While I am happy Trump won, I still wish it was a better candidate. While the Trump economic policies I like, the person is ugly. Too bad the person of Clinton was just as bad or worse.
I still hope to get:
1) a good Supreme Court justice from the list Trump presented
2) Tax reform as stated (I know it will not be the whole thing, but we shall see how much can be implemented)
3) While immigration seem to be mostly off the table. I hope to see great enforcement of the laws going forward.
4) few face palming moments from Trump speaking to foreign leaders.
I think people forget that the art of the deal is to start with a very strong postion and then work towards a middle ground. You start far out there so that the middle ground is still a good position where the person gets some of what was really wanted. Trump does this to a T. His starting positions are way out there and then he shifts (review immagration). For me I hope those shifts are not too far to the left for me.
Two areas are wrong with your transfer pricing. First, the IRS scrutinizes the profit margin between the related entities in a transfer pricing structure very closely.
Since the combined filing for a US company is filed in the US, the IRS sees it all and that 500% mark up from your example would be a huge red flag. They would require proof that something was done for the product in Luxembourg that justified that large a mark up. While not impossible, this is highly unlikely.
So, the IRS will disregard the entity and roll all for the transfer pricing structure from that point into the parent company. Then tax them at the 35% rate.
Second, the combined return that is audited by the IRS eliminates assets and liabilities from related parties. So, the 'loan' from Luxembourg, would only be the cash transfer to the US on the return and the IRS would tax it at 35%.
Your plan does not work. Thank you for discussing this with me, I rarely get to talk taxes with people since their eyes normally gloss over after a couple of minutes. At this point it will be up to the members of the league to decide if this is important or not to them.
2 - Regulations
Slight of hand? If you do not see the correlation between small to mid sized, local bank closing and the loss of jobs, or larger banks buying them and then, most likely removing a number of people, to unemployment, I do not know what will.
Also, the anecdotal evidence for the Affordable Care Act to reduce working hours is right on point with under employment.
The only slight of hand happening is you asking what I would replace the Affordable Care Act. That was never part of the argument. My argument was showing how regulations hurt working people and both regulations mentioned do that. Now it is your choice to decide if it is still worth it to have the law if it hurt these people, because of other benefits received.
3- Immigration
Nothing new here to discuss and I do not need to repeat myself.
4 - Minimum wage
Nothing new here either just finger pointing at 'evil' republicans. Nothing to refute the logic of a 1000 dollar minimum wage or even to accept it will hurt jobs and the economy some, but the benefits outweigh the negatives. We could at least agree to disagree on that, but you will not concede the point. Too bad.
Thank you all for the responses, I know there are a ton I have not answered. I had hoped I would like this more, but I found it more a chore, so this will be my last post. Good luck to you all and have a great day.
Wow, so many responses. I know I will not be able to get to them all or even read them all, but there are a few that I do want to respond to.
First, J_A, thank you for the reply.
Second, you are correct about cost of goods being another expense. I should have mentioned it as well. Point for you.
Third, at least we do agree that transfer pricing is complicated and there are many ways to do it and each company has their own way. I have used the one the company I work for has for a good number of its product lines and you have mentioned another way. If my conclusion is true, then it should work for your example as well. Lets look at it.
"Because manufacturing normally takes place in high corporate tax countries, transfer pricing normally minimizes the selling price of the good to the next stage in the chain: the intermediary."
1) Is the multi national company transferring money out of the US? Yes. The payment to the vendor would be money into the non-US company and that the third party would use the cash received in that country.
2) Does this reduce the tax rate of the US multi-national company? N/A. As J_A mentioned transfer pricing has not started since this part of the transaction is to a third party vendor.
"Here’s were Ireland, Estonia, Panama, Luxembourg, the Netherlands (bet you didn’t know about those two-even more popular than Ireland) or the Caymans come in. The intermediary buys the cheap manufactured products from the Chinese affiliate, and then sells it very dearly to the next link in the chain, the final retailer."
I add these all together since whether the company's structure is a chain of only two or twenty entities, each step still; 1) send cash to purchase the goods in lower tax rate countries and 2) helps reduce the overall tax rate of the multi-national. The needless complications for naming different steps is not necessary for the conclusion that using transfer pricing to reduce the company's tax rate has moved money to lower cost countries and out of higher cost countries in an effort to reduce the company's overall tax rate..
"And you don’t need a single person in that country. It’s all a paper transaction."
