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It depends on the style guide for whichever company employs you. Mine, for instance, is s-apostrophe in all cases. Although it can be debated, I think you'll find that most of the standard printers and newspapers almost always side with s-apostrophe.
I know MBC discovered recently that there's a semi-accepted standard to use s-apostrophe-s for religious figures (Jesus's, Moses's, etc) but I think that's pretty silly.
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