Congress must enact tax reform without territorial taxation

By Philip G. Cohen, professor, Pace University's Lubin School of Business, New York City - 04/18/13 04:20 PM ET

What does Loophole Expansion have to do with Tax Reform???Many companies are seeking to lower the federal tax rate that publicly-traded and other “C” corporations pay on taxable income. This is in line with a broad consensus that U.S. corporate (and perhaps individual) tax rates should be lowered, with the revenue lost from this effort made up for by limiting or eliminating certain exemptions and deductions, which is often referred to as broadening the base.??

Some of this effort has been characterized as loophole closing. While not a popular view among the U.S. corporate tax community, some have argued that loophole closing should also be used to raise additional revenue to pay-down deficits and stimulate job creation in the U.S. ??

Under the current U.S. tax structure, income not sourced or connected with the United States, and earned by foreign subsidiaries, will generally not be subject to U.S. taxation until if and when the earnings are distributed back to the United States. Many, if not most U.S. based multinationals, refrain from distributing overseas income to the United States unless most if not all the tax on the dividend is offset with foreign tax credits. Thus earnings from foreign subsidiaries operating in zero or low-taxed countries are generally kept offshore. This is referred to as the lockout effect and in some cases results in the income never being subject to U.S. or foreign tax.??

There is an exception to deferral for certain types of income and activities. When this exception applies, there is immediate U.S. taxation. The latter treatment is generally reserved for passive income, highly mobile activities, as well as investment of earnings in United States property, including most loans to related U.S. companies. If anything, over the last 10-15 years, Subpart F, the part of the Internal Revenue Code that provides for immediate U.S. taxation of certain offshore earnings, has been weakened with provisions enacted including “look-thru” and the “active financing” exception coupled with the wide utilization of foreign entities that are disregarded for U.S. tax purposes. Even aside from the foregoing, there are many other techniques available under current law, like short-term loans, to legally avoid Subpart F’s impact.??

Many U.S. based multinationals are concentrating their lobbying efforts to using tax reform to implement territorial taxation. Moving toward territorial taxation has a plethora of advocates. Even the National Commission on Fiscal Responsibility and Reform, the so-called Simpson-Bowles Commission, whose mission was deficit reduction supported territorial taxation and Erskine Bowles and Alan Simpson continue to do so. Chairman Camp of the House Ways and Means Committee is also a proponent of territorial taxation albeit with some limits. One argument for territorial taxation is that companies based outside the U.S. generally do not face worldwide taxation on active income, putting companies incorporated in the U.S. at a competitive disadvantage with their foreign-based rivals. The second argument for territorial taxation is that it will eliminate the lockout effect of having hundreds of billions of dollars of earnings trapped offshore.??

What does loophole expansion have to do with either tax reform or deficit reduction? There is an existing loophole for offshore earnings. The Internal Revenue Code today taxes income earned by a foreign subsidiary differently than if earned in the U.S. because taxation of the former is generally deferred. Hundreds of billions of dollars of profits are being shifted from the United States tax base, to abroad, where it’s deferred until if and when repatriated. It is difficult for the IRS to police this area.??

A territorial tax system would serve to encourage the shifting of activities offshore, and, with it, taxable profits and jobs. Congress attempted to address the lockout effect in 2004, with the enactment of Internal Revenue Code section 965 which permitted for a limited time, U.S. based multinationals to repatriate billions of dollars kept in foreign subsidiaries at a tax rate of 5.25 percent compared to the general corporate tax rate of 35 percent. This provision, which was part of The American Jobs Creation Act of 2004, was also heavily lobbied for by many of the same companies behind the push for territorial taxation. It didn’t create many U.S. jobs if you don’t include K Street lobbyists.

??Charlie Wilson, who headed General Motors, and became secretary of Defense under President Eisenhower has been misquoted as testifying that “what’s good for General Motors is good for the country.” There is no doubt that expanding the deferral loophole to full-blown adoption of territorial taxation would benefit many U.S. based multinationals. There are well-funded efforts to influence lawmakers of both parties in this effort.??