"But there is no relationship between transfer pricing and employment. Labor is not located in the low tax jurisdictions, waiting for the USA to cut their corporate taxes so factories can move from China to Georgia."
It is not that transfer pricing needs people, but the money that is gained through the transfer pricing will cause the multi-national to spend it in that country. That spending will cause increases in jobs and infrastructure in that country and it is money not spent in the high taxed locations like the US.
Trying to cloud the issue with needless complications does not change the final result.
Regulations-
Would you like to prop up any more straw men to knock over? You ignore the two examples that I mentioned and then list a whole bunch of bad ones just to demonize the argument. That that way any logical debate will not happen. If you actually want to talk reasonably about this, we can continue, but I see little point until then.
The Wall-
"Besides the fact that it will be tremendously costly to build, man and maintain, and won’t be paid by Mexico; besides the fact that it will have a massive environmental impact by blocking animal routes (damn regulations); besides the fact that it will take decades and won’t be finished even if it’s started due to the fact of how the USA budgets multi-year projects in single year appropriations;"
Huh, this sounds like an argument that could have been made for the interstate road system. Or the Hoover Dam. Yet somehow that happened. The issue is not what you are saying above, but whether it is worthwhile to make the wall. We both know each other's answer.
"But because crossing back and forth is so difficult and dangerous, once here, they stay and bring in their families. And voila, 12 million people, a lot of which would rather be elsewhere, are here permanently."
Actually the best way to reduce illegal immigrants here in the US is to find them, enforce the laws, and ship them out. Shoot, according to you, most of them would thank us since the only thing keeping them here is the danger of walking back. Sounds like a win-win to me. Then they will not have to do the dangerous crossing again because the wall will make it too difficult.
Clinton-
Typical again. ignore the reason and go for an emotional response. No need to go into it anymore until you wish to be reasonable.
I am fine with the trade deals, but the US needs to be more competitive in the global market to take advantage for them instead of being taken advantage of like we are right now.
If the drop in rates happened immediately, it would, but if it is done slowly over time then the changes made by business to take advantage of this and other tax base increases would make up the difference.
On defaulting the deficit, I am not concerned. I expect the bluster and the threat to gain some advantage in negotiations.
Don Zeko, Thank you for the reply. I see this more as the loud mouth part. I am fine with bluster when there are checks in place to stop him from going beyond the bluster. His lack of policy knowledge is backed up by the people he surrounds himself with and it has been seen with the policies he has brought out, like his tax plan. I doubt they were completely his brain child.
Know this will not be popular, but I will not get into the cries of racism. I disagree and will leave it at that.
As for whether he will actually do any of these things? I do not know, but I do know what I will get with Clinton. I will hope that some will happen.
j r:
The problem with Trump’s plan is just that the numbers don’t add up.His overall tax policy would drastically cut revenues.Personally, I support cutting taxes, but for that to make sense it has to be met with cuts on the expenditure side of the ledger, which is the opposite of building a proposed giant white elephant border wall. And it’s hard for me to take a point of view seriously for gigging Hillary Clinton for not understanding the economy, while simultaneously advocating against immigration.
J R, thank you for the response. For the first point about the tax rate numbers, it depends on how the 15% rate is enacted. If it was immediately dropped from 35% tax rate to 15%, there would be a large shortfall of revenue since businesses would not be able to react that fast to offset. Yet that is not the way it should have to be done. The government has often done a tiered approach to large changes and hopefully the government would look to do it here. Say reduce the rate by 2-4% over the next 5-10 years. Also, there are two ways to affect the amount of taxes collected, one by rate changes and the other is with changing the tax base. Trump changes the tax base and there will be additional revenue coming in from that increase. The one of those changes will be the repatriating of money from over seas at a much lower rate. That was part of the plan, hopefully it will stay. This will increase the incentive for the companies to bring the cash into the US and, if the reduced rate is still high enough, it would bring in additional tax revenues. The attached article has the wrong option on what to do, but it shows there is around 2.4 trillion overseas that would be good to entice back to the US and there would be a good chunk brought back over if the reduced tax rate was between 10-15%.
As for the wall, yes it would be an additional cost to the US to build. The US spends billions today on infrastructure and this would be and additional project. This is a worth while expenditure and, ideally, funds would be shifted from the current infrastructure bucket,but I know better. It will just be tacked on. So be it, the benefit still out weighs the additional cost. With Trump's good economic plan, the economy will grow and tax revenues will increase to offset the additional expenses.
It was strange. How much was Aaron and how much was the defense. I feel like a bunch had to be Rogers, because I would have considered it a great performance to hold him to 200 yards, not 74.
