in the Italian legal framework: life insurance policy or financial instrument?
Starting from a brief description of the favourable tax regime provided for life insurance products in the domestic market in Italy, this paper aims to provide an overview of the risks connected with the re-characterisation of class III policies. The analysis is carried out with reference to the most recent Italian Supreme Court case law as well as in light of the latest decision issued by the Court of Justice of the European Union.
The Netherlands introduces a list of low-tax jurisdictions
The Netherlands has finally published a list of qualifying low-tax jurisdictions. This new list is especially relevant for two new Dutch legislative proposals: the Controlled Foreign Companies (CFC) measures, and the Dutch proposal to tax dividend, interest and royalty flows from a Dutch entity to a low-tax jurisdiction.
Summaries from the 11th Annual Tax Planning Strategies – US & Latin America Conference, Miami
Lauri Lehmusoja summarises the recently added reports from the 11th Annual Tax Planning Strategies – US & Latin America Conference, held in Miami in June 2018.
Letter from the Editor - Taxes Committee newsletter article, November 2018
Kristin Konschnik introduces the November 2018 IBA Taxes Committee update.
From the Co-Chairs - Taxes Committee newsletter, November 2018
Francesco Capitta and Ana Lucia Ferreyra reflect on the IBA Annual Conference 2018 and look ahead to the New Era of Taxation conference.
From the Co-Chairs, September 2018
A message from Francesco Capitta and Ana Lucia Ferreyra.
Letter from the Editor - September 2018
A message from Kristin Konschnik.
All Roads Lead To Rome – the IBA Annual Conference 2018
This year’s IBA Annual Conference will be held in Rome, from Monday 8 October.
Meet the Officer - Aseem Chawla
An interview with Aseem Chawla of ASC Legal, Solicitors & Advocates, Secretary of the Taxes Committee.
Young Lawyers Programme - September 2018 newsletter
Message from the Young Lawyers Programme of the Taxes Committee, which is an IBA initiative that aims to attract younger lawyers to participate in relevant Committee activities and to enhance their engagement with the various IBA committees, groups and activities.
Wrap-up of Latin America (Miami) Conference
The 11th Annual US–Latin America Tax Planning Strategies Conference was held at the Mandarin Oriental in Miami on 13-15 June 2018.
US tax reform affecting estate planning for NRAs holding US situs assets: loss of the 30-day rule for CFCs
This article focuses on the relatively outsized consequence for many non-US individual clients of a seemingly narrow change brought in by the US Tax Cuts and Jobs Act: the elimination of the so-called ‘30-day rule’ for controlled foreign corporations (CFC).
Cloud mining of cryptocurrencies
In Austria, as in many other countries, there are no explicit rules in the Income Tax Act and Value Added Tax Act specifically dealing with cryptocurrencies. Thankfully, in 2017, the Austrian Ministry of Finance released guidance, which is helpful in most respects, but definitely not comprehensive.
The 2017 United States international tax reforms: a sea change
By far, the most important development in United States taxation in the past year has been the enactment of the law known as the Tax Cuts and Jobs Act of 2017 (the ‘TCJA’).[1] The TCJA, controversially and hurriedly passed on a near party-line vote, is one of the most significant reforms of US federal tax law since the enactment of the Internal Revenue Code of 1986.
Presumptive assessment of undue transfer of tax loss: the new weapon of the Mexican tax authority
On 2 June 2018, an amendment to the Mexican Federal Tax Code came into effect.
Uruguay's free zones: the new reform
On 8 December 2017, the Uruguayan Executive Branch enacted Act No 19,566 (the ‘Act’), amending several provisions of the so-called Free Zones Act (No 15,921). The following provides a summary of the main amendments introduced by the Act, which entered into force on 8 March 2018.
Uruguay – Taxation on E-commerce Companies: New Regulations
In May 2018 Uruguay’s governing Administration issued a Regulatory Decree, which is summarised below; in July 2018, Uruguay’s Tax Office issued a special Resolution spelling out certain implementation details.
Recent tax developments by jurisdiction - 2018

