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Old 05-06-2016, 05:37 PM   #5
Greedy,Greedy,Greedy
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Re: A couple of Wonks since the last board is closed for bidness

Quote:
Originally Posted by taxwonk View Post
1. Section 162(m). TM I have no doubt there will still be many bankers, lawyers, doctors, etc., still paid in excess of $250K. I just want their employers taxed for it. I want the rest of America making their $16,000-$40,000 to stop subsidizing the ones who don't need welfare. The additional tax revenue can be put to use rebuilding roads and schools, creating jobs that pay a living wage and restoring infrastructure.

2. GGG, You say there are ways that clever lawyers use to get around 162(m). Please to show me how they will do that when there are no exceptions to 162(m) and all increases in wealth are taxed identically? As for sourcing rules, I would deal with them thus: if income from outside the US produces cash or its equivalent that comes into the hands of a domestic individual or entity, it becomes taxable US income. Loans, investment, whatever. Once the cash crosses the border it's taxed. If it is converted to hard goods and then those are imported, deem a sale at fmv at the moment the property crosses.
162(m) relates to business deduction of salary. Just make it something other than salary, whether dividends or equity comp what have you. Lawyers who take partnership draws aren't subject to 162(m); it is a corporate provision.

So you're saying that if I keep my cash abroad it's not taxed here. WAHOOO! Not a problem. Retiring to the little Attican villa owned by an offshore trust sounds cool. In the meantime, Canada is close and very, very nice.
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