Jump to content

hornmpa96

Certifiably Surly
  • Posts

    1325
  • Joined

  • Last visited

Everything posted by hornmpa96

  1. Is there a reason they are holding votes without all the Democratic senators in the room? it’s almost like they don’t care if it actually passes.
  2. Assuming the US enacts the current proposals regarding corporate international taxation, the US will be creating tax costs for US based multinationals over and above what the OECD is asking from its members primarily due to the following differences: 1. The US tax system applies it’s own set of accounting rules to determine taxable income. Accordingly this results in significant timing differences which create double taxation unless losses and/or tax credits can be carried forward/back. 2. The OECD will allow companies to earn a normal return on substantive activities measured by tangible assets and payroll in a jurisdiction without an additional tax applying at the parent level while the current US proposals would remove the current 10% exemption. 3. The US has comprehensive expense allocation and foreign tax credit disallowance rules which effectively raise the tax rate on foreign earnings. Should we be subjecting US corporations to costs over and above their foreign counterparts? I certainly see the reasons for making changes similar to the OECD recommendation, but should the US system be more costly to USS based multinationals?
  3. It’s really overly complicated similar to everything else in the US tax code.
  4. Going back to the Green Book, the proposal is similar to this approach which requires the deceased to recognize all appreciation on assets on the final income tax return subject to a $1 million exemption plus a $500,000 exemption for a primary residence. Additionally the proposal treats capital gains as ordinary income and so the appreciation is subject to tax at 43.4% assuming the highest marginal rates apply. After considering the final income tax return, the estate would run through the estate tax process with the current 11.7 million exemption.
  5. The CEOs who are being paid in stock are paying tax on those stock/option grants as compensation at ordinary income rates. If holding private company stock is taxed differently than public company stock, it will definitely create an incentive for companies to stay private for as long as possible.
  6. Fair point - It’s probably more accurate to state that the proposal is really a change to the exemption amount although Treasury’s Green Book doesn’t present the proposal in that manner.
  7. That’s essentially Biden’s estate tax proposal. Everything above a certain amount is marked to market at death and the estate pays tax on the gain at that time.
  8. That propublica report is arguing for a mark-to-market regime. I’m curious about what unforeseen impacts would occur when we subject to people to tax when they haven’t engaged in transactions providing the cash to pay the tax.
  9. I think the US will enact this policy and the rest of the world will not.
  10. Republicans for not allowing birth control to be taught in schools and easily available?
  11. The frontier definitely moved East as the US army abandoned all of its forts defending various Texas settlements at the beginning of the Civil War.
  12. The Irish response will be interesting. Ireland built its economy by having a low tax rate and access to the EU.
  13. With all the browse out here, the deer are hardly hitting the protein right now.
  14. It was windy in South Texas this week. Arrived at the ranch to find this old windmill laying over the fence. I wish someone had recorded the truck pulling it off the fence.
  15. I totally understand the comments about wholly owned subsidiaries being generally managed and controlled by their parent. However, in the international tax context, we need some mechanism to determine which countries have the right to tax which income. The US system generally started with the premise that the corporate form is respected and therefore foreign income earned by foreign subs shouldn’t be subject to US tax unless repatriated to the US or is the type of income subject to potential abuse so that it’s subject to tax under a deemed repatriation regime. Lastly, the foreign tax credit system existed to prevent double taxation of this income between countries. Since 2017, the US moved away from those base principles. Under the current proposals, the US is moving to a full inclusion system with the most restrictive foreign tax credit system in the world. It’s extremely punitive to US based multinationals with real foreign businesses.
  16. First, the United States has the most aggressive system for taxing foreign income after the 2017 TCJA. Just because income is not taxed in Ireland doesn’t mean it’s not taxed in the US. Currently US companies are required to include deemed dividends in US taxable income based on the net income of its foreign subsidiaries under the GILTI regime. This deemed inclusion is subject to a potential 50% deduction and the US tax can be reduced by foreign tax credits. This Microsoft example is a horrible example as majority of the profits relates to a bullshit accounting gain from the liquidation of the certain subsidiaries of the company. Under the US system, there is likely zero taxable income because generally the liquidations of corporate subs into a parent company is tax free. Prior to the TCJA, the Irish company with Bermuda residency generated sizable tax benefits; however, under the current system, it’s likely subject to 10.5% US income tax. One can certainly argue if the rate is too low, etc.
  17. “If it wasn’t for the testing, we wouldn’t have so many cases.” Donald J Trump, Dumbass
  18. They thought she sounded taller on the radio.
  19. Donkey - I can respect your opinion and belief here. More power to you and yours for raising that child if this were to ever happen to your family. However, why should your opinion (and others who share that opinion) be forced on others who view things differently? Your family has the freedom under the law to live out your views, but you’re happy that the law is infringing on others ability to act based on their opinion. When does life actually begin? If you believe that’s anytime before viability outside the womb, “that’s like your opinion man.”
  20. Isn’t the risk level a little different given he actually has COVID? From my perspective, I would have been hesitant to let me child see him at all. It sounds like giving a kid some matches to play with.
  21. This morning the juror was interviewed on GMA and was asked a question about Chauvin invoking his 5th Amendment rights and impact on the jury’s decision. His answer seemed to indicate that it was at least considered. Does that go against the jury instructions and have any impact on potential appeals? I was fairly annoyed at Robin Roberts for even asking the question.
  22. I should have never sold my house in that area. By far my favorite house to own. On the tax side, married couples can exclude up to $500k of capital gain on their primary residence for tax purposes and half that for a single filer.
  23. This group wanted to go to A&M and couldn’t get in and then flunked out of SFA on their way to a government paycheck.
×
×
  • Create New...