Congress and the administration however have a fiduciary obligation to look beyond whether such tax reform would benefit these companies and inquire how such a migration would impact jobs in the United States and the U.S. tax base. Is widening the barnyard door even further good for America? I submit that under such criteria the case for expanding the deferral loophole is dubious.??

Philip G. Cohen is a tax professor at Pace University Lubin School of Business and a retired Vice President-Tax & General Tax Counsel for Unilever United States, Inc. The opinion expressed here is his personal views.

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Propositional calculus

(Difference between revisions)'''Propositional calculus''' is the study of logical propositions, that is, logical statements that might or might not be true under various interpretations. A good deal of the study concerns how to prove theorems in symbolic logic.'''Propositional calculus''' is the study of [[logic]]al propositions, that is, logical statements that might or might not be true under various interpretations. A good deal of the study concerns how to prove theorems in symbolic logic.[[Lewis Carroll]] wrote a book on it for young students.  [[Lewis Carroll]] wrote a book on it for young students.  It has been suggested that this article or section be merged with logic. (Discuss)

Propositional calculus is the study of logical propositions, that is, logical statements that might or might not be true under various interpretations. A good deal of the study concerns how to prove theorems in symbolic logic. Lewis Carroll wrote a book on it for young students.

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Rubio: Republicans are 'primarily' to blame for culture of dependency

Sen. Marco Rubio (R-Fla.) on Thursday said his party was “primarily” responsible for the culture of dependency on the federal government in the United States.

Rubio was discussing the Gang of Eight immigration bill on "The Rush Limbaugh Show," when Limbaugh said he didn’t understand the argument that Hispanics were a natural Republican constituency because a poll showed that 70 percent of Hispanics believe “that government is the primary source of prosperity.”

“I'd say that's a growing problem in America in general,” Rubio said. “I think we have a growing problem in this country that too many people have forgotten what the true sense of prosperity is … and let me tell you who I blame for that first and foremost. I blame that primarily, quite frankly, on decisions made by the Republican Party in the past to embrace crony capitalism and corporate welfare as conservatism, when, in fact, that's not what we're about.”

Rubio didn’t identify any specific members of his party, but referenced “multiple candidates” who campaigned as small-government conservatives and later governed as big-government liberals.

That comment seemed at least partially directed at former President George W. Bush.

“I also think that while we've had multiple candidates in the past that have campaigned as limited-government conservatives ... until it's their government program that they're trying to protect, or what have you,” he said. “So I don't think necessarily Republicans have always governed as the limited-government movement and the result is you see this kind of confusion in the American electorate about what the source of prosperity is.”

Rubio said the party needed to do a better job of explaining that “free enterprise is the only way to consistently create the kind of growth and opportunity that America's always been identified with.”

“We are about upward mobility,” he said. “We're about the true free enterprise system. We're not about big companies being able to use the federal government to create rules and regulations that make it harder on their competitors.”

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Roofer Union Calls for Repeal of Obama Health Law

A labor union representing roofers is reversing course and calling for repeal of the federal health law, citing concerns the law will raise its cost for insuring members.

Organized labor was instrumental in getting the Affordable Care Act passed in 2010, but more recently has voiced concerns that the law could lead members to lose their existing health plans. The United Union of Roofers, Waterproofers and Allied Workers is believed to be the first union to initially support the law and later call for its repeal.