The Committee has published its annual update on tax developments by jurisdiction for 2018
From the Co-Chairs, May 2018
A message from the Co-Chairs of the Taxes Committee, Francesco Capitta and Ana Lucia Ferreyra.
From the Editor, May 2018
A message from the Newsletter Editor of the Taxes Committee, Kristin Konschnik.
Meet the Officer, Simon Yates
Simon Yates is one of two current Vice-Chairs of the Taxes Committee. In this article, he explains a bit about how he got into law and what his role within the Committee entails.
Summaries from the 7th Annual IBA Finance & Capital Markets Tax Conference, January 2018
Lauri Lehmusoja provides a brief introduction to the summaries from the 7th Annual IBA Finance & Capital Markets Tax Conference that was held in London in January 2018.
Wrap-up of the London IBA Finance & Capital Markets Tax Conference, January 2018
Jack Bernstein sums up the activities at the Finance & Capital Markets Tax Conference which was attended by over 240 people.
Summary of the 18th Annual Tax Planning Strategies – US and Europe Conference
An overview summary of the 18th Annual Tax Planning Strategies – US and Europe Conference that took place in Amsterdam on the 12-13 April 2018.
Upcoming US-Latin America Tax Planning Strategies Conference – Miami
The 11th Annual US-Latin America Tax Planning Strategies Conference in Miami is coming up in June – there is still time to book your place!
IBA Taxes Committee Scholarship Programme
Each year to Taxes Committee encourages young lawyers to participate in its Scholarship Programme; find out more.
From the Co-Chairs - Taxes Committee, January 2018
Ana Lucia Ferreyra and Francesco Capitta introduce this edition of the Taxes Committee newsletter in their From the Co-Chairs message.
Summary of Buenos Aires Conference - Taxes Committee, January 2018
Mariana Eguiarte-Morett and Leandro Passarella offer a summary of ‘The New Era of Taxation’ Conference, which took place in Buenos Aires on 30 November and 1 December, and brought together tax practitioners, both in the public and private sectors, as well as from academia, from over 20 countries in Europe, Latin America and North America.
Meet the Officer feature – Ana Lucia Ferreyra - Taxes Committee, January 2018
This Meet the Officer feature is an interview with Ana Lucia Ferreyra, Co-Chair of the Taxes Committee from 1 January 2018.
Letter from the Editor - Taxes Committee, January 2018
Newsletter editor Kristin Konschnik introduces the January 2018 edition of the Taxes Committee newsletter, nodding to the Co-Chairs message, bidding a fond farewell to Alain Ranger and a warm welcome to Ana Lucia Ferreyra, incoming Co-Chair. Konschnik highlights the successes of 2017's conferences and looks forward to 2018, encouraging members to become involved with the Committee and its activities.
Summaries from the Annual IBA Conference in Sydney - Taxes Committee, January 2018
The Taxes Committee organises wide-ranging and highly informative programmes for several tax conferences each year. However, most of us can't make it to every conference and, even if we could, we would often like to be able to go back and remember the best insights of a great discussion. For this purpose, a detailed report is prepared on most panel sessions and lectures given in our conferences.
Summary of Taxes Committee activities at the IBA Annual Conference in Sydney - Taxes Committee, January 2018
Simon Yates and Ana Lucia Ferreyra summaries the IBA Taxes Committee activities at the IBA Annual Conference 2017 in Sydney, covering location, attendance and the sessions offered by the Committee.
Recent tax developments by jurisdiction - 2017

The Committee has published its annual update on tax developments by jurisdiction for 2017
Letter from the Co-Chairs
By Alain Ranger and Francesco Capitta
Letter from the Co-Chairs. Taxes Committee
Letter from the Editor
By Kristin Konschnik
Welcome to the May edition of the IBA Taxes Committee Newsletter! It’s been an extremely busy spring for the Taxes Committee, with conferences including the Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets in London and the Annual US-Europe Tax Planning Strategies conference held this year in Barcelona.
Report on the 17th Annual Tax Planning Strategies US and Europe Conference - Barcelona 5 – 7 April 2017
By Albert Collado and Sonia Velasco
The conference was co-organised by the tax sections of the IBA, the American Bar Association and the US branch of the International Fiscal Association. Carol Tello, Sonia Velasco and Albert Collado co-chaired the event.
US - Latin America Tax Planning Strategies Conference - Miami
By Emin Toro
Celebrating its 10th birthday, the Annual US-Latin America Tax Planning Strategies conference, co-sponsored by the IBA, the American Bar Association (ABA), the International Fiscal Association and the Tax Executives Institute, will be held in Miami on 15-16 June 2017, with the Wealth Management and Tax Executives Workshops taking place on 14 June.
IBA Annual Conference 2017: Taxes Committee Sessions

