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hornmpa96

Certifiably Surly
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Everything posted by hornmpa96

  1. Even Tom Glavine thinks the strike zone may be a little too wide
  2. Is this exhibit #1 in Paxton’s ads that George P is just too Latin for Texas?
  3. Calling Mr. Black and Mr. Scholes to the White courtesy phones to explain Options Valuation
  4. That option has a value when issued. Even deep out of the money options likely have some value. For accounting purposes, the company values the options when issued and generates an expense.
  5. It would. The LP interest is an asset owned by the individual. The valuation issues for non-public assets will definitely create controversy but we live with that controversy in other areas of tax (property, estate, etc).
  6. Nothing to add except Fuck Louie Gohmert
  7. 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.
  8. 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?
  9. It’s really overly complicated similar to everything else in the US tax code.
  10. 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.
  11. 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.
  12. 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.
  13. 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.
  14. 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.
  15. I think the US will enact this policy and the rest of the world will not.
  16. Republicans for not allowing birth control to be taught in schools and easily available?
  17. 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.
  18. The Irish response will be interesting. Ireland built its economy by having a low tax rate and access to the EU.
  19. With all the browse out here, the deer are hardly hitting the protein right now.
  20. 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.
  21. 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.
  22. 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.
  23. “If it wasn’t for the testing, we wouldn’t have so many cases.” Donald J Trump, Dumbass
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