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Talk:History of psychology

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There seems to be lots of 'Red' links here that do not link to anything. How do I get rid of them to make the article more aestheically pleasing ? Penny

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Statement by the Press Secretary on the Situation in Venezuela

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For Immediate Release April 17, 2013 Statement by the Press Secretary on the Situation in Venezuela

 

The United States congratulates the Venezuelan people for their participation in the April 14 presidential elections in a peaceful and orderly manner.  We call on the Venezuelan government to respect the rights of Venezuelan citizens to peaceful assembly and free speech.  We also urge everyone to refrain from violence and other measure that could raise tensions at this difficult moment.  The United States notes the acceptance by both candidates for an audit of the ballots and supports calls for a credible and transparent process to reassure the Venezuelan people regarding the results.  Such a process would contribute to political dialogue and help advance the country’s democracy.

Blog posts on this issue April 18, 2013 12:29 PM EDTIn the Face of Evil, Boston Has Shown that Americans Will Lift Up What Is Good

President Obama speaks at in interfaith service dedicated to those who were gravely wounded or killed at the Boston Marathon bombing.

April 18, 2013 10:15 AM EDTWatch Live: President Obama Addresses Healing Service in Boston

President Obama will deliver remarks this morning at Healing Our City: An Interfaith Service which is dedicated to those who were gravely wounded or killed in Monday’s bombing near the finish line of the Boston Marathon.

April 18, 2013 9:57 AM EDTCourage, Strength, Resilience: Women Fight AIDS

The Kaiser Foundation hosts an event for the launch of EMPOWERED, Alicia Keys' new campaign to help end the HIV/AIDs epidemic.

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User talk:Markman

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Welcome!

Hello, --Jpatt 10:00, 19 October 2011 (EDT), and welcome to Conservapedia!

We're glad you are here to edit. We ask that you read our Editor's Guide before you edit.

At the right are some useful links for you. You can include these links on your user page by putting "{{Useful links}}" on the page. Any questions--ask!

Thanks for reading, --Jpatt 10:00, 19 October 2011 (EDT)!

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Congratulations, your account has been promoted such that you can now block other accounts!--Andy Schlafly 16:41, 7 November 2011 (EST)

Great block and reverts this morning.--Andy Schlafly 09:33, 8 November 2011 (EST)

I don't think that's a good example of a block, sorry, and changed it to 3 days. They were using the Talk pages. They were providing sources. I think this shows a need for warning, not permanent blocking. They shouldn't have re-added material removed by Aschlafly but I don't think that's cause for a permablock. Some of their edits show they believe in Christianity. --Jzyehoshua 20:04, 23 July 2012 (EDT)

I'd originally changed it to 10 minutes, because I'd just glanced at the Diff and not seen any blatant vandalism. But when I checked the page history, I realized he'd re-added material reverted by the site's founder, pretty serious, so that's why I changed it to 3 days. I've explained it to him at his talk page. I still think it was an honest mistake made by a newbie, not intentional vandalism. Intentional vandals wouldn't go to that much trouble with serious writing and attempted sources. I think he probably spent time writing it, saw it reverted, and thought he could re-add it and discuss it, not realizing who had removed it. I'd like to see him get another chance. --Jzyehoshua 20:33, 23 July 2012 (EDT)

I was wondering what AlanA was blocked for. According to Conservapedia's Guidelines, "Unlike Wikipedia, we do not block for ideological reasons. Warnings are appropriate, not for obscenity, vandalism or parody (Which are block-able offenses without warning.), but for silliness and other problems. In rare cases, our approach to repeated ideological conflict is to lock the page, and then allow the Administrator Group to make changes on a manual basis based upon submitted suggestions on the Talk page."

