Scooter Chat

[pegsue]

[unitedrich] Whats up Scooter?

[scooter] Unitedrich Unitedrich Hey Buddy --- just looking for a couple of people --- Robo and Svanish

[unitedrich] Scooter saw Robo, must have left, hadnt seen Svanish

[scooter] Unitedrich Unitedrich Im sorry -- How are you buddy?

[EagleEye] Scooter welcome back

[unitedrich] Scooter Great! no complaints. and yourself?

[scooter] EagleEye EagleEye TY Sir !

[pegsue] Scooter Hey how are you today?

[scooter] Unitedrich Not sure just yet

[EagleEye] yw

[unitedrich] Scooter

[scooter] I 've been reading some future legislation in congress

[EagleEye] Scooter did you find what you went off for >?

[scooter] I need some assistance on some interpretation

[scooter] Svanish has some background on this I think

[scooter] EagleEye Unfortunately -- I may have

[scooter] not sure

[scooter] so panick just yet

[scooter] leggman24 leggman24 might be nothing --- refers future legislation of Foreign income

[leggman24] Scooter yea i know about it. they are trying to hide it in a bill that will pass through congress. i was hoping we would rv before they got to it.

[scooter] charlie911 charlie911 just the taxes -- nothing that states anything directly about foreign currency ---- but some interesting additions about assests

[bobbyToGo] retroactive tax,,,ask Clinton

[scooter] leggman24 they sure did hide it leggs

[charlie911] Scooter

[tony wilson] do you habe the bill #

[scooter] Charlie911 --- you are way too funny!!!

[scooter] leggman24 How did you read that -- was that meant mainly for foreign income not taxed by local country and was that just meant for Corporations

[charlie911] Scooter take off the tension

[EagleEye] ok everyone let's let Scooter talk so we can see what it is

[leggman24] Scooter yes they did. do you know when they are set to vote on it?

[charlie911] EagleEye OK EagleEye

[scooter] charlie911 charlie911 charlie911 -- and you're are perfect for the job !!!

[RicknSaudi] Scooter probably meant for expats like me

[leggman24] Scooter yea i read that. unfortionately that include us too.

[scooter] I don't know --- it's replacing some major paragraphs in established law

[RicknSaudi] Scooter Heard that may happen soon...Taxes anyway

[scooter] I need to dig into those subsections

[scooter] but here's the reason why Biden is saying October 17th -- Robo's original question

[scooter] leggman24 leggman24 I agree -- It does -- it specifically states war profits too

[scooter] anyway

[jcny47] Scooter Why is that?

[scooter] The congress Adjourns October 8th

[scooter] and the election is November 2nd

[scooter] that's why there's the hidden November 2nd timeline

[scooter] they know they are going to get obliterated and so they have to pass this tax

[scooter] leggman24

[scooter] The way I read that however is that is starts january 1, 2011

[scooter] Is that how you read that

[jcny47] Scooter please bear with me...what tax law are you speaking of? the one that they want to pass next year for income/

[scooter] jcny47 --- No -- This year

[scooter] one minute -- phone

[leggman24] Scooter i thought it went into law as soon as they passed it.

[Cyn] jcny47 This is the law they are trying to pass, that would put a 70% tax on our investment.

[leggman24] Scooter if it doesnt, then that gives us time to cash in and not have to pay the 70%.

[RicknSaudi] He's on a call from Sen. Clinton

[charlie911] Scooter i`m not sure a rv would be considered a " war profit"

[scooter] leggman24 leggman24 It's confusing that's why I need to some help interpreting

[scooter] Let me get everybody some links

[leggman24] Scooter link me baby....

[scooter] more intelligent eyes will help

[jcny47] Cyn ouch...what is wrong with them? are we not allowed to have anthing for our Families???gggeeeezzzz

[bubbie] jcny47 it's called share the wealth baby !!!!

[GJM] jcny47 Income redistribution

[scooter] http://thomas.loc.gov/cg ••• w:e16137:

[scooter] http://thomas.loc.gov/cg ••• w:e32953:

[scooter] http://thomas.loc.gov/cg ••• w:e11748:

[leggman24] Scooter give me a few to read and reread everything.

[scooter] this is the link that shows what is on the house floor

[scooter] http://majoritywhip.hous ••• Calendar

[bobbyToGo] i can't see which part pertains to a windfall for an individual

[RicknSaudi] http://majoritywhip.hous ••• Calendar

[scooter] I'm not sure what this means for individual investors -- the words can be interpreted both ways

[jcny47] would at least having a nevada corp help if you cANT DO SAYCHELLES?

