Showing posts with label Flat tax. Show all posts
Showing posts with label Flat tax. Show all posts

Tuesday, December 19, 2017

Do You Know What Is In The Tax Bill That Congress Is About To Pass?

Do You Know What Is In The Tax Bill That Congress Is About To Pass? | Tax-Public-Domain | Economy & Business IRS Politics US Congress


A conference committee has been merging the tax bills that were passed by the House of Representatives and the Senate, and even though we could still see some minor changes, it looks like the major parameters of the final bill have now been agreed upon.  The final bill will be known as the Tax Cuts and Jobs Act, and we are being told that it will be one of the largest tax cuts in U.S. history.  Unfortunately, the impact on our tax bills will be relatively minor, but at least it is a step in the right direction.  The following summary of the major provisions in the final bill comes from AOL…


  • A less generous corporate rate cut: Republicans may cut the corporate rate to 21% from the current federal rate of 35%, instead of the 20% proposed in both the house and Senate bills. The new rate would start in 2018.

  • A lower top individual tax rate: The top individual bracket would drop to 37% instead of the 38.5% proposed in the Senate bill. It would still be down from the current 39.6%.

  • Keep the estate tax, but raise the threshold to qualify: Instead of phasing out the estate tax over time, like the House bill, the compromise bill would instead simply increase the threshold for an estate to qualify — from $5.6 million to around $11 million. That aligns with the Senate bill.

  • Repeal the corporate alternative minimum tax (AMT): The corporate AMT in the Senate bill was a sore spot for many companies because it would have negated the effects of many popular deductions and credits, like the research and development credit.

The reduction in the corporate tax rate is probably the most important provision in this tax overhaul package.  For decades, the United States has had a much higher corporate tax rate than much of the rest of the world, and this has given large corporations an incentive to locate operations elsewhere.  By making the corporate tax rate more competitive with everyone else around the globe, it is hoped that this will mean more good jobs for American workers.


This bill also reduces individual tax rates, but not by that much.  So you will notice a reduction in your tax bill, but don’t expect anything “game changing” in nature.


In addition, this bill will eliminate the Obamacare individual mandate.  This is something that should have been done back in January, and I am very happy that Congress is finally getting it done.


It is anticipated that both the House and the Senate will vote on the final version of this tax bill next week.


Sadly, it is not a slam dunk that this bill will actually get through the Senate.


Senator Bob Corker voted against the original Senate bill, and he may vote against this version too.


Ron Johnson of Wisconsin and Susan Collins of Maine have also expressed reservations about this bill, and it is unclear how they will vote at this point.


And let us not forget that Senator John McCain’s health is rapidly failing.  Hopefully he would be present for any vote, but there is no guarantee that will happen.


In the end, Republicans can only lose two votes in the Senate, and so this is going to come down to the wire.


But President Trump is quite optimistic that this bill will succeed, and he says that it will “breathe new life into the American economy”…


“Our tax cuts will break down — and they’ll break it down fast — all forms of government and all forms of government barriers and breathe new life into the American economy,” Trump said.


“They will unleash the American people, they will tear down the constraints on discovery, innovation and creation, and they will restore the hopes and dreams of the American family. Millions of middle class families will win under our plan.”


Of course even if this bill passes, our tax code will still be a complete and utter nightmare.


The tax code will still be over two million words, and the regulations will still be more than seven million words.  Our system will still greatly favor those that can hire accountants and tax attorneys to find every conceivable loophole possible, and it will still be a tremendous burden on the middle class.


If I am elected to Congress, I am going to fight to completely abolish the IRS and the income tax.  As I travel around Idaho and speak to groups, many are extremely receptive to these proposals, but they wonder how we would fund the government without an income tax.


Well, the truth is that the individual income tax only accounts for about 46 percent of all federal revenue, so we could definitely eliminate the individual income tax but we would also have to dramatically reduce the size of the federal government at the same time.


And we have a historical precedent for what this would look like.


Between 1872 and 1913 there was no federal income tax, and it was the best period of economic growth in U.S. history.


Of course the Democrats are not just going to roll over and allow us to cut the size of the federal government in half, so in the short-term we can focus on some other solutions.  A flat tax or a fair tax would both be far superior to the system that we have today, and there are some very good proposals already out there that just need to be implemented.


I once spent an entire year studying our tax code, and I still shudder when I think about those 12 months.  Our tax code is a complete and utter abomination, and while I applaud Congress for trying to “simplify” it, the truth is that this bill that is about to be passed won’t make that much of a difference.


We need to fundamentally change the way that we fund government in this nation, and that is why I want to completely abolish the income tax.  The system that we have right now is simply not fixable, and we should not pretend that any “tax reform bill” is going to solve our problems.


The post Do You Know What Is In The Tax Bill That Congress Is About To Pass? appeared first on The Sleuth Journal.

Monday, December 11, 2017

Senate Tax Debacle: Certain Pass-Through Entities Face Marginal Tax Rates Over 100% Under Current Bill

As the House and Senate continue to try to reconcile their two versions of a tax plan, the taxing structure for pass-through entities (s-corps, LLC"s, etc.) continues to be somewhat controversial, if not completely nonsensical. As we pointed out last week, the Senate bill somewhat randomly chose to exclude pass-through entities organized as family trusts from tax cuts which would ultimately leave them on the hook for much larger tax bills due to the elimination of other deductions. It"s unclear whether this bizarre exclusion was just an oversight or an intentional political hit on an easy target that no one in Washington DC would dare defend publicly: rich families organized as trusts.


Now, a new note from the Tax Policy Center lays out some scenarios whereby the marginal tax rate for high-income pass-through entities could soar to over 100%.  Of course, while two rational people can debate the impact of a ~40% tax rate on a person"s desire to work, we"re almost certain that a taxing structure that takes more than 100% of your marginal income will be a slight disincentive.  Here"s an example of how it works from the Wall Street Journal:








Consider, for example, a married, self-employed New Jersey lawyer with three children and earnings of about $615,000. Getting $100 more in business income would force the lawyer to pay $105.45 in federal and state taxes, according to calculations by the conservative-leaning Tax Foundation. That is more than double the marginal tax rate that household faces today.