So if AlanA was blocked for an ideological comment, questioning whether Gallup results are critical of religion, then isn't that contrary to guidelines? And if we are allowed to block based on ideological reasons, shouldn't the guidelines be updated so people at least know what to expect? --Jzyehoshua 12:12, 24 July 2012 (EDT)

I just don't know if it sends that good a message to respond to such a comment by banning and preventing conversation. I disagree with his comment, but I think the right approach is to discuss it so long as he remains courteous and honest in the discusssion. --Jzyehoshua 12:14, 24 July 2012 (EDT) The atheistic Britons comment was vandalism I suppose though, so that might be worthy of a block. I hadn't noticed that one as much before. --Jzyehoshua 12:18, 24 July 2012 (EDT)

Okay, what is with some of these blocks? You just blocked some people on the main page who said some stuff about video games in disagreement with you, even when they were remaining courteous. What was with the block of GuitarSniper in particular? You said he was "trolling" for expressing disagreement about video games causing violence? Are we just blocking everybody who dares disagree with every single one of our most esoteric opinions now?[1] Just blocking everybody who dares make a single comment we disagree with? What's the point of Debate pages if people can't disagree reasonably? Why don't you just delete those and put up a "Dictatorship of Markman" flag on the site if you're going to make blocks like that? Man... This isn't compatible with the Guidelines at all. The site claims that "Unlike Wikipedia, we do not block for ideological reasons. Warnings are appropriate, not for obscenity, vandalism or parody (Which are block-able offenses without warning.), but for silliness and other problems. In rare cases, our approach to repeated ideological conflict is to lock the page, and then allow the Administrator Group to make changes on a manual basis based upon submitted suggestions on the Talk page."[2] Start treating these people fairly so I don't have to reverse all these silly blocks that are contary to Conservapedia's guidelines. It wastes my time and yours. --Joshua Zambrano 23:40, 24 July 2012 (EDT)

I am not saying it is but, like those of a number of long-serving editors here, this user name can be explained with about 5 seconds of thought. Croy is a surname. I also know at least one town in Britain. Ifor is a Welsh name - quite common, a variation of Ivor. Serge is a particularly common name. It's the anglisisation of Sergei, as in Prokofiev, Rachmaninov etc. I went to school with a Serge. Ban him if you like for username reasons, but I thought your comments were a little gratuitous. Just saying.... AlanE 20:23, 22 February 2013 (EST)

While I do not disagree with your recent blocks, I do feel that the the comments you put for the block reason are a little bit over the top, and do not reflect on Conservapedia's professional policies. It is perfectly fair to block a troll, but you don't need to reciprocate by making some more accusations, that have little to do with the user's actions. Thanks for reading,

brenden 21:10, 22 February 2013 (EST)

Bear in mind I was the one who started the baby-eating thing. I think he found it far more welcoming than the "FNQ Hello" (Dvergne will know what I mean.) There is a lack of basic courtesy on this site that one feels unless they are completely within the ideological circle - which you are of course.

What I said had to be said. It needs to be said every now and then because people come here, they do all the right things to get Andy's favour and are given power. They use it. Some of them abuse it. They know they have the boss's blessing. They don't know my history - usually because they haven't bothered to find out. To them I am just another troll, when really I am just letting off a bit of steam as a grumpy old man who likes taking the mickey occasionally . And I have always been a keen and somewhat amused observer of social interaction. And yes, it is trolling to an extent. So are Cons' constant hardly relevant incursions into talk pages. (And just to stir the possum (an Australianism) .... without the homosexual couple who lived in the next apartment from when I was 11 to 18 years of age I may not have been able to create the articles in Category:Sacred music for they instilled in me a love of church music that has lasted over 50 years. Musical vermin, they were.) Cheers - and sorry I misunderstood. AlanE 03:57, 23 February 2013 (EST)

What is the point of blocking a new user and telling them to recreate their account with a more appropriate username if you block them with autoblock enabled and account creation disabled ??? It seems a bit counter intuitive and unproductive to me. Dvergne 03:47, 24 February 2013 (EST)

Whoops, didn't notice I did that. Thanks, I'll avoid this mistake next time. - Markman 03:48, 24 February 2013 (EST) I suggest you be less vigorous with your blocking otherwise I may need to have a word with Andy, it seems you are starting to drive away genuine users as well as the parodists, spammers and trolls. Dvergne 09:12, 25 February 2013 (EST) Just to be sure here, could you put a diff of the offending edits that DonnyC made? brenden 23:23, 26 February 2013 (EST) I have gone through his contributions for the past week and there is nothing that is deserving of a block. --DamianJohn 01:41, 27 February 2013 (EST)