[bobbyToGo] Scooter which part of the house bill text pertains to us

[scooter] keepmwlknfny keepmwlknfny I did indeed

[gozilla]

Does anyone have these links in full form? I cannot get them to work from the chat log...

Thanks for the post PegSue

[Chief V]

For some reason not one of the links worked. Gave me a DNSSEARCH link.

[pegsue]

Here is one of the links

http://thomas.loc.gov/cgi-bin/query/F?c111:7:./temp/~c111cFGtPw:e16137

Hope it works now.

pegsue

Sorry, looks like these time out. I can't get back there either.

[Jac]

Does anyone have these links in full form? I cannot get them to work from the chat log...

Thanks for the post PegSue

http://majoritywhip.house.gov

Try adding house instead of hous and adding .gov to all of the links. It worked for me. The links cut and pasted

incompletly.

[gozilla]

Here is one of the links

http://thomas.loc.gov/cgi-bin/query/F?c111:7:./temp/~c111cFGtPw:e16137

Hope it works now.

pegsue

Sorry, looks like these time out. I can't get back there either.

Thanks PegSue. That link tells me that the search has timed out on that site.

Scooter - Do you have the bill numbers you are referring to?

[tampa1000]

What was this post all about anyway?

[BobbyToGo]

There is a house bill being introduced in this congress which might pertain to our Dinar investment regarding implementing special taxation rates. Smart folks (attorneys, accts, etc) are looking into it now. They will interpret for Scooter. That's what I understand. If Dems are after our RV money, the house bill number will be posted far and wide for you to call your representatives about it.

[Carlym]

There is a house bill being introduced in this congress which might pertain to our Dinar investment regarding implementing special taxation rates. Smart folks (attorneys, accts, etc) are looking into it now. They will interpret for Scooter. That's what I understand. If Dems are after our RV money, the house bill number will be posted far and wide for you to call your representatives about it.

I swear, I am going to have a nervous breakdown. 70%????

[bayoubobby]

There is a house bill being introduced in this congress which might pertain to our Dinar investment regarding implementing special taxation rates. Smart folks (attorneys, accts, etc) are looking into it now. They will interpret for Scooter. That's what I understand. If Dems are after our RV money, the house bill number will be posted far and wide for you to call your representatives about it.

the power to tax is the power to destroy

[dhill958]

the power to tax is the power to destroy

This makes me think of a quote I just read:

"Any government big enough to give you anything you want is strong enough to take everything you have."

THOMAS JEFFERSON

[PAPATOM]

There is a house bill being introduced in this congress which might pertain to our Dinar investment regarding implementing special taxation rates. Smart folks (attorneys, accts, etc) are looking into it now. They will interpret for Scooter. That's what I understand. If Dems are after our RV money, the house bill number will be posted far and wide for you to call your representatives about it.

this needs attention !!! I suggest memberS get this information to Glenn BECK with FOX NEWS. if it's real, they will ferrett it out and expose what the dimocraps are doing! of course they will not report all the dinar THEY have...cus they got em privately while on a trip.....

they'll be after ours for more of their pet projects......BECK, SEAN HANNITY, BILL OREILY.....send it to all the conservative sharks and let them feed on it.

plus type it somewhere else...like a NEWSpAPER opinion section.....just get awareness of it out past this forum....

[brichards513]

Here is one of the links

http://thomas.loc.gov/cgi-bin/query/F?c111:7:./temp/~c111cFGtPw:e16137

Hope it works now.

pegsue

Sorry, looks like these time out. I can't get back there either.

Not sure if this is what everyone is looking for - but this legislative summary talks about foreign tax loopholes - both individual and corporate - so I thought this might be what everyone is talking about.....

HR 4213 - The American Jobs & Closing Tax Loopholes Act of 2010.pdf

[Montana]

Not sure if this is what everyone is looking for - but this legislative summary talks about foreign tax loopholes - both individual and corporate - so I thought this might be what everyone is talking about.....

What did I miss? I read this and didn't see anything that addressed our type of situation? Anyone else have a different take?

[dlbfilm]

Wow, so much to swallow on a Sunday... I am glad we have a great team working with us... Always remember dont react first, find out the facts the options then choose the best possible solution. Thats all any of us are trying to do. Just let us all know how to help each other to get through this adventure....

