U.S. Politics 2017: Yes Virginia, There Is a Santa Claus

[Fez]

8 minutes ago, Kalbear said:

They are talking about doing a write in candidacy for strange. 

Which would hand the seat to Doug Jones. This is a big difference from Murkowski's 2010 write-in campaign, where she received a large number of Democratic votes. In that race, she got 39.5%, Miller (GOP) got 35.5%, and McAdams (D) got 23.5%. Democrats don't often win in Alaska, but they generally do a lot better than that.

Doug Jones is pretty consistently already getting around 40% in the polls, so there's no incentive for his supporters to vote Strange to keep out Moore. They can just vote Jones and get him in.

[Kalbear]

I think the gop will back his running and then have him resign quickly after he's in office so that they can do another special election. 

Eta: his being Roy Moore. 

[Maithanet]

2 minutes ago, Kalbear said:

I think the gop will back his running and then have him resign quickly after he's in office so that they can do another special election. 

Eta: his being Roy Moore. 

You think Roy Moore would go along with that?  I don't.  This is a guy who twice forced people to remove him from the state supreme court.  He's not exactly a team player. 

[Mlle. Zabzie]

1 hour ago, OldGimletEye said:

I’m probably screwing this up and probably over simplifying things, but isn't the whole process something like:

1. I make MAGA caps because everyone wants one of course.

2. MAGA caps, however, are made mostly with labor. Most of my cost will be labor cost. So whether the corporate tax rate is 20% or 25% or 30% or 50% or whatever, it still cheaper to make the product in China or Vietnam or wherever than the US.

3. But, I really, don’t want to pay the US tax rate.

4. So I hire some guy in Dublin to start a company.

6. I license the trademark to the guy in Dublin,for “MAGA”, a valuable piece of intellectual property if there ever was one and he pays me some money for the trademark. But, given how valuable a trademark would be on something like MAGA, I have him pay me a very low price.

7. The guy in Dublin pays some other guy in Hannoi or maybe Beijing to start a company that makes MAGA hats. The guy in Hannoi or Beijing agrees to pay a fee for the MAGA trademark to the guy in Dublin.

8. The MAGA hats are sold around the world.

9. The guy in Dublin records a bunch of profits, which makes Ireland's GDP numbers look fantastic. He pays the Irish Corporate Tax rate. He doesn’t send the money back to the US though. He puts the money in a bank account or whatever.

10. Conservative tv commentator guy then says, “How about that Celtic Tiger! There doin’ awesome cause of that low corporate tax rate. Look at those GDP numbers! Just  Wow!”,  even though not one MAGA cap was made in Ireland and not one Irish worker got paid a dime for making MAGA caps.

Ok - so you are very close.  Let's say I am a US corporation that holds the IP to make the greatest MAGA caps ever.  I currently give a limited license to a Chinese company to contract manufacturer my MAGA caps for me, which pass to me FOB Shanghai.  I pay the Chinese company a fixed price under the contract which goes into my COGS/is in effect tax deductible.  The hats arrive at SEATAC and are shipped to my warehouse in Montana, from whence I distribute them to customers.  But lets say I am starting to have a worldwide market for my MAGA hats.  It started out small - but now there is going to be a booming business in my MAGA hats offshore.  I'm also doing a pretty brisk business onshore.  But I realize I'm also going to need a new product.  It will be based on the original MAGA hat, but I will be doing some R&D to create a new and improved MAGAer HAT.  So, what do I do.  I contribute my MAGA IP to a "platform" - the other person is my newly formed Irish subsidiary.  I will get an arm's length royalty in respect of the IP as determined by economists working for a big 4 accounting firm and memorialized in a transfer pricing study.  I move some management to Dublin; hire some European IP attorneys and create "substance" in Ireland.  I then say that Ireland will contribute all the cash for future R&D and will own all the future IP associated with the future R&D off the platform.  I will pay the Irish company a royalty to use that new R&D (which may be contracted by the Irish sub to my R&D arms in separate subsidiaries in the Bay Area and Guangzhou).  The Irish company (or another offshore affiliate) will then enter into the contract with the contract manufacturer and it will buy all the inventory for the MAGAer hats.  It will hire me as a "limited risk distributor" who will distribute the hats to US customers.  I will sell the hats and pass back all of the profit to the Irish company less a margin determined by the same accounting firm economists.  A bunch of cash ends up in Ireland, which is "active" cash, so not brought back to the US.  However, some of it ends up in my R&D company and paying US R&D folks, and some of it is used in Europe to buy out the Austrian competitor.  Still no US tax.  

So it's a lot like what you said, and there are times when people do sell the trademark cross border, only that is an immediate FMV hit, and you need a full appraisal to back you up.  Also your guy in Dublin is actually your wholly owned subsidiary, so nothing has left the system.

