Despite significant theological and practical differences, families with both Shia and Sunni members may not have challenges greater than any other families. The difference in Islamic inheritance, however, is often significant and can have lasting negative consequences.
Islamic inheritance, other than the fact that it is fard or obligatory for Muslims, tends to strengthen families at a time when they are the most vulnerable: when someone beloved passes away. In American society, as well as communities around the world, inheritance is a major vulnerability to family unity and cohesion. Problems of some sort are practically universal for families with wealth. Muslims who do it right and follow the Sharia will typically have healthier families as a result.
Since Shias and Sunnis often intermarry, and it is somewhat common to see siblings and children in the same families identifying as either Sunni or Shia, how do we follow inheritance rules and do it right?
One obvious solution is that you go by the rules of whoever the descendent was. So if the person who is writing his will is Shia, do it the Shia way, and if the individual is Sunni, do it the Sunni way. This solution may seem okay, but it may also cause unintended problems as I will explain. I will also attempt to offer a solution.
What do we mean by Shia?
The term Shia is broad to the point of not being analytically useful in itself. The word “Shia” is often, perhaps unfairly, shorthand for Ithna Ashari (Twelver) Shi’ism, which represents the majority of Shias around the world. There are non-Ithna Ashari groups that use the “Shia” label and have different inheritance rules, and some Muslims who identify as Shia may practice Islam without any readily noticeable differences from Sunnis. So the term I will use to describe the differences and how we will try to bridge them is Ithna Ashari rather than Shia.
What are the differences between Sunni and Ithna Ashari inheritance?
Islamic inheritance rules are in all instances derived primarily from the Quran. Shares are ordained to your children for example, not because you love them or because they married the right person, but because Allah has ordained it. Getting this right matters since we don’t want to do an injustice to anyone, least of all those we love. As most Muslims are aware, there are different historical methodologies for determining Islamic law, known as madhahib or schools of thought.
Among the majority of Sunnis in the United States, schools of thought on inheritance will almost never matter since most families who care to plan ahead have relatives on the same page as them. As a practical matter, after helping hundreds of families, I cannot recall a single instance where a client instructed me to follow a particular Sunni madhab. There are philosophical underpinnings that are consistent throughout the Sunni view that are different from the Ithna Ashari perspective.
The Ithna Ashari rules of inheritance also rely on the Quran, so familiar rules such as daughters getting half the share of sons are still present at the outset. However, the Ithna Ashari system tends to be simpler and allows for greater flexibility than the Sunni system.
The Ithna Ashari system of inheritance has three distinct tiers of heirs. If someone has one or more children of any gender and living parents, who are in the first tier, we don’t look for any other non-spouse heirs. If none of these exist, you go to siblings and others who would be in the second tier. The spouse sits outside the tier system and will take her Quranic share, which is typically ⅛ or ¼ depending on if there are children.
The spouse gets treated about the same in the Sunni and Ithna Ashari system, with an important distinction in Ithna Ashari inheritance of holding two classes of wives – traditional “nikah” wives and “muta” (temporary marriage arrangements) wives. Traditional “nikah” wives are virtually identical to the Sunni system, though “muta” wives have no right to inheritance unless it is in the “muta” contract. Sunnis do not permit “muta” at all.
In Sunni inheritance, there may be a need to look further than the Ithna Ashari tier system because Sunnis have “agnatic” heirs. An agnate is often a son or a father, but there can be female agnatic heirs, as I show in my example below. This can sometimes greatly expand the number of people who may be beneficiaries compared to the Ithna Ashari system. There is also a different understanding of who the heirs are that get their inheritance from the Quran.
There is an underlying philosophical difference between the Sunni and Ithna Ashari systems. Under the Sunni view, the inheritance rules represent a reform of the pre-Islamic Arab system of inheritance. The early generations of Muslims demonstrated this in their practice. In the Ithna Ashari view, Islam and the inheritance rules are a complete replacement of all previous norms from Arab society. An example of how this would matter in practice is in order:
Say Hafsa dies and leaves two daughters, Safiyyah and Rabia, and a sister, Bilquis. In all Sunni schools of thought, 2/3rds share gets divided between the two daughters, consistent with the Quran, and Bilquis will get the remaining ⅓.
In the Ithna Ashari rules of inheritance, you will get a different result. Safiyyah and Rabia will take everything between them. Bilquis receives nothing.