The Taxes Committee is looking forward to the 2017 IBA Annual Conference in Sydney, Australia from 8-13 October 2017, registration for which is now open. Sydney is one of Australia's leading commercial cities, with a wealth of business and networking opportunities.
From the Co-Chairs
By Alain Ranger and Francesco Capitta
It’s been a busy first quarter for the Committee, with upcoming conferences in Barcelona, Miami and Buenos Aires shaping up well, and the 2017 national reporters programme launched for this year.
From the Editor
By Kristin Konschnik
Whether it's political changes on both sides of the Atlantic, or increasingly aggressive and coordinated tax administrations, this year will offer a multitude of learning and planning opportunities for members.
Barcelona conference on tax planning strategies in US and Europe – preview
The 17th Annual Tax Planning Strategies US and Europe event in April, co-sponsored by the American Bar Association, will feature state aid, treaty abuse, debt/equity considerations and the ever-popular government roundtable on the agenda.
Help the Taxes Committee improve new global tax rules
By Mark van Casteren and Roberto Duque Estrada
The Committee regularly provides input to consultations on proposed new tax rules, including the BEPS Action plan and the Transfer Pricing Toolkit, to improve their content and quality.
Taxes Committee – conference session reports
By Lauri Lehmusoja
Reports of conference panel sessions and lectures are now available online - a valuable resource, allowing participants to refresh their takeaways and giving those unable to attend the key insights.
Wrap-up of London conference on tax issues in cross-border corporate finance and capital markets
By Jack Bernstein
The 6th Annual IBA Tax Conference: Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets, held in 30-31 January, proved both timely and important.
From the Co-Chairs
By Alain Ranger and Francesco Capitta
The Committee’s Co-Chairs look back on the highlights of a successful 2016, and outline the conferences in the Taxes Committee calendar for 2017, as well as providing an update on the Scholarship Programme and officer changes.
From the Editor
By Kristin Konschnik
It’s uncertain how Brexit and the Trump Presidency will impact international tax planning going forward but, through its conferences and newsletter articles, the Taxes Committee aims to keep members up-to-date on relevant changes.
The New Era of Taxation – conference summary
By Francesco Capitta and Margriet Lukkien
Held every year by the Committee, The New Era of Taxation conference allows the new generation of international tax lawyers to discuss key topics of the moment, and the November 2016 event in Amsterdam did not disappoint.
Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets – conference preview
By Jack Bernstein
Sixty top tax professionals from law firms, financial institutions, multinationals and other organisations will speak at this event in London on 30–31 January.
Meet the Offices – Francesco Capitta, Taxes Committee Co-Chair

The new Co-Chair outlines what inspired him to enter practice in Italy, what he finds most important as a global tax lawyer, and his ‘IBA career’ over the last 15 years.
IBA Annual Conference 2017 – Taxes Committee sessions

From transparency requirements to Asia-Pacific investments flows, the BEPS interest barrier to the ‘rule of law’ principle – the IBA Annual Conference in Sydney this October will be packed with exciting, timely and informative sessions for tax practitioners.
Taxes Newsletter - May 2016

This edition of the Committee's newsletter outlines some of the latest international developments in tax law, including changes by the Australian government, foreign rectification orders in Canada, Austrian legislation affecting cross-border mergers, the Portuguese State Budget, and Uruguay's free port regime. Click here to download and read.
A taxing time to invest in Australia
By Reynah Tang
This article outlines three recent tax and tax related changes introduced by the Australian Government that impact on investment in Australia: a new multinational anti-avoidance law; a withholding tax on the disposal of direct and indirect Australian real property interests by foreign residents; and the introduction of tax related standard conditions for foreign investment approvals.
Implications of recent Austrian tax law changes on outbound cross-border mergers
By Niklas Schmidt and Cynthia Pfister
Recent changes introduced in Austria with the Tax Amendments Act 2015 may have a significant impact on cross-border mergers, rendering them less attractive. This is due to the fact that as of 1 January 2016, it is no longer possible to defer any exit tax triggered by a merger.
New benefits for logistics business in Uruguay
By Guzmán Ramírez
Amendments to the Uruguayan Customs Code have introduced more incentives for the setup of regional distribution centres in Uruguay. The updated Code provides for the creation of a new category of bonded warehouse to benefit from the tax exemptions of the Free Port Regime.
The Portuguese State Budget for 2016
By Bruno Santiago and Roberto Mendonça
This article provides a brief overview of the main amendments in the Portuguese tax system, relevant from an international taxation point of view, that were brought by the State Budget for 2016.
Foreign rectification orders not binding on Canada
By Phil Ward
This article discusses a recent decision of the Tax Court of Canada which held that foreign rectification orders were not binding on the Canada Revenue Agency in the absence of recognition by a competent Canadian court. Rectification proceedings have become common in Canada as a way to fix mistakes to avoid unforeseen tax consequences, but taxpayers can anticipate that the agency will resist rectification orders issued by foreign courts.
Meet the Officers: Membership Officers

