the VP. If there are adjuncts present, VP-raising is considered as a type of remnant movement. In contrast to Cole and Herman's prediction, Massam's proposal states that indirect objects and obliques that are generated higher than the VP have grammatical subextraction unless they move from the VP. Remnant raising and VSO If the object evacuates the VP before the VP moves into a higher position within the clause, it derives VSO order instead, of VOS. Massam looks at the difference between VP-raising accounts of VOS and VSO by investigating the Niuean language. Massam argues that whether a NP object or a DP is selected by the verb determines if there is VP or VP-remnant raising. To get the structure of a VOS clause, an NP object is selected by the verb; the selected NP does not need case and so it will stay in the VP. Consequently, the object is pseudo-incorporated into the verb in the VOS clause. If a DP object is selected by the verb, VP-remnant movement occurs and creates VSO. Both possibilities are shown in the tables below: Niuean VSO Niuean VOS VP-raising and VSO/VOS alternations For languages whose alternations between VOS and VSO are more difficult to characterize, other factors help distinguish the word order. Unlike Niuean, whose objects are case-marked in VSO, not in VOS, Kroeger proposes that factors such as thematic role and grammatical functions help characterize word order such as in Tagalog. In reference to the verb, the argument with the highest thematic role should be the closest to it, and the highest grammatical function should be the farthest. For specifically-active voice clauses, the competition between the two situations helps to explain the variation of word order in Tagalog. Since there is no conflict in non-active clauses, there is less variation in word order. Flexible linearization (FL) approach Bury proposed that any phrase containing a subject and a constituent with a verb and an object can be linearized with the subject to the left or to the right of the verb-object constituent. That is called the flexible linearization (FL) approach, and with the combination of verb movement, it can account for most, if not all, VOS and VSO derivations. Under the assumption, word orders in languages surface as VOS because they may have been linearized with the subject, in this case to the right of the verb-object constituent. FL approach differs from most