[Mr. Chatywin et al.]

50 minutes ago, denstorebog said:

That should be ... interesting.

Also, Strange apparently can't run. So it would have to be Brooks.

EDIT: Okay, apparently that's somewhat ambiguous.

Numerous GOP senators, including McConnell, are calling for Moore to step down.

[denstorebog]

Some people are floating the idea of Sessions getting into the race, easily holding the seat for the party and leaving Trump to find a cooperative AG for you-know-what.

[IheartIheartTesla]

Assuming Moore as a Senator is the worst case scenario, almost anything else (Strange/Sessions/Jones/a shoe as write in) would be better for both Alabama and the nation.

[Maithanet]

5 minutes ago, IheartIheartTesla said:

Assuming Moore as a Senator is the worst case scenario, almost anything else (Strange/Sessions/Jones/a shoe as write in) would be better for both Alabama and the nation.

Sessions retaking his seat and Trump appointing a lackey as AG is probably worse, because then Trump can fire Mueller whenever he wants.  Other than that, I agree. 

[IheartIheartTesla]

Firing Mueller would be crossing the Rubicon. Not sure it would turn out all that well for Trump.

Also, doesnt the new AG have to be confirmed by the Senate? I dont think Trump has the support of 51 right now, particularly if his end game is easy to see.

[Mr. Chatywin et al.]

He could use a recess appointment. The question is would MM block it by keeping the Senate in session.

[Kalbear]

1 hour ago, Maithanet said:

You think Roy Moore would go along with that?  I don't.  This is a guy who twice forced people to remove him from the state supreme court.  He's not exactly a team player. 

I don't think he'll have a choice in the matter. The Senate can remove one of their own; point of fact, this is one of the only ways that I know of that a senator can be removed, by vote of their colleagues. I think McConnell et al hate his ass very much, and would happily remove him if these allegations prove enough to get rid of him. 

And then they can have ANOTHER special election, and likely bring in Strange, and things will be fine. Heck, Trump might even go along with that happily. 

[Ormond]

2 minutes ago, Kalbear said:

I don't think he'll have a choice in the matter. The Senate can remove one of their own; point of fact, this is one of the only ways that I know of that a senator can be removed, by vote of their colleagues. I think McConnell et al hate his ass very much, and would happily remove him if these allegations prove enough to get rid of him. 

And then they can have ANOTHER special election, and likely bring in Strange, and things will be fine. Heck, Trump might even go along with that happily. 

Perhaps the above is a possibility, but I would tend to agree that Moore's personality is such that he would force the Senate to actually vote to remove him. I do not think he would resign. 

[Kalbear]

3 minutes ago, Ormond said:

Perhaps the above is a possibility, but I would tend to agree that Moore's personality is such that he would force the Senate to actually vote to remove him. I do not think he would resign. 

Oh no. I don't think he would resign in a second. He would fight tooth and nail. But I think that's a hit McConnell would be willing to take; Moore's vote isn't worth dealing with both Moore being a horrible person AND Moore being a horrible Republican. 

[denstorebog]

You want some more good news? Alright then.

 

This is just a small step of the way, but it's good to see this issue gain some traction.

[Bonnot OG]

Alabama will still vote for the predatory asshole like they voted in another predatory asshole straight into the white house. At least Moore loves god, loves the law, hates people of color and the lgbt community and is a republican, so what if he rapes kids? At least he isn't a democrat.

Fuck the GOP and Republicans.

[Maithanet]

22 minutes ago, IheartIheartTesla said:

Firing Mueller would be crossing the Rubicon. Not sure it would turn out all that well for Trump.

Also, doesnt the new AG have to be confirmed by the Senate? I dont think Trump has the support of 51 right now, particularly if his end game is easy to see.

The new AG would have to be confirmed by the Senate, but MM's threat to hold up an AG was in the event that Sessions was fired.  If Sessions left willingly, they'll appoint someone new, and it'll probably be someone who has given his personal assurances to Trump that he'll fire Mueller, if Trump needs him to. 

Trump has crossed the Rubicon a few times already.  What do you think McConnell and Ryan are gonna do?  Impeachment?  Don't be ridiculous.  Trump's approval will take another small hit, and Republicans will tut-tut that Trump shouldn't do such things.  Ignoring the fact that their actual job is to prevent him from doing such things. 