[Captjohn]

We know that O and his regime have made it very clear that they intend to close loop holes on foreign income and foreign tax havens for U.S. companies. That's a totally different thing than a tax on currency gains realized by U.S. citizens in the U.S. We'll just have to wait and see. No need to panic IMO.

[bayoubobby]

We know that O and his regime have made it very clear that they intend to close loop holes on foreign income and foreign tax havens for U.S. companies. That's a totally different thing than a tax on currency gains realized by U.S. citizens in the U.S. We'll just have to wait and see. No need to panic IMO.

after scanning the linked PDF, I agree

[TBnhispower]

Honestly, we do not have to take this quietly (if it's true). I say march on Washington. There are enough of us to be heard. Our government can't take everything!!!!!!!

[kingfish]

Again..... O will take every dollar from you that he can.... Michelle needs another European vacation.

REMEMBER IN NOVEMBER PEOPLE!!!!!

IF YOU WANT HOPE..... YOU GOTTA GET RID OF THE CHANGE!!!

[CAPT JACK]

FOREIGN TAX CREDIT LOOPHOLES

Summary. The bill includes changes developed jointly by the Treasury Department, the Committee on Ways and Means and the Senate Finance Committee to curtail abuses of the U.S. foreign tax credit system and other targeted abuses. Foreign tax credits are intended to ensure that U.S.-based multinational companies are not subject to double taxation. However, taxpayers have taken advantage of the U.S. foreign tax credit system to reduce the U.S. tax due on completely unrelated foreign income in a manner that has nothing to do with eliminating double taxation. The bill would eliminate $9.6 billion of foreign tax credit loopholes.

Rules to prevent splitting foreign tax credits from income. To prevent double taxation (i.e., full taxation by both a foreign country and by the United States on the same item of income), taxpayers are permitted to claim foreign tax credits with respect to foreign taxes paid on income earned offshore. Taxpayers have devised several techniques for splitting foreign taxes from the foreign income on which those taxes were paid. With these techniques, the foreign income remains offshore and untaxed by the United States, while the foreign taxes are currently available in the U.S. to offset U.S. tax that is due on other foreign source income. In many cases, the foreign income is permanently reinvested offshore such that it likely will never be repatriated and taxed in the U.S. This use of foreign tax credits has nothing to do with relieving double taxation. The President’s FY 2011 Budget proposes to adopt a matching rule to prevent the separation of creditable foreign taxes from the associated foreign income. The bill would adopt the President’s Budget proposal by implementing a matching rule that would suspend the recognition of foreign tax credits until the related foreign income is taken into account for U.S. tax purposes. The bill targets abusive techniques and does not affect timing differences that result from normal tax accounting differences between foreign and U.S. tax rules. The provision would apply to all “split” foreign taxes claimed by taxpayers after December 31, 2010.

Denial of foreign tax credit with respect to foreign income not subject to United States taxation by reason of covered asset acquisitions. There are certain rules that permit taxpayers to treat a stock acquisition as an asset acquisition under U.S. tax law. Taxpayers can obtain similar results by acquiring interests in entities that are treated as corporations for foreign tax purposes, but as non-corporate entities (such as partnerships) for U.S. tax purposes. These transactions (“covered asset acquisitions”) result in a step-up in the basis of the assets of the acquired entity to the fair market value that was paid for the stock (or interest in the business entity). In the foreign context, this step-up usually exists only for U.S. tax purposes, and not for foreign tax purposes. As a result, depreciation for U.S. tax purposes exceeds depreciation for foreign tax purposes, such that the U.S. taxable base is lower than the foreign taxable base. Because foreign taxes – and therefore foreign tax credits – are based on the foreign taxable base, there are more foreign tax credits than are necessary to avoid double tax on the U.S. tax base. Taxpayers are using these additional foreign tax credits to reduce taxes imposed on other, completely unrelated foreign income. The bill would prevent taxpayers from claiming the foreign tax credit with respect to foreign income that is never subject to U.S. taxation because of a covered asset acquisition. The provision would generally apply to related party transactions occurring after December 31, 2010.