 


If the New Jersey lawyer’s stay-at-home spouse wanted a job, the first $100 of the spouse’s wages would require $107.79 in taxes. And the tax rates for similarly situated residents of California and New York City would be even higher, the Tax Foundation found. Analyses by the Tax Policy Center, which is run by a former Obama administration official, find similar results, with federal marginal rates as high as 85%, and those don’t include items such as state taxes, self-employment taxes or the phase-out of child tax credits.



As Joseph Rosenberg of the Tax Policy Center notes, the penalty is greatest for high-income pass-through entities in highly taxed states. 








Consider the example of a married couple whose entire income is “specified service” income generated by a pass-through entity and who claims the standard deduction. At an income of $524,000, the couple could take an $87,000 deduction (17.4% of the couple’s taxable income “without regard” to the deduction) that would reduce their taxes by $30,450 (since they are in the 35% tax bracket), but the deduction is entirely phased out at an income of $624,000. On average, that amounts to more than a 30% surtax on top of the 35% statutory tax rate over that range of income.


 


The actual phase-out is much more complicated, as the bill’s text released Monday night makes clear, because the deduction continues to apply even as its benefit is phased out. (If that sounds convoluted, it’s because it is.) The couple’s marginal income tax rate would jump to 61.375% at $528,541 of income. And it would rise to 73% until their income reaches $624,000 and the deduction is fully phased-out, at which point their marginal tax rate would return to the 35 percent ordinary income tax rate. (Note that these calculations do not include the additional 3.8 percent in self-employment payroll tax or the net investment income tax).



Here is how the overall tax rate schedule for pass-through income would look:



“This is a big concern,” said Scott Greenberg, a Tax Foundation analyst. “It would be unfortunate if Congress passed a tax bill that had the effect of making additional work and additional income not worthwhile for any subgroup of households.”


Of course, in the end, this type of taxing structure just raises the returns on "gaming" the tax system in every way possible.  “I would expect a huge tax-gaming response once people fully understand how it works,” said Mr. Gamage, a former Treasury Department official, who said business owners have an easier time engaging in such tax avoidance than salaried employees do. “The payoff for gaming is huge, within the set of people who both face these rates and have flexible enough business structures.”


Not surprisingly, lawmakers are looking at changes to prevent this debacle from happening as they attempt to reconcile Senate and House versions of the tax bill this week. The formal House-Senate conference committee will meet on Wednesday, and GOP lawmakers have said they may unveil an agreement by week’s end...though they seem to consistently miss their own self-imposed deadlines.


But you shouldn"t worry about these issues too much as a spokeswoman for the Senate Finance Committee assured the Journal that as "with any major reform, there will always be unusual hypotheticals delivering anomalous results...The goal of Congress’s tax overhaul has been to lower taxes on the American people and by and large, according to a variety of analyses, we’re achieving that."









Friday, December 8, 2017

Tax Bill May Spark Exodus From High-Tax States

From FinancialSense.com via ValueWalk.com,


The following is a summary of our recent podcast, “Exodus – The Major Wealth Migration,” which can be listened to on our site here on on iTunes here.



It’s looking increasingly likely that we’ll see the GOP tax bill pass in the near future. Prepped for signing by the end of this year, the bill is sure to have sweeping effects on all taxpayers, especially those in high tax states.


Consider Dan White at Moody’s: Taxation Shift Spells Trouble for Underfunded States


“(Eliminating the state and local tax deduction) could help on the margins to drive people from those states to lower tax states because their burdens are going to increase significantly,” White said.


 


“What’s more, it’s going to make it more difficult during the next recession for states to increase taxes without being burdensome to the underlying economy.”



Many of the Rich Will Pay Under New Tax Plan


If we take the example of a high-net-worth individual living in California and making $1 million a year, that person’s state taxes amount to $102,000. If that person owns a $1.5 million home, property taxes would be around $27,000. As the new plan eliminates mortgage interest deduction above $500,000, this person would lose the ability to deduct roughly $20,000 in interest expenses.


In total, this person would lose roughly $150,000 in deductions. At a 40 percent tax rate, this person would end up paying around $60,000 more in taxes under the GOP plan.


“The idea that this is a tax giveaway to the rich just doesn’t hold true,” Financial Sense’s Jim Puplava said.


 


“It may help somebody that lives in Florida, who doesn’t have to worry about state tax deductions, because there’s no state income tax. And it does help out corporations by lowering their tax rate… but as far as individuals who lose their itemized deductions, this is going to, in effect, be a tax increase.”



Millionaire Migration Patterns


Generally, high-net-worth individuals don’t tend to move state-to-state very often, but that’s probably about to change.


One notable example occurred last year when billionaire hedge fund manager David Tepper relocated from high income tax New Jersey to Florida, which doesn’t have a state income tax. This not only saved Tepper millions of dollars, but also cost New Jersey as well.


If the GOP plan goes through, high tax states may have to rethink their tax strategy.


“I think we’re going to see a big migration,” Jim Puplava told listeners this week.


 


“We’re already losing almost 100,000 taxpayers per year in California. … If this tax bill goes through, this is really going to force a lot of people out. This is going to have a major impact on those high-tax states, and this is going to be a revenue drain.”



Ramifications Down the Road


With the deductibility of state and property taxes under threat, where every dollar paid saves 40 cents in federal taxes, we could see the effective tax rate spike.


Also, historically, when the federal government has eliminated deductions in exchange for lower tax rates, it has a habit of hiking those rates back up in short order. This happened in 1986 under Ronald Reagan’s tax reform where we saw President Bush Sr. and President Clinton hike rates up to the current 39.6 percent rate on the high end.


“This is a major game changer,” Puplava said.


 


“Now that it looks like we have a greater likelihood of this tax bill getting passed, we’re going to see a demographic migration.”



Listen to all our daily interviews with leading guest experts by clicking here.









Monday, November 13, 2017

The Whiskey Rebellion: How Brand New America Tore Up The Bill of Rights

Via The Daily Bell


223 years ago today, “The Dreadful Night” occurred in Western Pennsylvania, after an uprising called The Whiskey Rebellion.


The United States was brand new. Soldiers who had fought for independence from Great Britain found themselves on opposite sides of a skirmish. Some were having their rights violated practically before the ink was dry on the Bill of Rights. Other Veterans of the Revolution were doing the oppressing at Alexander Hamilton’s behest.