I think this is when I really start to love this show. It is the clever writing and the intrigue of this war that sold the show for me.
1) Never cared for this story ark. Franklin could have just stayed in the background and I would have been fine with it.
2) Agreed. Londo still thinks the universes revolve around the Centari Republic. It also helps that Morden is the one that has helped Londo achieve the power he has, so I think he still views him as an ally.
4) When we see their motivation later on it is easy to see why they have no knowledge of empathy or kinder emtions. I agree that this is why they brought on board so of the humans to give them that knowledge. V org gur Naan zbir jnf fhttrfgrq ol gur uhzna nqivfbef nf jryy.
Agreed, Burt. It is tough to find that back that is going to in the end zone consistently, but you only need to find one and hope he hits pay dirt often.
Teams are moving away from three down backs. They now have one for the first two downs and then another for third down. That is almost the best a back gets these days. Many teams are even worse and have a split like Cleveland, three backs with none getting into the high teens of carries.
Combined to that how much more pass friendly the league is and you get drastically reduced/inconsistent points to backs.
That is why I think the zero back strategy is becoming more viable and our league is very friendly for this. We only need one back to play each week, so we only need a second back on the bye week (baring injury).
On “So. That Happened.”
That was cruel Jaybird.
"
Hello All,
While I am happy Trump won, I still wish it was a better candidate. While the Trump economic policies I like, the person is ugly. Too bad the person of Clinton was just as bad or worse.
I still hope to get:
1) a good Supreme Court justice from the list Trump presented
2) Tax reform as stated (I know it will not be the whole thing, but we shall see how much can be implemented)
3) While immigration seem to be mostly off the table. I hope to see great enforcement of the laws going forward.
4) few face palming moments from Trump speaking to foreign leaders.
I think people forget that the art of the deal is to start with a very strong postion and then work towards a middle ground. You start far out there so that the middle ground is still a good position where the person gets some of what was really wanted. Trump does this to a T. His starting positions are way out there and then he shifts (review immagration). For me I hope those shifts are not too far to the left for me.
Here is to a good four years.
Derek
On “Gasp! A Trump Supporter!”
J_A thank you for the response again.
Two areas are wrong with your transfer pricing. First, the IRS scrutinizes the profit margin between the related entities in a transfer pricing structure very closely.
Since the combined filing for a US company is filed in the US, the IRS sees it all and that 500% mark up from your example would be a huge red flag. They would require proof that something was done for the product in Luxembourg that justified that large a mark up. While not impossible, this is highly unlikely.
So, the IRS will disregard the entity and roll all for the transfer pricing structure from that point into the parent company. Then tax them at the 35% rate.
Second, the combined return that is audited by the IRS eliminates assets and liabilities from related parties. So, the 'loan' from Luxembourg, would only be the cash transfer to the US on the return and the IRS would tax it at 35%.
Your plan does not work. Thank you for discussing this with me, I rarely get to talk taxes with people since their eyes normally gloss over after a couple of minutes. At this point it will be up to the members of the league to decide if this is important or not to them.
2 - Regulations
Slight of hand? If you do not see the correlation between small to mid sized, local bank closing and the loss of jobs, or larger banks buying them and then, most likely removing a number of people, to unemployment, I do not know what will.
Also, the anecdotal evidence for the Affordable Care Act to reduce working hours is right on point with under employment.
The only slight of hand happening is you asking what I would replace the Affordable Care Act. That was never part of the argument. My argument was showing how regulations hurt working people and both regulations mentioned do that. Now it is your choice to decide if it is still worth it to have the law if it hurt these people, because of other benefits received.
3- Immigration
Nothing new here to discuss and I do not need to repeat myself.
4 - Minimum wage
Nothing new here either just finger pointing at 'evil' republicans. Nothing to refute the logic of a 1000 dollar minimum wage or even to accept it will hurt jobs and the economy some, but the benefits outweigh the negatives. We could at least agree to disagree on that, but you will not concede the point. Too bad.
Thank you all for the responses, I know there are a ton I have not answered. I had hoped I would like this more, but I found it more a chore, so this will be my last post. Good luck to you all and have a great day.
"
Wow, so many responses. I know I will not be able to get to them all or even read them all, but there are a few that I do want to respond to.
First, J_A, thank you for the reply.
Second, you are correct about cost of goods being another expense. I should have mentioned it as well. Point for you.