Another significant difference between the two systems is the wasiyyah. In both Sunni and Ithna Ashari inheritance rules, you can give up to ⅓ of your estate for a beneficial purpose. However, the wasiyyah is more restricted for Sunnis, it is not for those already entitled to an inheritance in Islam. So the shares of rightful heirs, relative to each other, represents both a minimum and a maximum. There is a well-known hadith stating that an heir cannot benefit from the wasiyyah. Muhammad ﷺ is reported to have said:
Allah has appointed for everyone who has a right what is due to him, and no bequest must be made to an heir.” (Abu Dawud and others)
This rule is universal among Sunnis. However, with Ithna Asharis, this restriction does not exist. An obvious consequence of this difference is that a daughter can get wasiyyah in the Ithna Ashari arrangement, which would then change what heirs receive relative to each other. The daughter can get about the same as a son. It can also be used to favor some heirs over others.
The significance of Khums and Inheritance
While these rules can be vastly different from each other, one crucial Ithna Ashari concept is khums. Khums is a tax in addition to Zakat where ⅕ of excess earnings (and there are detailed rules concerning this beyond the scope of this post) is paid to a Syed. While the word khums is mentioned in the Quran, there is no Sunni analog to Ithna Ashari Khums. The reason khums comes up in this discussion is its treatment of inheritance.
In the example above, say Hafsa is Sunni and her sister Bilquis is Ithna Ashari. Bilquis had no right to that inheritance if we apply Ithna Ashari rules, but she received an inheritance because her sister was observing Sunni rules. Under Ithna Ashari rules, she does not need to give her share to Safiyyah and Rabia. She can keep it and pay her 20% khums.
Hafsa should not exclude her sister from inheritance just because her sister is Shia. Hafsa is Sunni, and she must make sure inheritance is distributed to her heir, even though her sister’s fiqh is completely fine with her not receiving an inheritance. Bilquis, who is Shia in this example, has two options when she gets an inheritance from Hafsa: Bilquis may give it all to her two nieces, Safiyyah and Rabia, or she can keep it and pay the khums. Either one is a good result from the Sunni perspective, the former because Islamic inheritance is the right of the heir – once she receives it, she can give it away. The later is, of course, fine because in the Sharia, Bilquis is the one with the right to inheritance.
More or fewer pieces of the pie
In broad strokes, where the Ithna Ashari and Sunni systems of inheritance differ is that there are more slices to the inheritance pie in the Sunni system of inheritance and fewer pieces with Ithna Ashari, with shares going to fewer people. So it is harder, perhaps impossible, to find examples where someone who is entitled to Islamic Inheritance in the Ithna Ashara system is excluded entirely from the Sunni system.
However, it is undoubtedly the case that an heir may get more inheritance in the Ithna Ashari system than they would otherwise receive in the Sunni system. Say we change some facts in the above example, that Hafsa was Shia while the sister Bilquis and the daughters, Safiyyah and Rabia were Sunni. If Hafsa were to do her estate plan under the Ithna Ashari system, she would unjustly deprive her sister Bilquis because, under the Sunni system, her share is mandated in the Sharia. Safiyyah and Rabia would not be entitled to a portion of their inheritance and should give it to their aunt. Doing inheritance wrong here can cause needless complexity and perhaps unnecessary family drama. It would be best for Hafsa to plan her inheritance based on the Sunni system.
The flexibility of the Wasiyyah
In all Sunni schools of thought and among the Ithna Ashari, the wasiyyah is no more than ⅓ of the estate. In the Sunni tradition the Wasiyyah can be for a beneficial cause, including people who do not already have a right to inheritance and of course charities. Among Ithna Asharis, the wasiyyah can be used to give inheritance to virtually anyone, which includes everyone permissible for Sunnis to give their wasiyyah to and rightful heirs who are already getting an inheritance. So, for example, it is possible for a daughter to be both the beneficiary of inheritance by right, plus the beneficiary of the wasiyyah. We had previously discussed the issue of daughters getting half the inheritance of sons, something that is the rule for Sunnis and the default Ithna Ashari rule as well. For Muslims, at least in the Sunni tradition, that is the judgment of Allah. While for Ithna Ashari, this matter is more flexible because of the wasiyyah. Flexibility can bend in several ways. This might include ways that can result in long-term resentment and pain within families.