The Whiskey Rebellion saw farmers stand up to an unfair tax handed down by the federal government, and the government responded with the force of a monarchy. It may have all sprung from Alexander Hamilton’s desire for glory. Or Hamilton, the first Secretary of Treasury, may have had other motives for setting the precedent of force which still lives on today.


It all started after the Revolution, in 1791, when the federal government was in debt, and had no official money. The notes they paid to soldiers were worth fractions of what was promised, but many had no choice but to accept the funds and go home in order to try to survive.


But the soldiers were not the only ones who needed to be paid after the war. There were a number of rich investors and bankers who had provided the capital needed to win the Revolution. They too were awaiting repayment.


Alexander Hamilton had a better relationship with these financiers than with the soldiers. Hamilton was one of the leading banking figures of the time. He proposed a tax which would have two purposes. The tax would raise the revenue necessary to pay back the wealthy financiers of the Revolution. But the tax would also bring under the jurisdiction of the federal government a group of pioneers living in rural western Pennsylvania. The tax was to be levied on the production of whiskey, and not just at a commercial level. Everyone who made whiskey owed the tax. This would be the first federal tax on domestic goods.


This was a problem for the people of western Pennsylvania. Most people in this area used whiskey as a currency. Whatever surplus grain a family had would be converted into whiskey in order to preserve it. Whiskey would still have the calories of grain and was drank by almost everyone. It could be used for preserving and making some medicines.


Whiskey didn’t spoil, was widely used, and easy to transport. This made it an ideal currency. No need for banks, no need for paper money the worth of which can be manipulated. These people had tangible goods with intrinsic value absent of government mandate.


But Alexander Hamilton and the federal government insisted that the tax on whiskey be paid in coin.


For western Pennsylvanians, this amounted to an income tax. But even worse, now they had to find a way to convert their whiskey into coin. They had no use for coin since they used whiskey as a currency. But now the federal government would require them to use more time and effort just to pay the tax.


But it gets worse. Producers of whiskey were given a choice. They could pay a flat tax or pay a per gallon price. For commercial distillers who produced a lot of whiskey, the flat rate was cheaper than the per gallon rate. But for individuals, the per gallon rate was cheaper.


This was a political reward that Hamilton gave to commercial whiskey distillers in the area. They would now have the cheapest whiskey available since the flat tax worked out to a lower per gallon rate than home-distillers were forced to pay.


Hamilton did this to gain a foothold of support in the area (his enforcer was a large scale distiller) and to convert the economy of western Pennsylvania away from a whiskey-based currency. The sooner everyone was brought under the jurisdiction of the federal government, the sooner the government could raise money to pay for spending.


The tax destroyed the way of life for your average rural Pennsylvanian. First, they were singled out for a tax that most city dwellers would not be affected by. Next, they were forced to find a way to earn coin in order to pay the tax. Then, the tax made their whiskey more expensive compared to commercial distillers. This meant it was harder to sell, making it harder to convert the whiskey into coin to pay the tax.


Many people from this area moved out west to avoid the intricacies of society and government. Some were veterans of the Revolution. They would not accept this tax.


They were outraged that this tax was levied against them while the Northwest Indian War was going badly for the U.S. making the area unsafe. Seeing the tax as an advantage to grain growers (who owed no tax) and big distillers in the east (who owed a flat rate) also fueled western Pennsylvanian’s anti-federal sentiment.


They decided that if this was the way the new country was to treat its people, they wanted no part in it. They refused to pay the tax and served vigilante justice to tax collectors and other sympathizers of the federal government. They reacted similarly to how the United States reacted to unfair British taxes which sparked the Revolution.


By 1794 the climax of the situation unfolded. A U.S. Marshall was sent to the area and a showdown ensued. Some rebels were shot in a skirmish and their leader, a veteran of the Revolution, was killed. The tax collector and U.S. Marshall were captured only to later escape, and the fury of western Pennsylvanians peaked.


There was talk among the rebels that they should secede from the United States and form their own country. The plan that emerged was a watered down version of protest in which the rebels would march through Pittsburgh nonviolently. This was meant to send a message that they would not back down against what they saw as Hamilton’s attempts to pay back the wealthy by taxing the ordinary citizen.


President George Washington decided it was time to send in the army. A commission he sent to western Pennsylvania returned and recommended using the military to enforce the tax laws, and restore order.


By October 1794 Washington was seeing troops off, and heading back east, much to the dismay of some moderate locals including Congressman William Findley. He saw Washington as a fair president who just wanted to do what was right. Alexander Hamilton was the real force behind the army heading west, according to Findley, who was included on Hamilton’s list of possible rebels to be arrested.


Hamilton went with the army of nearly 20,000 as a civilian adviser. He was instructed by Washington to maintain the utmost discipline among the troops. As they advanced toward their target in western Pennsylvania, Hamilton was to prevent any breach of law by the troops, such as pillaging the countryside.


Officers harshly punished any soldier caught stealing, but the soldiers were doing so because of the lack of rations and clothing. Hamilton decided to solve this by making the theft of these goods legal. According to William Hogeland in his book The Whiskey Rebellion:


The quartermaster corps, [Hamilton] announced, would impress civilian property along the way. Now families watched helplessly as bayonet-wielding soldiers–no longer freelancing thieves but officials, authorized by the president–commandeered hard-won winter supplies of grain, meat, firewood, and blankets on behalf of the government of the United States. A steady, freezing rain meant the arrival of winter. Families whose sustenance was carted away faced grim months ahead (218).



Once the army and Hamilton finally arrived at the target county in western Pennsylvania, they contonued their oppression. They did not care much to follow the due process laid out in the Bill of Rights in new Constitution, despite Hamilton’s assurances to the President.


Many residents had signed oaths of support for the U.S. government. By signing, they risked local vigilante justice. But the U.S. promised that they would be pardoned as punishment was served to the region for failing to pay the new tax, and leading an insurrection against officials of the federal government.


These oaths were ignored and many who had signed them were arrested by Hamilton and the army anyway. A month earlier the first arrests of a few rebels had been made, prompting the most guilty among the rebels to flee. Anyone left in western Pennsylvania had minimal roles in the insurrection, and had certainly not led it. The most violent rebels, who had committed the worst acts against government officials, had already fled.