Third, at least we do agree that transfer pricing is complicated and there are many ways to do it and each company has their own way. I have used the one the company I work for has for a good number of its product lines and you have mentioned another way. If my conclusion is true, then it should work for your example as well. Lets look at it.
"Because manufacturing normally takes place in high corporate tax countries, transfer pricing normally minimizes the selling price of the good to the next stage in the chain: the intermediary."
1) Is the multi national company transferring money out of the US? Yes. The payment to the vendor would be money into the non-US company and that the third party would use the cash received in that country.
2) Does this reduce the tax rate of the US multi-national company? N/A. As J_A mentioned transfer pricing has not started since this part of the transaction is to a third party vendor.
"Here’s were Ireland, Estonia, Panama, Luxembourg, the Netherlands (bet you didn’t know about those two-even more popular than Ireland) or the Caymans come in. The intermediary buys the cheap manufactured products from the Chinese affiliate, and then sells it very dearly to the next link in the chain, the final retailer."
I add these all together since whether the company's structure is a chain of only two or twenty entities, each step still; 1) send cash to purchase the goods in lower tax rate countries and 2) helps reduce the overall tax rate of the multi-national. The needless complications for naming different steps is not necessary for the conclusion that using transfer pricing to reduce the company's tax rate has moved money to lower cost countries and out of higher cost countries in an effort to reduce the company's overall tax rate..
"And you don’t need a single person in that country. It’s all a paper transaction."
"But there is no relationship between transfer pricing and employment. Labor is not located in the low tax jurisdictions, waiting for the USA to cut their corporate taxes so factories can move from China to Georgia."
It is not that transfer pricing needs people, but the money that is gained through the transfer pricing will cause the multi-national to spend it in that country. That spending will cause increases in jobs and infrastructure in that country and it is money not spent in the high taxed locations like the US.
Trying to cloud the issue with needless complications does not change the final result.
Regulations-
Would you like to prop up any more straw men to knock over? You ignore the two examples that I mentioned and then list a whole bunch of bad ones just to demonize the argument. That that way any logical debate will not happen. If you actually want to talk reasonably about this, we can continue, but I see little point until then.
The Wall-
"Besides the fact that it will be tremendously costly to build, man and maintain, and won’t be paid by Mexico; besides the fact that it will have a massive environmental impact by blocking animal routes (damn regulations); besides the fact that it will take decades and won’t be finished even if it’s started due to the fact of how the USA budgets multi-year projects in single year appropriations;"
Huh, this sounds like an argument that could have been made for the interstate road system. Or the Hoover Dam. Yet somehow that happened. The issue is not what you are saying above, but whether it is worthwhile to make the wall. We both know each other's answer.
"But because crossing back and forth is so difficult and dangerous, once here, they stay and bring in their families. And voila, 12 million people, a lot of which would rather be elsewhere, are here permanently."
Actually the best way to reduce illegal immigrants here in the US is to find them, enforce the laws, and ship them out. Shoot, according to you, most of them would thank us since the only thing keeping them here is the danger of walking back. Sounds like a win-win to me. Then they will not have to do the dangerous crossing again because the wall will make it too difficult.
Clinton-
Typical again. ignore the reason and go for an emotional response. No need to go into it anymore until you wish to be reasonable.
"
North, Thank you for the response.
I am fine with the trade deals, but the US needs to be more competitive in the global market to take advantage for them instead of being taken advantage of like we are right now.
If the drop in rates happened immediately, it would, but if it is done slowly over time then the changes made by business to take advantage of this and other tax base increases would make up the difference.
On defaulting the deficit, I am not concerned. I expect the bluster and the threat to gain some advantage in negotiations.
"
Don Zeko, Thank you for the reply. I see this more as the loud mouth part. I am fine with bluster when there are checks in place to stop him from going beyond the bluster. His lack of policy knowledge is backed up by the people he surrounds himself with and it has been seen with the policies he has brought out, like his tax plan. I doubt they were completely his brain child.
Know this will not be popular, but I will not get into the cries of racism. I disagree and will leave it at that.
As for whether he will actually do any of these things? I do not know, but I do know what I will get with Clinton. I will hope that some will happen.
"
J_A true, but you say that like it does not work.Taxes have always influenced behavior and that can work here too.
