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hornmpa96

Certifiably Surly
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Posts posted by hornmpa96

  1. 8 minutes ago, fattyflattie said:

    Want to get knocked up in 10th grade or addicted to drugs, well, yeah you might have blown it.  Who’s fault is that?  

    Republicans for not allowing birth control to be taught in schools and easily available?

    • Like 2
  2. 2 hours ago, RDCanecutter said:

    But didn't the Comanche get the upper hand during the Civil War, and push the frontier back eastward about 50 miles? I believe something similar happened in Minnesota at the same time with the Sioux.

    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.

  3. 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.

    • Hook 'Em 2
  4. 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.

    • Hook 'Em 7
  5. 8 hours ago, DonkeyCigars said:

     

    But seriously, it's my opinion and belief and how I lead in life as the paterfamilias. If that were to happen rather than hit the kill switch, I would redeem the child by raising it as my own. Your mileage may vary, and it appears to do so. I'm sorry that makes us mortal enemies or whatever in your mind.

    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.”

  6. 17 hours ago, Wulaw Horn said:

    So he’s being a dick clearly, but why does he have to wear a mask to see her outside. CDC says it’s like 1 in 10000 to have outdoor transmittal and even if that happened she’s young, healthy and fully vaxed. Dads obviously an asshole but her risk calibration is fucked up. 

    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.

  7. 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.

  8. On 4/22/2021 at 6:20 AM, South Austin said:

    Just adding to the anecdotal evidence, my friend’s parents’ bought their house near Canyon Vista Middle School about 15-20 years ago for $365,000. After the dad died a year ago, the mom put the house on the market last weekend and before an open house got a cash offer for $1.4M. And because of some uber-favorable tax treatment, she’s going to pay next to nothing on the capital gains.

    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.

  9. 41 minutes ago, Neonmoon said:

    How to explain the police mentality: 

    Imagine the dorks who went to Aggy or who would go to Aggy in every high school in America getting badges. 
     

    inferiority complex + racism = Aggy

    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.

    • Hook 'Em 1
  10. 39 minutes ago, GW Hayduke said:

    Technology is surely playing a role in wealth disparity, and I agree market efficiencies can leave folks out of a job. We have always had changing technologies.  IMO our current problem is bigger and is a result of the boomer generation.

    We used to heavily tax the rich and invest in future generations. Boomers benefited from all of that.  When the boomers came along and due to their large population held a lot of political power (which they still wield), those trends shifted. 

    Higher education was much more affordable for boomers when compared to current college kids.  Pell grants have been replaced with our current student loan system.  At one point, the cost of college was growing eight times faster than wages.

    https://en.wikipedia.org/wiki/College_tuition_in_the_United_States#/media/File:InflationTuitionMedicalGeneral1978to2008.png

    Boomers were able to support a family on a single income. That is no longer the case.  

    From the 1930s to the 1980s, the top annual tax rate never dropped below 63%.  When the boomers came of age, the top annual tax rate dropped to 28% and has virtually remained below 40% for top earners.    

    Since boomers came of age, government investment in future generations have decreased. 

    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.

    • Hook 'Em 1
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