“The Dreadful Night” began in the middle of the night on November 13, 1794. Hamilton had created three lists of people: those who were not to be arrested, those who would be arrested, and those who were to be brought in as witnesses for questioning. The first list was not provided to the generals. Hamilton gave them the authority to arrest anyone they suspected of having participated in the rebellion, aided the rebels, raised liberty poles, or robbed the mail. He also authorized the troops to arrest local officials who failed to suppress the insurrection. The officers and soldiers who were passed these orders were delighted to finally have some excitement and authority on this trip west.


One particularly unstable officer named White was put in control of  the 40 prisoners which Hamilton thought would give the most valuable intelligence on the whole situation. These prisoners “were brought to a dark log structure” where they were tied up and seated on the muddy floor, and guarded by soldiers instructed to keep the prisoners away from the warmth of the fire. The tavern keeper was told he would be killed if any prisoners received food, and thus for more than two days the sadistic officer in charge:


…starved and dehydrated his shivering, exhausted captives, steadily cursing and castigating them, glorying in their helplessness and describing their imminent hanging. Even White’s troops became concerned about the captives who seemed barely alive (222).



The prisoners were then marched 12 miles in bad weather to be held in another jail, still without being charged with any crime. Following interrogation, most of them were eventually released without any criminal proceedings. This was unsurprising since most of those arrested were indeed innocent.


The arrests and brutality went on for several days throughout western Pennsylvania. This served as a reminder to all residents not to speak out against the federal government. Hamilton made it clear to the presiding judge that regardless of innocence, a good number of detainees would need to be marched back to Philadelphia in order to give the impression that the federal government had accomplished its goal, and put down a violent, unjustified rebellion. The judge held a number of rebels for trial even with what he considered lack of evidence, fearing that the army would revolt if too many prisoners were let go.


The prisoners that remained in custody were marched back to Philadelphia with great show in order to create the illusion of glory. It was essentially a photo op for Hamilton and Washington, who could now say, see, look what we did, look at the problems we solved. The prisoners were paraded on Christmas Day 1794 before 20,000 Philadelphians.


It was a disappointing show to the spectators who knowing that thousands of rebels had marched against the government, were surprised to see only twenty prisoners. Twelve cases went to trial, and two rebels were convicted. The rest weren’t released until 1796. They were left to find their way home if they could afford it. The whiskey tax remained hard to collect until it was repealed in 1801 by President Thomas Jefferson.


From the beginning of this country, the federal government has not been very good at abiding by the Constitution. Clearly, the due process rights of most of the “rebels” arrested were violated. Also violated were the rights of the farmers whose food and property was confiscated along the way in order to supply the army.


Cruel and unusual punishment was used on the prisoners, prior to them even being charged. What a precedent to set at the birth of a “free” country. They tore up the Bill of Rights before the ink had time to set.


With Hamilton’s broad presence in the foundation of the country’s banking and finances, is it any wonder that his vision has led us to where we are today? The government still uses taxes to give some businesses an advantage. The government still levies taxes which are meant to change the way citizens live their lives.


But remember that the government still found it hard to enforce and collect the whiskey tax. And today we can arrange our lives in a similar fashion, and make it difficult for the government to collect their unfair taxes. Let the spirit of rebellion inspire you.









Tuesday, November 7, 2017

Trump"s "Beautiful Tax Plan"... Fuggedaboutit!

Via MurraySabrin.com,


Last week President Trump’s tax plan was unveiled with great fanfare by the Congressional Republican leadership. Although President Trump babbled what he claimed to be the biggest tax cut in American history, the evidence is quite to the contrary.


Former Reagan budget director David Stockman dissects the “beautiful tax plan,” concluding that it is nothing less than a big scam. Tax cuts are not targeted toward the middle class but the highest income earners in the country and corporations. That is not to say that taxes should not be cut for upper income individuals, families and businesses, but all taxes should be reduced for everyone.



Closing so-called loopholes is another egregious flaw in Trump’s tax “reform.”  There are no tax “loopholes” in the tax code.  There are only exemptions. deduction and credits.  A loophole is term used by politicians and tax grabbers who think any individual, family or business that pays less taxes is getting away with not paying their “fair share.”  “Fair taxation” is an oxymoron if there ever was one.  Taxes are coerced from workers and business owners.  Thus, taxation should have no place in a free society.


If the American people really want to live in a free society (and that is a big if considering who we have elected as president, legislators or governor around the country for decades) that will create the greatest prosperity for all working folks, they should agitate for the abolition of all taxes. I make the case for abolishing all taxes America in my 1995 book Tax Free 2000: The Rebirth of American Liberty.


Why should taxes be reduced substantially or abolished altogether? Reducing taxes does three things for families and businesses.


First, less money going to the taxman means that people can spend more on their families’ needs.


 


Second, less money going to the taxman means that people can save more for the future.


 


Third, less money go to the taxman means that people can increase their charitable contributions.



But the big government proponents would scream in horror… “What about the poor?” “What about the elderly and disabled?” “What about the children and education?” “What about infrastructure?” “What about our national security?” “What about all the regulatory agencies?” And on and on and on. (I explain in Tax Free 2000 how the services that people want will be funded by voluntary exchange, and how people will make choices about what social welfare services they want to support with their charitable contributions. I also discussed the transition from the current welfare-warfare state to a free society.)


For both liberals (progressives) and conservatives they cannot conceive of a free society… one in which people are in charge of their earned incomes as opposed to having to cough up anywhere from 10 to 50% of their income to the political elites that run the country who are supported by special interests and crony capitalists that put them into office.


In addition, one of the major benefits of a tax-free society would be the end of U.S. military intervention overseas. A tax-free America would end undeclared wars and bring the troops home from the hundreds of military bases around the world, ending the military industrial complex’s global empire. Substantially lower taxes or a tax-free society would end America’s welfare-warfare state once and for all, and make the United States the greatest magnet for capital, which would boost both employment and living standards considerably.


Trump’s tax plan should be deep-sixed because it does not address the fundamental issue – federal government spending. As long as the federal government spends $4 trillion a year, which keep on increasing in good and bad times, America’s welfare-warfare state will eventually lead us to national bankruptcy, because growing entitlements and global military commitments are financially unsustainable.