Just because you can do something, does not mean you should. This may be particularly true when in a mixed Sunni-Ithna Ashari family.
One of the benefits of the Islamic Rules of inheritance and the reason why it tends to promote rather than inhibit family harmony is the relative lack of flexibility. You are entitled to inheritance only to the extent it is ordained by Allah. When someone dies and either leaves you something or not, there is nobody with whom to be upset. When it’s done right, there is no “he manipulated dad” or “that woman took everything.” It is the Judgement of Allah. Even Muslims who are not especially religious understand that.
The best part of Ithna Ashari Rules
While Sunnis have significant theological disagreements with Ithna Ashari, the families formed from these two traditions need not result in long-term rancor because of inheritance issues. The availability of the Khums when inheritance is done “wrong” from an Ithna Ashari perspective, and the ability to not distribute wasiyyah to heirs means that the main benefit in this world of Islamic Inheritance, more harmonious families, can be available to everyone.
To learn more about the fard Islamic Rules of inheritance, you can get a resource guide here.
Highly Educated, Willingly Domesticated
Doctor. Engineer. Certified Nurse-Midwife. Writer and Literary Critic. Lab Technician. Parliamentary Assistant. These highly-trained, respected careers are the culmination of years of intense study, training, and self-discipline. Most people, upon achieving these esteemed positions, would happily dedicate the rest of their working years to putting their knowledge and expertise to use. They would gradually gain more experience, earn greater pay, and amass professional perks. Most likely they would also, over time, assume leadership roles, earn awards, or become sought-after experts in their field.
What kind of person has all this at her fingertips, but decides to give it up? Who would trade in years of grueling study and professional striving for an undervalued position that requires no degree whatsoever What type of professional would be willing to forgo a significant salary to instead work for free, indefinitely, with no chance whatsoever of a paycheck, recognition, benefits, or promotion?
Who else, but a mother?
While certainly not all mothers choose to give up their careers in order to raise their children, there is a subset of women who do. Stay-at-home-moms (SAHMs) may spend the majority of their days performing unglamorous tasks like washing dishes, changing diapers, and reading storybooks to squirming toddlers, but behind the humble job title are dynamic, educated, and capable women. They may currently have a burp cloth in one hand and a sippy cup in the other, but chances are, SAHMs have a mind and capabilities that reach far beyond the apparent scope of their household duties.
What motivates a capable and ambitious woman to give up her career and stay home to raise children? Is she coerced into it, or does she choose it willingly? What is her driving force, if not money, status, or respect? I had many questions for these women -my sisters in Islam and my stay-at-home “colleagues”- and some of their answers surprised me.
For this article I interviewed seven highly-educated Muslim moms who chose to put successful careers on hold, at least temporarily, to raise their children. Between them, they hold PhDs, MDs, and Masters degrees. While the pervasive stereotype about Muslim women is that they are oppressed and backward, these high-achieving females are no anomaly. In fact, according to her article in USA Today, Dalia Mogahed points out that, “Muslim American women are among the most educated faith group in the country and outpace their male counterparts in higher education.” Across the pond, The Guardian reports that “more young Muslim women have been gaining degrees at British universities than Muslim men, even though they have been underrepresented for decades.”
Ambitions and dreams
Every single one of the women I interviewed grew up in a household with parents who highly emphasized their daughters’ education. In fact, all of them were encouraged -either gently or more insistently- to pursue “top” careers in medicine, engineering, or science. Perhaps unsurprisingly, most of the women I interviewed were at the head of their classes at university.
In their school years, before marriage, all of the women I spoke with considered their career to be their main priority; motherhood seemed far-off and undefined. “When in uni,” explains Neveen, an endodontist who eventually put her career on hold to be a SAHM and homeschooler, “I never, ever thought I’d homeschool (nor did I believe in it), nor did I ever think I’d be a SAHM. I was very career-oriented. I was top of my class in dental school and in residency.”
“I absolutely thought I would be a career woman,” agrees Nicole, a mom of three in California who holds a Masters degree in Middle East Studies. “I never considered staying at home with the kids, because they were totally out of my mind frame at the time.”
“I expected that after graduation I would follow a research-based career,” adds Layla*, another SAHM in California who holds a PhD in Computer Engineering. “I never thought I’d stay at home because I believed it was fine for kids to be in daycare. I also thought SAHMs were losing their potential and missing out on so much they could otherwise accomplish in their lives.”