Membership Officers - Aseem Chawla, Gordon Warnke, Roberto Estrada and Guillermo Canalejo Lasarte discuss their officer roles on the Taxes Committee.
Real estate rich company clauses in Germany’s recent double taxation treaty practice: how to cope with the changes - Taxes Committee newsletter article, December 2015
By Dr Nicole Schwäbe
The Organisation for Economic Cooperation and Development (OECD) Model Tax Convention was amended by a real estate rich company clause in 2003 according to which the taxation right on capital gains derived from the alienation of shares in a real estate company is transferred to the state in which the real estate is situated.
Corporate income tax consequences of asset transfers between a Dutch head office and its permanent establishment - Taxes Committee newsletter article, December 2015
By Pim Duteweert
In the Netherlands, a Dutch corporate taxpayer (binnenlands belastingplichtige) is taxed on its worldwide profits including those derived from abroad through a permanent establishment (‘PE’). Relief from double taxation in respect of PE profits is granted through the so-called ‘object exemption’ (objectvrijstelling).
India: tax controversies on software-related payments - Taxes Committee newsletter article, December 2015
By Himanshu Sinha, Nameer Khan, Rajat Dosi and Ayush Tandon
Taxability of software payments in India has been a highly vexed issue under both the direct and indirect tax regimes. From an income tax perspective, the dispute has been in relation to whether a right to use software granted by a non-resident to a resident in India constitutes a royalty under the Income Tax Act 1961 (the ‘IT Act’) and the tax treaties.
Nigeria: tax regulation highlights in 2015 - Taxes Committee newsletter article, December 2015
By Ehijeagbon Oserogho
The free fall in the price of crude oil poses a grave, albeit unfamiliar, challenge to the funding of public expenditures by all tiers of government in Nigeria. Historically, Nigeria has relied on its sale of crude oil for more than three quarters of its global revenues, most of which are expended on recurrent expenditures.
US: the ‘wilfulness’ element in the Inland Revenue Service’s Offshore Voluntary Disclosure Program (OVDP) - Taxes Committee, December 2015
By John Anthony Castro
What constitutes ‘wilful’ in determining the meaning of the term ‘non-wilful’ as used by the Internal Revenue Service (IRS) in the Offshore Voluntary Disclosure Program?
What a foreign investor should know about acquiring a US business - Taxes Committee, December 2015
By Robert G. Lorndale
This article is intended as a practical United States tax-planning guide for foreign (ie, non-US) persons considering investing in or acquiring a US business.
Uruguay: Tax developments for foreign companies included in the National Budget Bill - Taxes Committee, December 2015
By Guzmán Ramírez
On 31 August 2015, the Uruguayan Government submitted before Parliament the National Budget Bill for the period 2015–2019 (the ‘Budget Bill’).
Corporate income tax reform in Ukraine - Taxes Committee newsletter article, December 2015
By Tetyana Matsyuk and Maksym Maksymov
The Ukrainian tax system operates in a permanent state of reform. Despite the principle of tax legislation stability laid down in Ukraine’s Tax Code (the ‘Tax Code’), new tax laws are introduced in Ukraine at the end of every year and become effective one week after adoption.
Ireland: tax appeal procedural reform - Taxes Committee newsletter article, December 2015
By Brian Duffy
In January 2015, pre-legislative scrutiny of the draft heads of the Finance (Tax Appeals Commission) Bill (the ‘Draft Heads’) was undertaken. The author was invited to the process and gave evidence before the Oireachtas Joint Committee on Finance, Public Expenditure and Reform on the Draft Heads, which was the first time a tax practitioner had been invited to participate in the process.
European Court of Justice on tax system of Austrian private foundations - Taxes Committee newsletter article, December 2015
By Dr Niklas J R M Schmidt and Cynthia Pfister
In a recent judgment the European Court of Justice (ECJ) decided that the system of interim taxation of Austrian private foundations does not comply with European Community (EC) law.
Mexico: energy and infrastructure investment trusts - Taxes Committee newsletter article, December 2015
By Jorge Correa and Nadja Ruiz
On 20 December 2013, Articles 27 and 28 of the Mexican Constitution were amended. In a nutshell, these articles were modified to open up the hydrocarbon and power industries to private investment.
Italy: cooperative tax compliance - Taxes Committee newsletter article, December 2015
By Massimo di Terlizzi
On the basis of the Organisation for Economic and Cooperation and Development’s (OECD) indications,1 Legislative Decree no 128 of 5 August 2015, published in Official Journal no 190 of 18 August 2015,2 has introduced a regime of cooperative tax compliance between taxpayers and the Italian tax administration through forms of preliminary exchange.
Meet the officer: Scholarship Officers Margriet Lukkien and Ana Lucia Ferreyra - Taxes Committee, December 2015