Trumpnomics does nothing to take us on a journey toward a freer economy. In fact, Trump’s tax plan continues the bipartisan consensus in Washington DC, namely that without the federal government spending $4 trillion a year the economy would implode. Now is the time to have the debate that former President Clinton said we should have years ago about the role of government in a free society.


I am an unabashed, unapologetic proponent of reducing both taxes and federal spending substantially, with the goal of creating a tax-free society. Where do you stand? For liberty or statism?









Wednesday, November 1, 2017

The Delays Begin: Release Of Republican Tax Bill Postponed Until Thursday

In our comprehensive review of the GOP tax bill which was scheduled to be unveiled tomorrow, we noted the following key caveat  "There are a lot of unknowns in this process, the biggest of which - of course - is whether the bill will be delayed from its scheduled Wednesday appearance." In retrospect, and in light of the conflicting reports about what may be contained in the final draft of the bill, this has proved prophetic because moments ago, Axios reported that week"s 2nd biggest events - after Trump"s announcement of Jay Powell as the next Fed chair - the release of the Republican tax bill is being postponed by at least one day, from Wednesday to Thursday.








The delay of the scheduled release, by the House Ways and Means Committee, reveals the difficulties the team has had in resolving how to raise enough money to pay for the massive corporate tax cuts. Political hot button issues — like the treatment of 401k savings — are still in flux. The delay shouldn"t affect the timing for the mark-up, which is expected to happen Monday.



Separately, the Hill adds that the GOP now says the bill will be released on Thursday as lawmakers scramble to reach a consensus on how to restructure the nation’s tax laws.








Fights over possible changes to the tax status of 401(k) retirement plans and the state and local taxes deduction are at the center of the delay. Lobbyists chattered throughout the day over whether Wednesday’s big unveiling of the GOP tax package would have to be delayed as it became clear that lawmakers were differing over various reductions.


 


Hours before the decision was made to punt the release for a day, Ways and Means Committee Chairman Kevin Brady (R-Texas) told reporters that he intended to release text of a bill Wednesday — but that it would not be a chairman’s mark. This would allow Brady to make changes to the text through the weekend ahead of a planned markup on Monday in the Ways and Means Committee.


 


President Trump had sought to quash any changes to 401(k) plans last week, but it has become clear that Republicans have not stopped talking about shifting the tax status of the plans as they seek to ensure their bill does not add to the deficit after its first 10 years. Republicans have discussed lowering the amount people can put into their retirement plans before taxes, which could increase the amount of revenue initially hit by taxes. 


 


Brady appears to be moving toward a compromise that would allow a deduction for local property taxes — a concession that could win at least some support from the blue-state Republicans. “I think we"re moving in the right direction,” Rep. Leonard Lance (R-N.J.) said on CNN Tuesday.


 


The bill"s unveiling would launch the GOP"s blitzkrieg effort to try to pass legislation by Thanksgiving and trigger a lobbying bonanza from both supporters and opponents. Any delay in the bill’s introduction is not helpful giving the time pressures, though the delay of one day would not affect the planned Monday markup.



Meanwhile, earlier on Tuesday Bloomberg reported that Republican tax writers were planning to keep the top individual income tax rate unchanged at 39.6%. 








The top rate may apply to taxpayers with adjusted gross incomes of about $1 million and higher, said the people who asked not to be named because the discussions are private. Currently, the 39.6 percent rate kicks in at $418,400 of taxable income for single filers and $470,700 for married couples filing jointly.


 


The White House and GOP leaders’ tax framework released last month called for reducing the current seven income brackets to three -- 12 percent, 25 percent and 35 percent, with the flexibility for the tax-writing committees to add a possible fourth bracket for top earners.



The delay itself is not surprising as the final bill is expected to somehow reconcile numerous other, often conflicting items among which:


  • Are middle-class cuts from the budget framework (like doubling the standard deduction and expanded child tax credits) included?

  • Is the SALT deduction included (or capped in some way)?

  • What level is the corporate tax rate (over/under Trump’s 20% target)

  • Is there a fourth tax bracket (rumblings suggest incomes above 1mm USD would be affected)

  • Is the tax cut retroactive to Jan. 1, 2017?

  • Is there a repatriation deal for money kept overseas?

  • Does it add to the deficit?  If so, how much?

  • Will extraneous issues be slipped into the draft to entice specific voters?
    • Minimum wage hike

    • Border wall funding

    • Debt ceiling compromise

    • Planned parenthood funding


And much more. In light of this, the biggest surprise would be if the GOP actually manages to have a just one day delay.


This means that for markets Thursday is now shaping up as an especially painful day, with announcements due on not only the next Fed chair, but also the layout of the tax bill. The good news is that no matter what the "news" actually is, the market will hit new all time highs.









Tuesday, October 3, 2017

Welcome To The Hunger Games: Trump’s Tax Plan Is Going To Mean A Battle Royal Among D.C. Lobbyists

Welcome To The Hunger Games: Trump’s Tax Plan Is Going To Mean A Battle Royal Among D.C. Lobbyists | The-Hunger-Games-460x259 | Economy & Business IRS Politics Special Interests Trump


Are you ready for mass chaos in Washington?  There are lobbyists for just about every cause that you can possibly imagine, and they are always working hard to influence members of Congress on their particular issues.  But when you are talking about a major tax reform bill, that is something that virtually every single lobbyist in the entire city will want to be involved in.  Our tax code is over two million words long, and the regulations are over seven million words long, and any changes to our immensely complex system could have absolutely enormous implications.  There will be winners and there will be losers with any piece of legislation, and lobbyists will zealously fight to defend the turf belonging to their particular clients.  Often lobbyists from different sides will literally be pitted directly against one another, and it won’t be pretty.  In fact, one analyst that works for Cowen Washington Research Group says that we could soon be watching “the corporate hunger games”…



Almost every industry, special interest, and consumer group has an interest in the tax code, especially if the package ends up being as ambitious as Trump and Republican leaders want it to be. Chris Krueger, an analyst at Cowen Washington Research Group, told Business Insider that the battle over which loopholes to keep and which to throw out could get nasty.