As young women, many assumed that if they ever chose to start a family, they would have assistants, nannies, or domestic helpers to lighten their load. Several of them believed they would put their future children, if any, in daycare. However, the reality of motherhood made each of these women change her mind.
“My child was highly attached to me,” explains Sazida, an Assistant to a Member of Parliament in England, “and I could not envision him being looked after by anyone else despite generous offers from relatives.”
“After I had my first child all I wanted to do was be able to care for her myself,” concurs Melissa, a Certified Nurse Midwife from New York.
It turns out that maternal instincts were not the only factor that made women choose to drop out of the workforce. Dedication to Islam played an enormous part in their decision-making.
“After having my first child,” explains Layla, “I decided that he was far more precious than working. He is a gift that Allah gave me to protect and care for.”
“After I became Muslim,” shares Nicole, “My goals changed, and I hoped to marry and have children. I do think it was beneficial for my children to have a parent always there to depend on,” she adds. “I feel like I was the anchor in the family for them, and I hope to continue that role.”
“What’s important to me,” asserts Neveen, “Is to raise my kids as good Muslims who love -and are proud of- their life and deen.”
Another reason many highly educated women choose to stay at home is because they have the opportunity to homeschool some or all of their children. Remarkably, out of the seven women who answered questions for this article, five reported that they chose to homeschool at least one child for a few or more years.
“I really enjoy my homeschooling journey with my kids and I get to know them better, alhamdullilah,” states Layla.
The opportunity to nurture, educate, and raise their children with love and Islamic values is the primary reason why these talented women were willing to put their successful careers on hold. “Hopefully Allah will reward us in Jannah,” muses Layla.
Although none of the women I interviewed regrets her choice to be a SAHM, they all agree that it is a challenging job that is actually harder than their former career.
One obstacle they must overcome is the negative perception others have about successful women who make the choice to put their career on hold. “I soon learnt that casual clothes, a toddler, and a buggy don’t give you the same respect as suits and heels,” says Sazida.
One would expect, given their faith’s emphasis on the dignity of mothers, that Muslim SAHMs would enjoy the support of their family and friends. Unfortunately, this is not always the case.
One mom explains, “My in-laws offered to look after my child, and my father-in-law couldn’t understand why I wanted to stay at home when there was perfectly good childcare that they were offering. After two and three years passed, he got more and more disheartened that I was not earning and complained about the lost potential income.”
“My non-Muslim mother told me that I wasting my education,” confides Nicole. “She did not support me staying home, though I think she appreciated that I was there for my children and have a good relationship with them. She was a SAHM as well, so I am not sure where that was coming from, actually.”
Melissa’s mom was similarly skeptical of her daughter’s decision. “My mother didn’t love me being fully dependent on my husband,” she admits.
“I was not at all supported by my family or friends,” laments Radhia, a Lab Technician with a BS in Microbiology with a Chemistry minor.
Other than being doubted and blamed for their choice, there are other challenges that SAHMs face. Accustomed to mental stimulation, exciting challenges, professional accomplishments, and adult interaction, many former career women find staying at home to raise youngsters to be monotonous and lonely. The nannies, assistants, cleaners, and other workers they had envisioned often never materialized, since hiring these helpers was usually too expensive. Husbands who spent the day working as the family’s sole breadwinner, were usually too tired to help with household duties. A few women admitted that they felt guilty asking for help in the home when their husband was already exhausted from work. To exacerbate the problem, most of the women I interviewed lived far from family, so they could not rely on the help one normally gets from parents and siblings. That means the bulk of the childcare and housework fell onto their laps alone.
“The main challenges for me,” states Nicole, “were boredom, and finding good friends to spend time with who had similar interests. I was also very stressed because the raising of the children, the housework, the food, and overall upkeep of our lives were my responsibility, and I found that to be a heavy burden.”
“I think the feelings of vulnerability and insecurity about whether I was a good enough mother and housewife was difficult,” shares Melissa. “All my sense of worth was wrapped up in the kids and home, and if something went wrong I felt like a failure.”
“It was not as easy as I thought it would be,” confesses Radhia. “It was overwhelming at times, and I did miss working. Emotionally and physically, it was very draining.”
