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hornmpa96

Certifiably Surly
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Everything posted by hornmpa96

  1. The Irish response will be interesting. Ireland built its economy by having a low tax rate and access to the EU.
  2. With all the browse out here, the deer are hardly hitting the protein right now.
  3. 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.
  4. 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.
  5. 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.
  6. “If it wasn’t for the testing, we wouldn’t have so many cases.” Donald J Trump, Dumbass
  7. They thought she sounded taller on the radio.
  8. 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.”
  9. 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.
  10. 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.
  11. 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.
  12. 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.
  13. A murderer was held accountable by our judicial system. It’s a step in the right direction that hopefully no one is above the law.
  14. Texags is a bastion of liberal thoughts compared to the mental midgets on Tigerdroppings.
  15. Didn’t John Wayne invent this position?
  16. Totally agree with the comments about lack of investment in higher education. However, the pre-1986 tax rates are misleading. Prior to the 1986 tax act, all personal interest expense and passive losses were deductible. So yes marginal tax rates were higher but few paid them because of the massive amounts of legal deductions available.
  17. Another hit batter - Isn’t it time for old school Dusty to order the Code Red?
  18. Should Straw owe Dusty some push-ups every time he hits a fly ball?
  19. Were you on your way to Marble Arch Station and did you find that English girl?
  20. Just rewatched the Untouchables. The score for this movie is perfect.
  21. Tied for my second favorite OU coach with John Blake - only trails Gary Gibbs.
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