“Welcome tribunes to the corporate hunger games!” Kruger said in an email. “Only one-sixth of lobbyists were involved with health care (give or take — assuming it is one-sixth of economy). Six-sixths of lobbyists are involved in taxes.”



There is so much at stake, and if the Republicans are able to get something passed it probably won’t look much like the plan that Trump originally proposed.  But it is so important to do something, because today Americans spend more on taxes than they will on food, clothing, and housing combined.  That is morally wrong, and we desperately need tax relief.


Trump’s tax plan would nearly double the standard deduction, and that would be a wonderful thing.  It would provide instant tax relief to working class Americans, and that is something that I would greatly applaud.



Trump’s tax plan would also great reduce the tax rate for corporations.  Our big corporations certainly don’t need the help, but we do want to get our rate more in line with the rest of the planet.  Because our corporate tax rate is one of the highest in the world, it actually encourages companies to set up shop some place else.  Being more competitive with the rest of the world would likely mean more jobs for the American people.


Trump’s tax plan would also reduce the number of tax brackets for individuals.  Instead of seven, now there would just be three tax brackets of 12 percent, 25 percent and 35 percent.  To me, those rates are way too high, but of course I would like to eliminate the individual income tax entirely.


Many are criticizing Trump’s plan for proposing to raise at least a trillion dollars over the next decade by getting rid of the deduction for state and local income taxes.  For those that live in very high tax states such as California, that deduction is a really big deal…



High-income Californians, for instance, pay as much as 13.3 per cent of their income to the state in addition to their federal taxes. New Yorkers can pay up to 8.82 per cent.


Just seven U.S. states have no personal income taxes, including Texas, Florida and Nevada.



Hopefully the Republicans can pass some sort of tax reform in the short-term, because the status quo is definitely not acceptable.


When the income tax was first introduced in 1913, the vast majority of taxpayers were being taxed at a rate of just one percent.  The following comes from Politifact…



The 1913 law imposed a tax of 1 percent on income up to $20,000, for both individual and joint filers. However, exemptions from the tax — the first $3,000 of income for individuals and the first $4,000 for joint filers — meant “virtually all middle-class Americans” were excused from paying, according to W. Elliot Brownlee’s book, Federal Taxation in America. The law also put in place a graduated surtax on incomes above $20,000; the highest rate paid, 7 percent, applied to Americans making more than $500,000 (about $11.4 million in 2011 dollars).



Today, Americans are being taxed into oblivion.  It has been reported that we spend more than 6 billion hours a year on our taxes, and I once wrote an article detailing 97 different ways that various levels of government extract revenue from all of us.


Every year government just gets bigger and bigger on the federal, state and local levels.  And the bigger government gets, the more oppressive it tends to become.


Personally, I would love to start starving the beast that the left has created, and a great way to do that would be to completely eliminate the federal income tax.


A lot of people could not even imagine a world without a federal income tax.  But the truth is that our country once thrived under such a system.  In fact, the greatest period of economic growth in U.S. history was between 1872 and 1913 when there was no income tax at all.


And we could do it again.  Today, the individual income tax only accounts for about 46 percent of all federal revenue, and if we reduced the federal government to a size that our founders would have wanted, we would be more than okay.


But even if we can’t greatly reduce the size of the federal government in the short-term, we can at least go to a very basic flat tax or a fair tax, and both of those systems would be far superior to what we have today.


If we can’t get a flat tax or a fair tax right now, we should at least try to dramatically reduce tax rates and simplify the tax code as much as humanly possible.


But if we do get a short-term victory, the battle is definitely not over.  In the long-term, we need to be very clear that our goal should be to abolish the income tax, the IRS and the Federal Reserve entirely.  Anything short of that is not good enough.







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Sunday, October 1, 2017

Welcome To The Hunger Games: Trump's Tax Plan To Unleash Battle Royal Among D.C. Lobbyists

Authored by Michael Snyder via The Economic Collapse blog,


Are you ready for mass chaos in Washington?



There are lobbyists for just about every cause that you can possibly imagine, and they are always working hard to influence members of Congress on their particular issues.  But when you are talking about a major tax reform bill, that is something that virtually every single lobbyist in the entire city will want to be involved in.  Our tax code is over two million words long, and the regulations are over seven million words long, and any changes to our immensely complex system could have absolutely enormous implications.  There will be winners and there will be losers with any piece of legislation, and lobbyists will zealously fight to defend the turf belonging to their particular clients.  Often lobbyists from different sides will literally be pitted directly against one another, and it won’t be pretty. 


In fact, one analyst that works for Cowen Washington Research Group says that we could soon be watching “the corporate hunger games”…





Almost every industry, special interest, and consumer group has an interest in the tax code, especially if the package ends up being as ambitious as Trump and Republican leaders want it to be. Chris Krueger, an analyst at Cowen Washington Research Group, told Business Insider that the battle over which loopholes to keep and which to throw out could get nasty.



“Welcome tribunes to the corporate hunger games!” Kruger said in an email.



“Only one-sixth of lobbyists were involved with health care (give or take — assuming it is one-sixth of economy). Six-sixths of lobbyists are involved in taxes.”



There is so much at stake, and if the Republicans are able to get something passed it probably won’t look much like the plan that Trump originally proposed.  But it is so important to do something, because today Americans spend more on taxes than they will on food, clothing, and housing combined.  That is morally wrong, and we desperately need tax relief.


Trump’s tax plan would nearly double the standard deduction, and that would be a wonderful thing.  It would provide instant tax relief to working class Americans, and that is something that I would greatly applaud.


Trump’s tax plan would also great reduce the tax rate for corporations.  Our big corporations certainly don’t need the help, but we do want to get our rate more in line with the rest of the planet.  Because our corporate tax rate is one of the highest in the world, it actually encourages companies to set up shop some place else.  Being more competitive with the rest of the world would likely mean more jobs for the American people.


Trump’s tax plan would also reduce the number of tax brackets for individuals.  Instead of seven, now there would just be three tax brackets of 12 percent, 25 percent and 35 percent.  To me, those rates are way too high, but of course I would like to eliminate the individual income tax entirely.


Many are criticizing Trump’s plan for proposing to raise at least a trillion dollars over the next decade by getting rid of the deduction for state and local income taxes.  For those that live in very high tax states such as California, that deduction is a really big deal…





High-income Californians, for instance, pay as much as 13.3 per cent of their income to the state in addition to their federal taxes. New Yorkers can pay up to 8.82 per cent.



