Struggling to balance its budget, Greece is reducing spending by cutting tax collection efforts:
“As a result of the austerity measures putting some tax officers on reduced pay, we have 5,500 fewer tax office jobs,” said tax officers’ union head Charalambos Nikolakopoulos.
Reduced pay is not the same as fewer jobs, but still. . . “Greek tax officials walked off the job Thursday at the start of a 48-hour strike to protest salary cuts and other austerity measures, as the government struggles to meet revenue targets demanded by the crisis-struck country’s international creditors.” How do they think they’ll get paid?
I’m for higher taxes, but I understand the need for spending cuts. Public employee unions can overplay their hands.
“Tax Repatriation Holiday”: Choosing Words Strategically
[A more legible .pdf version of this posting is downloadable at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1963951.]
“The real goal . . . is to determine what ‘story’ a client wishes to tell about his product and then find a word that evokes it—and spurs the impulse to buy.”
Tax policy turns on terms. Witness the deliberate and effective popularization of the term “Death Tax.”
Now, the “product” being offered in H.R. 1834 is a temporary, targeted 85-percent dividends received deduction: an ultra-low tax rate on foreign earnings that U.S. multinationals have trapped in offshore subsidiaries, most often in tax havens. Its common name is “Repatriation Holiday.”
Continue reading ““Repatriation Tax Holiday”: Choosing Words Strategically”
Whatever merit there is to granting corporations the Constitutional right of free speech, as the Citizens United case does, there is no merit to granting that right to foreign corporations. Or to U.S. subsidiaries of foreign corporations. Or to U.S. corporations owned by foreigners or — for goodness’ sake — by foreign governments.
Fixing this anomaly would take a Constitutional amendment at this point. The Supreme Court is unlikely to reverse its 5-4 decision: the Justices most likely to leave are dissenters.
I’m not saying States and the Federal Government should be obligated to restrict speech of foreign-influenced entities. But governments should be able to say those corporations can’t contribute to campaigns or spend money to influence American elections.
Tax law provides plenty of precedent for denying or granting rights to corporations based on ownership. For instance, a controlled foreign corporation is one in which U.S. shareholders own more than 50 percent, by vote or value. Code section 957(a). Continue reading “Tax Law’s Look-through Rules Can Address Citizens United”
The Raleigh paper published the letter below (they like short ones). I titled it “Terrifying Tax Tactics,” but that may have been too much to print in one column.
North Carolina’s inheritance tax applies only to folks who meet their Maker while worth over $5 million. Just in time for Halloween, the tax-exempt Civitas Institute said it’s a gruesome tax that turns Revenue Department officials into grave robbers (Oct. 30 Under the Dome). That kind of rhetoric aims to frighten us and stop us from thinking. Boo!
Continue reading “Gruesome tax”
The WSJ reports:
” . . . the disturbance followed aggressive collection of new charges for the use of machines used to make children’s wear, the town’s mainstay product. The tax was targeted at small, independent workshops that often aren’t licensed and are manned mostly by migrant laborers who earn money per piece produced.
“They said workshop managers were being charged between 300 yuan (about $48) and 600 yuan for each machine used, in what Chinese discussing the matter online called the ‘sewing-machine tax.’ It amounts to about twice as much as was collected in the past.”
It’s a lot easier for taxers to count sewing machines once than either (1) to measure production by counting each and every item that leaves the facility or (2) to measure piecework, maybe daily, payments to workers. Was the sewing machine tax in lieu of a tax on production? Maybe so, since the operators were reportedly unlicensed. In any event, it was too effective. And it targeted a narrow group that could identify its members.
Right out of college in 1969, my first job was teaching French at maybe the best public high school in North Carolina. I was making $6,300 a year, which seemed like a lot, since all-in costs at Davidson College had been around $2,000. So I could afford to go to France in the summers. The epiphany was when I found out I could deduct all my living expenses (I took some classes, did an internship or “stage,” and traveled).
Deductions for travel were later called a loophole: “Congressional discussion of the 1986 revisions makes clear that a French professor who tours France to brush up on his language skills is not entitled to a tax deduction.” http://chronicle.com/article/Tax-PlanningSabbatical/126293/. They got me. I was on the Joint Committee staff then, and don’t remember the change. I don’t think I was involved.
I remember, as I was putting my documentation together to claim my deduction, my father telling me, “If you claim $12 a day, they’ll never question it.” I was living low to the ground back then.
“Under the [September 19 Obama Administration] proposal, if a U.S parent transfers an intangible to a controlled foreign corporation (CFC) in circumstances that demonstrate excessive income shifting from the United States, then an amount equal to the excessive return would be treated as subpart F income. This would reduce the deficit by $19 billion over 10 years.” http://www.whitehouse.gov/sites/default/files/omb/budget/fy2012/assets/jointcommitteereport.pdf
Great. But what is “excessive”? How much income-shifting is OK? This looks as vague as our old “commensurate with income” standard. (I was always irritated when that standard was labeled “super-royalty.” A salary commensurate with income is not a super-salary.) Strike “excessive” and you’re getting somewhere.
Or “if a U.S parent shifts income from the United States by transferring an intangible to a controlled foreign corporation (CFC), then an amount equal to the income [from that intangible?] would be treated as subpart F income.”