Blocking the User:GiseleRom because of Silly and/or foul username. Account may be recreated as a first name and last initial sounds quite ironic when the block isn't performed by User:MarkM but by User:Markman :-) --AugustO 14:40, 28 February 2013 (EST)

I haven't seen your input to this article on Talk:E=mc² yet - I'm interested in your thoughts! --AugustO 14:49, 28 February 2013 (EST)

If you don't know what you are doing, just don't do it! --AugustO 15:09, 28 February 2013 (EST) See my recent edit summary. - Markman 15:10, 28 February 2013 (EST) See Talk:E=mc² and my recent edit summary. --AugustO 15:11, 28 February 2013 (EST)

Hmmn - I suppose CP's policy on usernames may justify blocking him/her, but still, there remains the possibility the s/he was merely a fan of DW, and was unaware of our username policy (Usernames shall be a variation of your real name). brenden 14:27, 1 March 2013 (EST)

Great blocks, but the better block reason is "user name policy: please consider recreating ...." Thanks!--Andy Schlafly 08:57, 2 March 2013 (EST)

Given your personal feelings you should not be blocking DonnyC. In any case he was engaging playfully with a sysop who has not taken offence, and who is big enough and ugly enough to deal with it. Our role is to block obvious trolls and vandals, not editors we happen not to like. Leave that sort of blocking to the sysops, which you are not. Please try to get along with others, rather than picking fights all the time. Thanks. --DamianJohn 15:14, 3 March 2013 (EST)

I have seen your warning regarding my excessive talk posts. Note that 13 of the 20 that you mention represent four discussions. I was unaware that a three post dialog, say, resulted in a 30-post article quota, or that correcting a misspelling in a talk post added 10 more to deficit.

Another two of my talk posts were a suggestion to improve an article (which was met with a request from the original editor to make the change), plus a "done" response from me. If that exchange puts me in the hole for 20 more article updates, I can see this is a very potent rule.

I do admit that the "letter of the law" can be interpreted this way. I will be more careful in the future. As long as I'm here, I wonder if you saw my question to you regarding why you prefer "sheep" to "lamb" in Exodus? MelH 17:03, 3 March 2013 (EST)

Can I ask why you blocked me? All I did was follow the procedures to delete obvious spam. JohnQu 09:47, 5 March 2013 (EST)

How nice of you to go around ask for citations for all my contributions. A lot of the information in those articles was written through knowledge I have gained over the years so probably can't point to a specific location for the referencing. It would be much appreciated if you would help me find these references. Dvergne 03:24, 6 March 2013 (EST)

You fool! You're even doing it to items that are cited. Look at USS Sturgeon. But keep going - it's showing people just how useful I was to the "information" part of the "Encyclopedia. There are hundreds yet. (How many article have you created and on what variety of subjects?) AlanE 14:18, 6 March 2013 (EST)

So sorry but I find Markman "uncited" edits correct. You are encouraged to add sources for verifiability or ask for help.--Joaquín Martínez 19:17, 6 March 2013 (EST) Joachin, I hadn't realised how much you disliked me. I had gone out of my way to treat you with respect and to give you some grounding in the music I love. I had no idea you disrespected my knowledge. Thanks for supporting a person who is doing this for no other reason than malice towards me. AlanE 20:53, 6 March 2013 (EST) While Citation Needed tags are good, it really makes no sense that you are simply systematically going through AlanE's edits, and sticking spamming his perfectly fine pages with them. A quick Google search would verify the credence of his edits, and I see no motive behind this beside petty disagreements with AlanE. brenden 21:08, 6 March 2013 (EST)

Ya might wanna check out the edits by MattyD as BryanF was a sock of that particularly annoying user.