Just seven U.S. states have no personal income taxes, including Texas, Florida and Nevada.



Hopefully the Republicans can pass some sort of tax reform in the short-term, because the status quo is definitely not acceptable.


When the income tax was first introduced in 1913, the vast majority of taxpayers were being taxed at a rate of just one percent.  The following comes from Politifact…





The 1913 law imposed a tax of 1 percent on income up to $20,000, for both individual and joint filers. However, exemptions from the tax — the first $3,000 of income for individuals and the first $4,000 for joint filers — meant “virtually all middle-class Americans” were excused from paying, according to W. Elliot Brownlee’s book, Federal Taxation in America.



The law also put in place a graduated surtax on incomes above $20,000; the highest rate paid, 7 percent, applied to Americans making more than $500,000 (about $11.4 million in 2011 dollars).



Today, Americans are being taxed into oblivion.  It has been reported that we spend more than 6 billion hours a year on our taxes, and I once wrote an article detailing 97 different ways that various levels of government extract revenue from all of us.


Every year government just gets bigger and bigger on the federal, state and local levels.  And the bigger government gets, the more oppressive it tends to become.


Personally, I would love to start starving the beast that the left has created, and a great way to do that would be to completely eliminate the federal income tax.


A lot of people could not even imagine a world without a federal income tax.  But the truth is that our country once thrived under such a system.  In fact, the greatest period of economic growth in U.S. history was between 1872 and 1913 when there was no income tax at all.


And we could do it again.  Today, the individual income tax only accounts for about 46 percent of all federal revenue, and if we reduced the federal government to a size that our founders would have wanted, we would be more than okay.


But even if we can’t greatly reduce the size of the federal government in the short-term, we can at least go to a very basic flat tax or a fair tax, and both of those systems would be far superior to what we have today.


If we can’t get a flat tax or a fair tax right now, we should at least try to dramatically reduce tax rates and simplify the tax code as much as humanly possible.


But if we do get a short-term victory, the battle is definitely not over.  In the long-term, we need to be very clear that our goal should be to abolish the income tax, the IRS and the Federal Reserve entirely.  Anything short of that is not good enough.


*  *  *


Michael Snyder is a Republican candidate for Congress in Idaho’s First Congressional District, and you can learn how you can get involved in the campaign on his official website. His new book entitled “Living A Life That Really Matters” is available in paperback and for the Kindle on Amazon.com.

Saturday, February 25, 2017

Which Country Punishes Productive People The Most?

Submitted by Daniel Mitchell via The Foundation for Economic Education,


Back in 2014, I shared some data from the Tax Foundation that measured the degree to which various developed nations punished high-income earners.


This measure of relative “progressivity” focused on personal income taxes. And that’s important because that levy often is the most onerous for highly productive residents of a nation.


But there are other taxes that also create a gap between what such taxpayers earn and produce and what they ultimately are able to consume and enjoy. What about the effects of payroll taxes? Of consumption taxes and other levies?


Looking at the Evidence


To answer that question, we have a very useful study from the European Policy Information Center on this topic. Authored by Alexander Fritz Englund and Jacob Lundberg, it looks at the total marginal tax rate on each nation’s most productive taxpayers.


They start with some sensible observations about why marginal tax rates matter, basically echoing what I wrote after last year’s Super Bowl.


Here’s what Englund and Lundberg wrote.





The marginal tax rate is the proportion of tax paid on the last euro earned. It is the relevant tax rate when deciding whether to work a few extra hours or accept a promotion, for example. As most income tax systems are progressive, the marginal tax rate on top incomes is usually also the highest marginal tax rate. It is an indicator of how progressive and distortionary the income tax is.”



They then explain why they include payroll taxes in their calculations.





The income tax alone does not provide a complete picture of how the tax system affects incentives to work and earn income. Many countries require employers and/or employees to pay social contributions. It is not uncommon for the associated benefits to be capped while the contribution itself is uncapped, meaning it is a de facto tax for high-income earners. Even those social contributions that are legally paid by the employer will in the end be paid by the employee as the employer should be expected to shift the burden of the tax through lower gross wages.”



Englund and Lundberg are correct. A payroll tax (sometimes called a “social insurance” levy) will be just as destructive as a regular income tax if workers aren’t “earning” some sort of additional benefit. And they’re also right when they point out that payroll taxes “paid” by employers actually are borne by workers.


They then explain why they include a measure of consumption taxation.





One must also take value-added taxes and other consumption taxes into account. Consumption taxes reduce the purchasing power of wage-earners and thus affect the return to working. In principle, it does not matter whether taxation takes place when income is earned or when it is consumed, as the ultimate purpose of work is consumption.”



Once again, the authors are spot on. Taxes undermine incentives to be productive by driving a wedge between pre-tax income and post-tax consumption, so you have to look at levies that grab your income as it is earned as well as levies that grab your income as it is spent.


All Things Considered


And when you begin to add everything together, you get the most accurate measure of government greed.





Taking all these taxes into account, one can compute the effective marginal tax rate. This shows how many cents the government receives for every euro of additional employee compensation paid by the firm. …If the top effective tax rate is 75 percent, as in Sweden, a person who contributes 100 additional euros to the economy will only be allowed to keep 25 euros while 75 euros are appropriated by the government. The tax system thus drives a wedge between the social and private return to work. …High marginal tax rates disconnect the private and social returns to economic activity and thereby the invisible hand ceases to function. For this reason, taxation causes distortions and is costly to society. High marginal tax rates make it less worthwhile to supply labour on the formal labour market and more worthwhile to spend time on household work, black market activities and tax avoidance.”



Here’s their data for various developed nations.


Keep in mind that these are the taxes that impact each nation’s most productive taxpayers. So that includes top income tax rates, both for the central governments and sub-national governments, as well as surtaxes. It includes various social insurance levies, to the extent such taxes apply to all income. And it includes a measure of estimated consumption taxation.



And here’s the ranking of all the nations. Shed a tear for entrepreneurs in Sweden, Belgium, and Portugal.


Slovakia wins the prize for the least-punitive tax regime, though it’s worth noting that Hong Kong easily would have the best system if it was included in the ranking.