“Staying home has been harder than I expected,” adds Summer*, a Writer and Literary Critic from Boston. “I didn’t realize how willful children could be. I thought they’d just do what I said. I’m still trying to get used to the individuality! It’s harder than my job was, only because of the emotional load, and the fact that the effort you put in doesn’t guarantee the results you hope for.”
Giving up their salary also put women in a state of financial dependency, which can be a bitter pill to swallow for women who are used to having their own resources.
“I felt very dependent on my husband, financially,” says Radhia.
“Alhamdulillah, my husband does not refuse if I ask him to buy anything,” explains Layla. “However, I felt like I was losing my power of deciding to buy something for someone else. For example, if I want to buy a gift for my mother or my sister, he never refuses when I ask him, but still I feel internally it is harder for me.”
“Alhamdulillah my husband’s personality is not one that would control my financial decisions/spending,” shares Neveen. “Otherwise I would never have chosen to be a SAHM.”
“Giving up my career limited my power to make financial decisions,” asserts Summer. “I could still spend what I wanted, but I had to ask permission, because my husband knew when ‘we’ were getting paid, and how much. He paid the bills, which I didn’t even look at.”
“Asking permission,” Summer adds, “is very annoying.”
Re-entering the workforce was difficult for some women, while not for others. The total time spent at home generally affected whether women could easily jump back into their profession, or not. Some of the moms felt their skills had not gotten rusty at all during their hiatus at home, while others felt it was nearly impossible to make up, professionally, for missed time.
Words of Wisdom
Although all of the women I interviewed firmly believe that their time at home with their children is well-spent, they do have advice for their sisters who are currently SAHMs, or considering the position.
“If I could go back and speak to myself as a new mum, I would tell myself to chill the heck out and just enjoy being a new mum,” says Sazida.
Melissa offers, “I wish people understood how talented you have to be to run a home successfully. It’s a ton of work and it requires you to be able to do everything from snuggle and nurture, to manage the money, budget, plan precisely, be a good hostess, handle problems around the home, manage time, and meet goals all while trying to look cute.”
“I would always recommend that women have their own bank account and money on the side,” advises Nicole. “You never know when you are going to need it.”
“Once their kids are in school,” adds Radhia, “I would suggest SAHMs start something from home, or take on part time work, or courses, if necessary.”
“For moms choosing to stay at home,” Layla suggests, “I would say try to work part-time if your time permits, and if you have a passion for working. Trust that Allah will protect you, no matter what. Remember, you are investing in your kids, and that is far more important than thinking ‘I need to keep money in my pocket.’”
Support, don’t judge
As a Muslim ummah, our job is to support one another as brothers and sisters. It seems people forget this oftentimes, and erroneously believe that we are entitled to gossip, speculate, and sit in judgement of each other, instead. In our lives we will all undoubtedly encounter women who choose to continue their careers, and those who put them on hold, and those who decide to give them up completely. Before we dare draw conclusions about anyone, we must keep in mind that only Allah knows a person’s entire story, her motivations, and her intentions. Only He is allowed to judge.
We must also remember that some women, for a variety of reasons, do not have the luxury of choosing to stay at home. They must work to the pay the bills. Allah knows their intentions and will reward their sacrifices as well.
It is my hope that this article will not cause more division amongst us, but rather raise awareness of the beautiful sacrifices that many talented and intelligent women willingly make for the sake of their children, and even more so, for the sake of Allah . They are the unsung heroes of our ummah, performing an undervalued job that is actually of utmost importance to the future of the world.
*Name has been changed
For the past decade, writer Laura El Alam has been a regular contributor to SISTERS Magazine, Al Jumuah, and About Islam. Her articles frequently tackle issues like Muslim American identity, women’s rights in Islam, support of converts/reverts, and racism. A graduate of Grinnell College, she currently lives in Massachusetts with her husband and five children. Laura recently started a Facebook page, The Common Sense Convert, to support Muslim women, particularly those who are new to the deen.
OpEd: Breaking Leases Into Pieces
Ali ibn Talib once said, “Know the truth and you’ll know who’s speaking the truth.”
I am based in Canada and was recently having coffee with friends. In the course of the conversation, a friend (who I consider knowledgeable) said that it’s okay to pay interest on a leased car because interest doesn’t apply to lease contracts. This completely caught me off guard, because it made no logical sense that interest would become halal based solely on the nature of the contract.