Who are the Scholarship Officers for the Taxes Committee. What does this Officer role entail? What are some of the benefits of the role and what are the challenges?
Taxes Committee newsletter, December 2015

Download the Taxes Committee Newsletter, December 2015 (PDF download, members will need to login using their IBA username and password)
Recent developments in the advance tax ruling practices in Luxembourg and the Netherlands - Taxes Committee newsletter article
By: Alexei Maliy & Cees-Frans Greeven
Within the recent discussions on tax arrangements by international enterprises aimed at reducing the taxable base in high tax jurisdictions while shifting profits to low tax jurisdictions, special attention is drawn to the practices of governments concluding ‘tax deals’ which allegedly offer special tax privileges to taxpayers.
Poland enters battle for exchange of tax information - Taxes Committee newsletter article
By: Aldona Leszczynska-Mikulska, Tomasz Krzywanski and Aleksandra Czyz
The protracted economic crisis has led to a need to improve the tax systems of many countries and consequently to exact taxes from taxpayers who do not always or fully transparently declare all their income in their country of tax residence.
Universal basis and double taxation conventions in Brazil - Taxes Committee newsletter article
By: Gustavo Martini de Matos
In another article, with coauthor João Francisco Bianco, I had the opportunity of critically analysing the Brazilian legislation concerning the levy of corporate income tax and social contribution on the profits made abroad by legal entities domiciled in Brazil, taking a double perspective: domestic law, and double taxation conventions.
US corporations’ fair share – inversions, REITs, MLPs and tax reform - Taxes Committee newsletter article
By: David R Hardy
In the summer of 2014, the financial press were awash with stories of US corporations considering or effecting ‘inversion’ transactions. Such transactions, turning the US corporation’s parent company into a non-US corporation, resulted in a substantial reduction in their US taxes.
BEPS developments within the European Union and the Dutch approach - Taxes Committee newsletter article
By: Margriet Lukkien and Sophie Korteweg.
Countering base erosion and profit shifting (BEPS) is not only high on the agenda of the G20 and the Organisation for Economic Co-operation and Development (OECD), but also of the European Union (EU).
IBA Officers interview - Taxes Committee newsletter article

By: Simon Yates and Ricardo Leon Santacruz. IBA Officers interview
From the Editor - Taxes Committee newsletter article

By: Claire Kennedy. From the Editor
From the Co-Chairs - Taxes Committee newsletter article

By: Ewout van Asbeck and Reeves Westbrook. From the Co-Chairs
Taxes Committee conference reports

See reports from various IBA Taxes conferences
Recent tax developments by jurisdiction - 2015

The Committee has published its annual update on tax developments by jurisdiction for 2015
Taxes Committee newsletter, July 2015

Download the Taxes Committee Newsletter, July 2015, featuring articles on... (PDF download, members will need to login using their IBA username and password)
February 2015 - submission on OECD Public Discussion Draft, BEPS Action 4: Interest Deductions and other Financial Payments

The Taxes Committee submits various comments to public bodies on proposed tax legislation through its Working Groups.
January 2015 - submission on OECD Public Discussion Draft, BEPS Action 14: Make Dispute Resolution Mechanisms More Effective

The Taxes Committee submits various comments to public bodies on proposed tax legislation through its Working Groups.
January 2015 - submission on OECD Public Discussion Draft, BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

The Taxes Committee submits various comments to public bodies on proposed tax legislation through its Working Groups.
January 2015 - submission on OECD Public Discussion Draft, BEPS Action 7: Preventing the Artificial Avoidance of PE Status

The Taxes Committee submits various comments to public bodies on proposed tax legislation through its Working Groups.
Taxes Committee newsletter, October 2014

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Taxes Committee newsletter, February 2014

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Recent tax developments by jurisdiction - 2014

The Committee has published its annual update on tax developments by jurisdiction for 2014
Taxes Committee newsletter, September 2013

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Taxes Committee newsletter, February 2013

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Taxes Committee newsletter, September 2012

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Taxes Committee newsletter, May 2012

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Taxes Committee newsletter, October 2011

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Taxes Committee newsletter, May 2010

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Taxes Committee newsletter, October 2010

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