[OldGimletEye]

On 11/9/2017 at 2:48 PM, Mlle. Zabzie said:

Ok - so you are very close.  Let's say I am a US corporation that holds the IP to make the greatest MAGA caps ever.  I currently give a limited license to a Chinese company to contract manufacturer my MAGA caps for me, which pass to me FOB Shanghai.  I pay the Chinese company a fixed price under the contract which goes into my COGS/is in effect tax deductible.  The hats arrive at SEATAC and are shipped to my warehouse in Montana, from whence I distribute them to customers.  But lets say I am starting to have a worldwide market for my MAGA hats.  It started out small - but now there is going to be a booming business in my MAGA hats offshore.  I'm also doing a pretty brisk business onshore.  But I realize I'm also going to need a new product.  It will be based on the original MAGA hat, but I will be doing some R&D to create a new and improved MAGAer HAT.  So, what do I do.  I contribute my MAGA IP to a "platform" - the other person is my newly formed Irish subsidiary.  I will get an arm's length royalty in respect of the IP as determined by economists working for a big 4 accounting firm and memorialized in a transfer pricing study.  I move some management to Dublin; hire some European IP attorneys and create "substance" in Ireland.  I then say that Ireland will contribute all the cash for future R&D and will own all the future IP associated with the future R&D off the platform.  I will pay the Irish company a royalty to use that new R&D (which may be contracted by the Irish sub to my R&D arms in separate subsidiaries in the Bay Area and Guangzhou).  The Irish company (or another offshore affiliate) will then enter into the contract with the contract manufacturer and it will buy all the inventory for the MAGAer hats.  It will hire me as a "limited risk distributor" who will distribute the hats to US customers.  I will sell the hats and pass back all of the profit to the Irish company less a margin determined by the same accounting firm economists.  A bunch of cash ends up in Ireland, which is "active" cash, so not brought back to the US.  However, some of it ends up in my R&D company and paying US R&D folks, and some of it is used in Europe to buy out the Austrian competitor.  Still no US tax.  

So it's a lot like what you said, and there are times when people do sell the trademark cross border, only that is an immediate FMV hit, and you need a full appraisal to back you up.  Also your guy in Dublin is actually your wholly owned subsidiary, so nothing has left the system.

Thanks for going through all the actual mechanics and details of this for me.

I’ll definitely file it away for future reference.

[Mlle. Zabzie]

17 minutes ago, OldGimletEye said:

Thanks for going through all the actual mechanics and details of this for me.

I’ll definitely file it away for future reference.

Hah - this is a very, very, very simplified version.  Like I said, the HP testimony is the best place for this stuff.  And some things have changed.  E.g., 367(d) makes it clear that you take into account IP contributed offshore in exchange for stock as a prepaid royalty at FMV which helps some of this.  But the game is to strip income out of the US and into low tax jurisdictions, whether from royalty payments, interest payments, purchases of inventory, etc.  And all of it can happen underneath a common parented group.  And look, some of it actually makes sense.  That is, let's say in the example that you owned the Chinese manufacturing facility. China would rightfully cry foul unless the Chinese subsidiary doing the manufacturing earned a fair return.  So a lot of the cross border stuff is weighing the priorities of different sovereigns to tax parts of a chain of production and sale.  

[Paladin of Ice]

According to an update in a Washington Post article, Moore can back out of the race if he and the party agree to do so, however his name would still appear on the ballot because he's beyond the point where it can be removed, and if Moore got the most votes after dropping out of the race, that would make the Democrat the winner.

I wonder what the odds are of the Republican party holding their nose and going through with this just to avoid the near certainty of having a Democratic Senator from Alabama should Moore be forced out. Sadly, I think the odds of them doing just that are very high.

Quote

It’s too late for Alabama Senate candidate Roy Moore’s name to be removed from the ballot, even if he wants to drop out.That’s according to John Bennett, a spokesman for the Alabama secretary of state.

Bennett says the party and candidate can revoke the Republican’s nomination, but his name would appear regardless, because a key deadline has already passed. Bennett says In such a scenario, even if Moore earned more votes than the Democrat, the state canvassing board would declare the Democrat the winner.Several senior Republicans called on Moore to quit the race after The Washington Post reported allegations of sexual misconduct.

 

[OldGimletEye]

23 hours ago, Mlle. Zabzie said:

Hah - this is a very, very, very simplified version.  Like I said, the HP testimony is the best place for this stuff.  

I’d imagine it’s a lot more complicated. But some people like myself have to start out slowly, or we might get utterly confused and have a helmet fire or something.

But, anyway, most of this tax stuff and international tax stuff, that I know is mainly from highly abstract  models. I’m not well versed as I’d like to be in how the mechanics of all this stuff actually goes down in practice. So its interesting to hear the perspective somebody that knows this stuff well.
 

23 hours ago, Mlle. Zabzie said:

And look, some of it actually makes sense.  That is, let's say in the example that you owned the Chinese manufacturing facility. China would rightfully cry foul unless the Chinese subsidiary doing the manufacturing earned a fair return.  So a lot of the cross border stuff is weighing the priorities of different sovereigns to tax parts of a chain of production and sale.  

This of course seems sensible to me.