Separate application of foreign tax credit limitation to items resourced under tax treaties. To prevent double taxation (i.e., full taxation by both a foreign country and by the United States on the same item of income), taxpayers are permitted to claim foreign tax credits with respect to foreign taxes paid on income earned offshore. To appropriately limit the use of the foreign tax credit system to the avoidance of double taxation, foreign tax credits are limited to the maximum amount of U.S. tax that could be imposed on the taxpayer’s foreign source income (i.e., thirty-five percent (35%) of the taxpayer’s foreign source income). Taxpayers have devised a technique to use the U.S. treaty network to enhance foreign tax credit utilization – well beyond what is needed to avoid double taxation – by artificially inflating foreign source income. With this technique, ownership of income-producing assets that would ordinarily be held by U.S.-based multinational companies in the United States (e.g., investments in U.S. securities) is shifted to foreign branches and disregarded entities. This income is often lightly taxed on a net basis by the foreign country, but the treaty prevails in categorizing the entire gross amount of the income generated by the U.S. assets as foreign source. This artificially inflates the taxpayer’s foreign source income and allows the taxpayer to use foreign tax credits to reduce taxes on foreign source income beyond the maximum amount of U.S. tax that could be imposed on such income. This unintended tax planning technique has nothing to do with relieving double taxation. The bill respects the treaty commitment to treating such income as foreign source, but segregates the income so that it is not the basis for claiming foreign tax credits that have nothing to do with double taxation. In doing so, the amendment conforms the foreign tax credit treatment of taxpayers operating abroad through foreign branches and disregarded entities to the treatment already afforded to taxpayers operating through foreign corporations. The bill would apply to taxable years beginning after the date of enactment.

Limitation on the use of section 956 for foreign tax credit planning (i.e., the “hopscotch” rule). U.S.-based multinational companies typically have complex foreign structures designed to mitigate their worldwide tax expense. In many cases, these structures include companies located in low-tax jurisdictions (e.g., tax havens such as Bermuda and the Cayman Islands) in a multi-tier chain of subsidiaries. If a foreign subsidiary with a relative high tax expense distributes a dividend up through a chain of companies, the foreign tax credit on the dividend ultimately received by the U.S. shareholder is a blend of the tax rates of each foreign subsidiary in that chain. If there is a tax-haven company in that chain, the U.S. tax due on the dividend may be significantly higher than the tax would have been if the foreign subsidiary’s dividend could have simply “hopscotched” over the chain as a direct distribution to the U.S. shareholder. Affirmative use of section 956, which was originally enacted as an anti-abuse provision, readily accomplishes this “hopscotch” by deeming a dividend from a foreign subsidiary directly to the U.S. shareholder. By taking advantage of this “hopscotch” rule, the foreign tax credit on this “deemed dividend” can be greater than the foreign tax credit would be on an actual dividend. The bill would limit the amount of foreign tax credits that may be claimed with respect to a deemed dividend under section 956 to the amount that would have been allowed with respect to an actual dividend. The provision would apply to the affirmative use of section 956 after December 31. 2010.

Special rule with respect to certain redemptions by foreign subsidiaries. Where a foreign-based multinational company owns a U.S. company, and that U.S. company owns a foreign subsidiary, the earnings of the foreign subsidiary are generally subject to U.S. tax when they are distributed to the U.S. shareholder. When those earnings are then distributed by the U.S. company to its foreign shareholder, a thirty percent (30%) withholding tax applies, unless reduced by treaty or some other provision of the tax code. Foreign-based multinational companies have devised a technique for avoiding U.S. taxation of such foreign subsidiary earnings. This technique involves a provision of the tax code that was originally enacted as an anti-abuse rule that treats certain sales of stock between related parties as a dividend. For example, under this provision, where a foreign-based multinational corporation sells stock in the U.S. company to its foreign subsidiary, the cash received from the foreign subsidiary in this sale is treated as a dividend from that foreign subsidiary. This deemed dividend allows the foreign subsidiary’s earnings to completely – and permanently – bypass the U.S. tax system. The bill would eliminate this type of tax planning by preventing the foreign subsidiary’s earnings from being reduced and, as a result, the earnings would remain subject to U.S. tax (including withholding tax) when repatriated to the foreign parent corporation as a dividend. The provision would apply to acquisitions after December 31. 2010.

