Posted on 08/30/2006 9:28:44 PM PDT by stainlessbanner
Internal Revenue Service, Publication 686 (6/2004), Certification for Reduced Tax Rates in Tax Treaty Countries. Someone has been smoking the paleo greenleaf.
I'm still chuckling over this one. Not only is the U.S. one of the only industrialized nations in the world that taxes world-wide income, we have people on FR defending the practice. Double taxation must be defended at all costs! To the barricades!
My take: LINK
Yes I do.
Borrowed first by the national government, it automatically arrives to the American people with interest due.
I don't pay anyone interest for the currency I hold.
It is a fiduciary asset which is absolutely simultaneously someone else's interest-bearing liability. It bears interest for the benefit of its issuer and creator, the central banks and their stockholders, the instant it goes into circulation.
OMG! The central banks and their stockholders! How much do they make off their evil scheme? What do they do with the interest that they charge us?
This article is the best I could find, that addresses the issue I have raised.
http://www.freerepublic.com/forum/a3b66550b3ee1.htm
The United States set up a provision to allow a tax credit to offset corporate taxes paid in foreign nations. It's a little more complicated than that, but I believe this to be the general objective.
The article addresses the option of switching to a territorial system, one that would alleviate the problem the WTO and Europe seems to have with our self-designed fix.
I object to the WTO being in the position to tell the U.S. what taxation rules it can or can not implement. I'm not inclined to support the U.S. acting unfairly, but in this instance it appears the U.S. has merely settled on a method of doing something that the WTO objects to, that could be facilitated in a different manner.
The ruling is therefore silly. Above and beyond that, I beleive that sovereign nations should be able to implement whatever policies they wish. If that impacts their ability to trade, then so be it.
France subsidizes Airbus. I don't like it because it allows Airbus to compete unfairly with our airline manufacturers. I note that the WTO hasn't stepped in and stopped France. That's probably because the U.S. hasn't squealed over the practice. Still the WTO has stepped in an aided France in it's objection to the U.S. tax policies.
RudeBoy, your contention was that some people were happy to see corporations double taxed. If you'll read this article you'll relize that I am not one of them. And in this instance, since you've jumped in to disagree with me, you may be.
This is where your analysis is incorrect. The Foreign Sales Corp. acted to reduce the corporate income tax rate paid by U.S. corporations to the U.S. Treasury, not foreign governments. The WTO (and the Heritage Foundation in your link) got it absolutely right this time. The U.S. government expects U.S. based corporations to pay tax on worldwide income. This places them at a competitive disadvantage to companies from practically every other industrialized nation in the world that do not pay income tax on the money they earn overseas (making their products cheaper). The "Foreign Sales Corp." was our government putting lipstick on a pig.
United States Takes Next Step in Airbus WTO Litigation, May 30, 2005.
We're in agreement there. And why did they do that? They did it to offset additional taxes paid to foreign governments. They couldn't directly strike those foreign tax payments down.
I believe the article I linked does address this.
I'm not sure I agree that all earnings on foreign soil should be tax exempt. Here's what I've thought would be the solution to this
Instead of a corporation setting up corporate satellites in foreign nations, that are essentially a part of the whole, I'd rather see them set up a separate entity on that foreign soil. Let that entity operate as a stand alone. Then when it paid taxes in that foreign nation, it wouldn't have to face U.S. taxation.
I don't have time to discuss this right now. There are other reasons why I like this model. I wouldn't be surprised if you disagree, but that's the way it goes.
Thanks for pointing that out. I would still rather see the U.S. duke that out with France rather than with a third party that seeks to oversee U.S. trade. Our nation should not be in a subservient position to any foreign or international body.
Sorry, but that's the way I see it.
Thanks for the link Ben.
No, no, no. U.S. individuals and corporations receive credit for any income tax they pay to a foreign jusrisdiction to this day, provided there is a treaty allowing for it. I see what you are arguing, but more specifically the FSC was created to offset the additional taxes paid to us. Think of it as our Federal Government tacitly acknowledging that it was screwing us more than foreign governments screw theirs.
I'm not sure I agree that all earnings on foreign soil should be tax exempt.
Small point, but no U.S. earnings are tax exempt merely because they're earned outside the U.S. The tax is assessed, and then a credit applied, if applicable.
Instead of a corporation setting up corporate satellites in foreign nations, that are essentially a part of the whole, I'd rather see them set up a separate entity on that foreign soil. Let that entity operate as a stand alone. Then when it paid taxes in that foreign nation, it wouldn't have to face U.S. taxation.
Under current tax law, this is nearly impossible. The IRS looks at income that is "effectively connected" (a legal term of art) to the U.S. In other words, Ford USA cannot simply set-up Dorf UK, and continue to allow Dorf to take advantage of Ford R&D, or its deeper pockets, etc. Some portion of Dorf income would still be taxable by the U.S. (again, under current law).
I used to have some respect for this person even though I disagreed with him on some issues, but now - Who gives a crap what this anti-American, anti-Christian zealot thinks? I saw this idiot giving a speech on C-SPAN saying that the United States was fascist and motivated by the same religious fascism as the Islamists that are engaging in terrorist attacks and that was our motivation for "attacking" the Middle East - creating "imaginary" threats, such as the current "imaginary" one with Iran, to have an excuse to attack Muslim nations because they are not Jewish or Christian. He's an idiot who should be given the respect he has earned - none.
Pimping your own blog and using your blog to *cough* refute and/or *cough* "prove" your position, is not only against FR's posting rules, but senseless. You are no expert at all and yes, pet, I DO own my own money!
It sounds like sour grapes.
1. I never claimed to be an expert.
2. It is an opinion piece. Every post on FR is someone's opinion. If you don't like mine, tough. I don't like yours but I don't cry about it.
3. The position is backed up by citations in the article. If you don't agree with what the referenced author says, its your business.
4. If it was wrong, or against posting rules, for me to post a link rather than expending even more of my time rewriting it just for FR, then let the ADMIN MODERATOR remove it. "Broadly stated, the goals of this site are to further conservatism, expose political corruption, and recover a truly constitutional form of government." An honest money system based on precious metals is conservative, debt based fiat paper is communist; the inflation we have experienced as a result of unbacked fiat paper since the '70s is massively corrupt; the Constitution itself in Art. 1, Sec. 10, Clause 1, vacates the right of anyone to use anything but gold and silver coin as a tender in the payment of debt and to have a truly constitutional form of government, we must observe this principle, not ignore it. I don't need to be lectured by you on posting rules.
4. You say you own your own money. You'd be committing a crime if you took paper currency and incinerated it, or shredded it, or took quarters and melted them. If it were yours you could do those things, as you could with other things of yours. Since you can't lawfully do that, it is not yours. Money has historically been a creature of the state. The king or sovereign had the prerogative of issuing, debasing, writing the rules regarding money. The several states took over that prerogative for a short time during the Articles of Confederation period, then with the Constitution, it became a matter for Congress. I have to admit that we didn't really completely own the money back then either, we did; but we couldn't melt it down after a certain point. The state had a right to stop citizens from demonetizing it by melting it and trading it as bullion. Then in 1913, Congress abdicated its Constitutional authority to coin money and regulate the value thereof, and created the Federal Reserve System that would be controlled primarily by bankers rather than Congress.
What you do have is certain rights over your money while it is in your control. You do own those rights, if you want to feel you own something. You don't own the money. You have the right to spend it, save it, and keep others from spending it for you. That is about all. If you doubt it, video yourself destroying US currency and post it up on Youtube.com, showing your face, and somewhere U.S. Treasury Agents can come to arrest you. If you are so confident that you do own your money.
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