"
J R, thank you for the response. For the first point about the tax rate numbers, it depends on how the 15% rate is enacted. If it was immediately dropped from 35% tax rate to 15%, there would be a large shortfall of revenue since businesses would not be able to react that fast to offset. Yet that is not the way it should have to be done. The government has often done a tiered approach to large changes and hopefully the government would look to do it here. Say reduce the rate by 2-4% over the next 5-10 years. Also, there are two ways to affect the amount of taxes collected, one by rate changes and the other is with changing the tax base. Trump changes the tax base and there will be additional revenue coming in from that increase. The one of those changes will be the repatriating of money from over seas at a much lower rate. That was part of the plan, hopefully it will stay. This will increase the incentive for the companies to bring the cash into the US and, if the reduced rate is still high enough, it would bring in additional tax revenues. The attached article has the wrong option on what to do, but it shows there is around 2.4 trillion overseas that would be good to entice back to the US and there would be a good chunk brought back over if the reduced tax rate was between 10-15%.
http://ctj.org/ctjreports/2016/03/fortune_500_companies_hold_a_record_24_trillion_offshore.php#.V72VlE0rKwk
As for the wall, yes it would be an additional cost to the US to build. The US spends billions today on infrastructure and this would be and additional project. This is a worth while expenditure and, ideally, funds would be shifted from the current infrastructure bucket,but I know better. It will just be tacked on. So be it, the benefit still out weighs the additional cost. With Trump's good economic plan, the economy will grow and tax revenues will increase to offset the additional expenses.
On “Fantasy Football 2016”
Sweet, I am in.
On “Walking The Plank To The GOP Nomination”
Excellent. Glad no one was around me as I laughed about this in the office.
On “Fantasy Football: Week 17 (and Football Season open thread)”
It did too. No dominant team and two 50/50 teams in the finals. Very interesting and a fun year. Hope we can continue this next year.
On “Fantasy Football: Week 13 (and Football Season open thread)”
I think I would rather lose the game than get that offer.
On “Fantasy Football: Week 8 (and Football Season open thread)”
It was strange. How much was Aaron and how much was the defense. I feel like a bunch had to be Rogers, because I would have considered it a great performance to hold him to 200 yards, not 74.
On “Babylonia!”
I think this is when I really start to love this show. It is the clever writing and the intrigue of this war that sold the show for me.
1) Never cared for this story ark. Franklin could have just stayed in the background and I would have been fine with it.
2) Agreed. Londo still thinks the universes revolve around the Centari Republic. It also helps that Morden is the one that has helped Londo achieve the power he has, so I think he still views him as an ally.
4) When we see their motivation later on it is easy to see why they have no knowledge of empathy or kinder emtions. I agree that this is why they brought on board so of the humans to give them that knowledge. V org gur Naan zbir jnf fhttrfgrq ol gur uhzna nqivfbef nf jryy.
On “Fantasy Football: Week 7 (and Football Season open thread)”
What is up with the Eagles? I thought they would be much better than this.
"
I am loving the interviews. I have a tough time channeling Belicheck though. I get this really nasty taste in my mouth when I try...
On “Fantasy Football: Week 6 (and Football Season open thread)”
A likely story. You probably paid someone to lure Cecil the Ouija Board from its preserve case so it looked like it was discarded.
On “Fantasy Football: Week 4 (and Football Season open thread)”
Yeah, it is starting off poorly. My two players barely beat out his one. Sigh.
"
I like seeing Tu taking a little from Burt.
On “Fantasy Football: Week 3 (and Football Season open thread)”
So far that is the winning strategy. Yet the bye weeks are coming up. Mouses may need to be clicked at that point.
On “Fantasy Football: Week 2 (and Football Season open thread)”
Agreed, Burt. It is tough to find that back that is going to in the end zone consistently, but you only need to find one and hope he hits pay dirt often.
"
Teams are moving away from three down backs. They now have one for the first two downs and then another for third down. That is almost the best a back gets these days. Many teams are even worse and have a split like Cleveland, three backs with none getting into the high teens of carries.
Combined to that how much more pass friendly the league is and you get drastically reduced/inconsistent points to backs.
That is why I think the zero back strategy is becoming more viable and our league is very friendly for this. We only need one back to play each week, so we only need a second back on the bye week (baring injury).
"
Yeah, a bunch of teams offensive lines are looking bad. Has there been anything talking about why?
On “Fantasy Football: Week 1 (and Football Season open thread)”
The thoughts and opinions of the Ouija board in no way reflect thoughts and opinions of the Week in review staff.
On “Babylonia!”
I liked this episode, but dumb and dumber got on my nerves. Lennier is awesome, but why just roll over?
*Comment archive for non-registered commenters assembled by email address as provided.