Modification of affiliation rules for purposes of rules allocating interest expense. To prevent double taxation (i.e., full taxation by both a foreign country and by the United States on the same item of income), taxpayers are permitted to claim foreign tax credits with respect to foreign taxes paid on income earned offshore. To appropriately limit the use of the foreign tax credit system to the avoidance of double taxation, foreign tax credits are limited to the maximum amount of U.S. tax that could be imposed on the taxpayer’s foreign source income (i.e., thirty-five percent (35%) of the taxpayer’s foreign source income). Taxpayers have used various techniques to minimize the amount of foreign source interest expense, which has the effect of artificially boosting foreign source income. In turn, this permits taxpayers to utilize more foreign tax credits than would otherwise be possible, and the use of such additional foreign tax credits has nothing to do with relieving double taxation. To prevent taxpayers from avoiding these rules, Treasury regulations prevent taxpayers from excluding foreign interest expense from the foreign tax credit limitation by placing it in foreign subsidiaries. The regulations achieve this result by including certain subsidiaries in the U.S. affiliated group. As a result, foreign source interest expense will be taken into account in the determination of the foreign tax credit limitation. The bill would modify the affiliation rules to strengthen these anti-abuse rules. The provision would apply to taxable years beginning after the date of enactment.

Repeal of 80/20 rules. Under current law, dividends and interest paid by a domestic corporation are generally considered U.S.-source income to the recipient and are generally subject to gross basis withholding if paid to a foreign person. If at least eighty percent (80%) of a corporation’s gross income during a three-year period is foreign source income and is attributable to the active conduct of a foreign trade or business (a so-called “80/20 company”), dividends and interest paid by the corporation will generally not be subject to the gross basis withholding rules. Furthermore, interest received from an 80/20 company can increase the foreign source income of, and therefore the amount of foreign tax credits that may be claimed by, a U.S. multinational company. Treasury has become aware that some companies have abused the 80/20 company rules. As a result, the President’s FY 2011 Budget proposes to repeal these rules. The bill would adopt the President’s Budget proposal to repeal the 80/20 company rules. The amendment would also repeal the 80/20 rules for interest paid by resident alien individuals. The bill would include relief for existing 80/20 companies that meet specific requirements and are not abusing the 80/20 company rules. Subject to the relief for these existing 80/20 companies, the provision would apply to taxable years beginning after December 31, 2010.

Technical correction to statute of limitations provision in the HIRE Act. The bill makes a technical correction to the foreign compliance provisions of the Hiring Incentives to Restore Employment (HIRE) Act to clarify the circumstances under which the statute of limitations will be tolled for corporations that fail to provide certain information on cross-border transactions or foreign assets. Under the technical correction, the statute of limitations period will not be tolled if the failure to provide such information is shown to be due to reasonable cause and not willful neglect.

OTHER REVENUE OFFSETS

Elimination of Advanced EITC. Presently, low- and moderate-income individuals may qualify for a refundable earned income tax credit (EITC). Individuals have the option of requesting advanced payments of the EITC throughout the year by having their payments of withheld income reduced by their employer. The President’s FY 2011 Budget proposes to eliminate the advanced EITC payment option, and the bill would incorporate that proposal. This provision is estimated to raise $1.021 billion over 10 years.

Quote of the Day

Does this help

[PAPATOM]

i'm not sure this is it.

the proposed language was related t0 taxing foreign currency.........and it may just be language iin another un related bill......

[ha ha]

Not sure if this is what everyone is looking for - but this legislative summary talks about foreign tax loopholes - both individual and corporate - so I thought this might be what everyone is talking about.....

I may be wrong, but l think the Bill talk about CLOSING OTHER TAX LOOPHOLES. l did not see where the bill talks about foreign currency exchange tax rate increases. please, if you do, bring it out. It says that the bill would continue to "tax carried interest gain tax rates". The bill would requrie investment Fund Manager to treat 75% of the remaining carried interest as ordinary income (50% for taxable years begining before January 1, 2013) The provision will be effected for taxable years ending on or after January 1, 2011.

If l am compelled to pay 75% fed tax plus 7% State tax on my currency investment (Iraqi dinar) l will leave the Conutry for good. Thank God,l shall become a Canadain which is not far away.

[machcobra]

Until I see total proof of this 70% BS, I call BS. This imo, is NOT what Obama is about! Looks to me more like someone on a mission! Repubs most likely!

PROOF IS IN THE PUDDING.

after scanning the linked PDF, I agree

[pourit]

Beginning to look like offshore may be the ticket.

[Kr3W]

Until I see total proof of this 70% BS, I call BS. This imo, is NOT what Obama is about! Looks to me more like someone on a mission! Repubs most likely!

PROOF IS IN THE PUDDING.

you're joking..... right?