There are a lot of animal articles without citations, u might wanna look at them. 10:31, 8 March 2013 (EST)

And I expect those whining about citations had better be prepared to find and add them. "That's not my job" is an excuse I will never accept. Karajou 11:38, 8 March 2013 (EST)

Try this [3] template instead for short or stub articles. Karajou 17:41, 8 March 2013 (EST)

This is good, but the uncited template is still needed for articles lacking in citations. And in regards to your previous remarks, don't worry about it. As I've already said, tomorrow I'm going to start going through articles lacking in citations and work on fixing them. - Markman 17:43, 8 March 2013 (EST)

Leave mine to me and I will use the books I use to check my facts. I will do them category by category. But don't put that tag on any more of my edits. Seeing as I'm being hung out to dry here, give me at least that. Now excuse me for an hour or three - I'm laying bricks today, at least they are going to stay where I put them.AlanE 19:23, 8 March 2013 (EST)

I've drastically reduced his block period, as his edits to mainspace articles have been helpful, and his edits to talkpages have been rather productive, and insightful. brenden 23:31, 4 June 2013 (EDT)

And then you block him for 2 hours, on the grounds of "accusing you of blocking him out of vengeance". Please explain what this really means. Also, Rafael, 2 day block?? For mocking users (I presume User:C, as he is the primary editor at MPR)? User:C has demonstrated that he prefers to engage in such banter, and the rather gentle mocking from rafael (in comparison to user:C's downright belligerent words) was certainly tolerable by any standards. brenden 13:29, 6 June 2013 (EDT)

I have three issues with what you have said: 1. Before today, I have never heard of the internet joke "Ryan Cash." My account was made in June 2010 and I'm not even sure if that joke was around then, considering that you are the first person to ever bring that to my attention. If the name sounds similar, it is purely coincidence, let me explain. Ryan is my first name and cs is the initials of my double-barreled surname. H was added in when I made my very first internet account and ryancs was taken, with ryancsh being the closest option. Since then, it's just been habit to stick to it.

2. You accuse me of Parody yet there is no evidence on conservapedia to prove that I am guilty of being a parody. I have only spoke with my own opinion and the guild-lines clearly state that the parody must me on conservapedia. In fact, I direct you to the difference between conservapedia and Wikipedia page in which it clearly states that conservapedia does not ban users due to outside blogs or activities. Even though the link to an internet joke is incorrect, you are still going against the values of conservapedia by trying to discredit me with outside information. Also, I might add that if I was a parodist would I not have begun being a parody when I joined and not 2 years later?

3. You blocked me for the 90/10 rule. Firstly I would point out that the rule states "90% talk page edits and only 10% quality edits to Conservapedia articles" on the conservative commandments. My contribution as a whole as been 75%talk and 25% edits, (5 to 20) but that includes the 4 debate talks I did over a year ago. This year it has been 5-15 and in June it was 5-2 (or 5-4 if you count my user page as talk). Surely this would show that I was starting to reform my behavior when you blocked me. I trust that an administrator, who is obviously dedicated as he is fervent to expel any troublemakers, would not like to give the impression "it doesn't matter if you reform we will still ban you" as this goes against the whole idea of repentance and forgiveness. In fact, your block has meant that I am not able to make the planned edits to the Liberal Denial page as I was blocked until 11PM and then had to spend my time writing this to prove my innocence.

So please, in the future, could you just ask before you block or give a verbal warning so that the accused (me in this case) has time to explain. Justice, not vengeance, is truly conservative. Ryancsh 5 June 2013 20:34 GMT

There is no evidence of parody or intentional misinformation from user Ryancsh. Karajou 02:02, 6 June 2013 (EDT)

I like how you didn't even bother to read that userpage. *sarcastic slow clap* brenden 15:50, 6 June 2013 (EDT)

You do have to admit, some of it is quite witty :) -- Penny

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