I asked him how this can be true and his response was that the lease contract is signed with the dealer and the interest transaction is between the dealer and the financing company so it has nothing to do with the buyer. Again, this baffled me because I regularly lease cars and this is an incorrect statement: The lease agreement is signed with a third party financing company who is charging you directly for the interest they pay the car dealership. Therefore, any lease contract that has interest associated with it is haram. This is the same as saying your landlord can charge you interest for his mortgage on a rental contract and this would make it halal. I tried to argue this case and explain to my friend that what he was saying was found on false assumptions and one should seriously look into this matter before treating riba in such a light manner.
Upon going home that night, I pulled out all my lease contracts (negotiated to 0% mind you) and sent them over to my friend. They clearly showed that a bill of sale is signed with the dealer, which is an initial commitment to purchase but the actual lease agreement is signed with a third party financing company which is charging you interest directly. If this interest rate is anything above zero it is haram (anything which is haram in a large quantity is also haram in a small quantity).
To my dismay, instead of acknowledging his mistake, my friend played the “Fatwa Card” and sent me a fatwa from a very large fatwa body in North America, which was also basing their argument on this false assumption. Fortunately for me, my friend pointed out the hotline number and the day and time the mufti who gave the fatwa would be available to answer questions.
I got in touch with the scholar and over a series of text messages proceeded to explain to him that his fatwa was based on a wrong assumption and for this reason people would be misled into leasing cars on interest and signing agreements with financing companies which are haram.
He was nice enough to hear my arguments, but still insisted that “maybe things were different in Canada.” Again this disappointed me because giving fatwa is a big responsibility – by saying “maybe” he was implying that full research has not been done and a blanket fatwa has been given for all of North America.
It also meant that if my point was true (for both Canada and the United States) dozens of Muslims maybe engaging in riba due to this fatwa.
The next week I proceeded to call two large dealerships (Honda and Toyota) in the very city where the Fatwa body is registered in the US and asked them about paperwork related to leasing. They both confirmed that when leasing a new vehicle, the lease contract is signed with a third party financing company which has the lien on the vehicle and the dealer is acting on the financing company’s behalf.
It is only when a vehicle is purchased in cash that a contract is signed with the dealer. This proved my point that both in the US and Canada car lease contracts are signed with the financing company and the interest obligations are directly with the consumer, therefore if the interest rate is anything above 0% it is haram. I sent a final text to the mufti and my friend sharing what I had found and letting him know that it was now between them and Allah.
1. As we will stand in front of Allah alone on Yaum al Qiyamah, in many ways we also stand alone in dunya. You would think that world renowned scholars and an entire institution would be basing their fatwas on fact-checked assumptions but this is not the case. You would also think that friends who you deem knowledgable and you trust would also use logic and critical thinking, but many times judgment is clouded for reasons unbeknownst to us. We must not take things at face value. We must do our research and get to the bottom of the truth. Allah says to stand up for truth and justice even if it be against our ourselves; although it is difficult to do so in front of friends and scholars who you respect, it is the only way.
2. There are too many discussions, debates and arguments that never reach closure or get resolved. It is important to follow up with each other on proofs and facts to bring things to closure, otherwise our deen will slowly be reduced to a swath of grey areas. Alhamdulillah, I now know enough about this subject to provide a 360 degree view and can share this with others. It is critical to bring these discussions to a close whether the result is for you or against you.
3. Many times we have a very pessimistic and half hearted view towards access to information. When I was calling the dealerships from Canada in the US, part of me said: Why would these guys give me the information? But if you say Bismillah and have your intentions in the right place Allah makes the path easy. One of the sales managers said “I can see you’re calling from Toronto, are you sure you have the right place?” I replied, “I need the information and if you can’t give it to me I don’t mind hanging up.” He was nice enough to provide me with the detailed process and paperwork that goes into leasing a car.
Finally, I haven’t mentioned any names in this opinion and I want to make clear that I am not doubting the intentions of those who I spoke to; I still respect and admire them greatly in their other works. We have to be able to separate individual cases and actions from the overall person.
May Allah guide us to the truth and rid of us any weaknesses or arrogance during the process.
Ed’s Note: The writer is not a religious scholar and is offering his opinion based on his research on leasing contracts in North America.
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