U.S. Ranking


For what it’s worth, the United States does fairly well compared to other nations. This is not because our personal income tax is reasonable (see dark blue bars), but rather because Barack Obama and Hillary Clinton were unsuccessful in their efforts to bust the “wage base cap” and apply the Social Security payroll tax on all income. We also thankfully don’t have a value-added tax. These factors explain why our medium-blue and light-blue bars are the smallest.


By the way, this doesn’t mean we have a friendly system for upper-income taxpayers in America. They lose almost half of every dollar they generate for the economy. And whether one is looking at Tax Foundation numbers, Congressional Budget Office calculations, information from the New York Times, or data from the IRS, rich people in the United States are paying a hugely disproportionate share of the tax burden.


Though none of this satisfies the statists. They actually would like us to think that letting well-to-do taxpayers keep any of their money is akin to a handout.


Now would be an appropriate time to remind everyone that imposing high tax rates doesn’t necessarily mean collecting high tax revenues.


In the 1980s, for instance, upper-income taxpayers paid far more revenue to the government when Reagan lowered the top income tax rate from 70 percent to 28 percent.


Also, keep in mind that these calculations don’t measure the tax bias against saving and investment, so the tax burden on some upper-income taxpayers may be higher or lower depending on the degree to which countries penalize capital formation.


P.S. If one includes the perverse incentive effects of various redistribution programs, the very highest marginal tax rates (at least when measuring implicit rates) sometimes apply to a nation’s poor people.


P.P.S. Our statist friends sometimes justify punitive taxes as a way of using coercion to produce more equality, but the net effect of such policies is weaker growth and that means it is more difficult for lower-income and middle-income people to climb the economic ladder. In other words, unfettered markets are the best way to get social mobility.

Friday, January 13, 2017

Here Are The Winners And Losers From Trump's "Border Tax Adjustment"

In late December, we explained why of all Trump economic proposals , the "border tax adjustment", while most controversial, could have the biggest impact on US assets.


As a quick refresher, the proposal would tax US imports at the corporate income tax rate, while exempting income earned from exports from any taxation. The reform would closely mirror tax border adjustments in economies with consumption-based VAT tax systems. If enacted, Deutsche Bank predicted that the plan would be especially bullish for the US dollar, sending it higher by as much as 15%. What’s more, it would have a transformational impact on the US trade relationship with the rest of the world. Consider the below:


  • A “border tax adjustment” would, roughly speaking, be equivalent to a 15% one-off devaluation of the dollar. Imports would be 20% more expensive, because corporates would have to pay the new 20% corporate tax rate on their value. Exports would be roughly 12% “cheaper”, because for every $33 of earnings earned from $100 of exports (we use the 33% gross margin of the S&P), there would be a 12% tax cost ($33 earnings*35% current tax rate) that would no longer be imposed on corporates. Taking the average impact on the prices of exports and imports is equivalent to a 15% drop in the dollar.

  • A border tax adjustment would be very inflationary. The price of exports doesn’t affect the US consumption basket so would have no impact on CPI. However, the cost of imports would go up by 20%, which based on a simple relationship between import PPI and US inflation would be equivalent to a 5% rise in the CPI. Corporates may of course choose to absorb part of the rise in import costs in their profit margins. But either way, the order of magnitude is large.

  • A border tax adjustment would be very positive for the US trade balance. Similarly to the dollar calculations, a border tax adjustment would be equivalent to an across the board import tariff of 20% and an export subsidy of 12%. Keeping all else constant and applying standard trade elasticity impact parameters to an average of the two estimates results in a more than 2% drop in the trade deficit equivalent to more than 400bn USD, or equivalently, an almost complete closing of the US trade deficit.

In other words, should the "border tax proposal" pass, it would not only send inflation soaring, while eliminating the US trade deficit - a long-time pet peeve of Trump  - it would also be the trade-equivalent of a 15% USD devaluation, even as it leads to an offsetting surge in the actual value of the dollar.




To be sure, the "should it pass" part is a significant wildcard.  As Goldman wrote in a note yesterday, explaining "what policy changes is the equity market expecting", Goldman said that "on the tax side, the equity market appears to expect corporate tax cuts, but the evidence that a switch to a border-adjusted tax is even partially priced is only mixed."


A reason for that within the GOP ranks, a fight has emerged - funded by powerful Koch interests - against the border tax proposal, as it would cripple non-export driven businesses such as importers, apparel makers, big retailers, and various core Koch businesses as described recently by the FT.


So while the passage of the controversial Border Tax Adjustment is far from assured, overnight Credit Suisse released an analysis which analyzed the various winner and losers from the array of proposed Trump Tax Reforms, among which companies impacted by the Border Adjustment.


While the Swiss bank hedges early, noting that it is still "too early to determine winners/losers as new information is surfacing daily…and the legislative process needs to run its course this year" and that "reforms (complexity) could impact the effective tax rate, cash taxes, and/or possibly COGS (border adjustments)", it nonetheless does quantify who the various winners and losers from the BTA would be, which it frams as follows:



Here is Credit Suisse" answer:


Potential Winners


  • Companies with a majority of their input costs contained within the U.S.
    • Potentially lower tax rate of 20% on sales and full deduction for input costs, potential examples: Health Care Service Providers, U.S. Cable/Telecom, Oil Refiners that source from the U.S., U.S. based manufacturer.


  • U.S. Exporters: as export revenues are not subject to U.S. tax.

Potential Losers


  • Products, services, and intangibles imported into the U.S. will be subject to the border adjustment.

  • Bottom up exercise to determine global supply chain (Automakers, Oil and Gas, to Retailers can be impacted).

  • U.S. Multinationals that have relied on aggressive tax planning to shift earning overseas.

  • Financial Statement effects: Unknown at this point but could result in a higher effective tax rate or COGS, lowering net income in particular for US companies that are net importers.

CS then looks at which specific companies could find border adjustments a potential positive, among which:


3M (MMM) Analyst Meeting – 2017 Outlook: There"s three points on the border adjustment portion.


  • One is, yes, we are a net exporter, so that clearly plays to our favor …

  • Second is commodities …There is not a materially amount of commodities that we are bringing over the border into the U.S. Much of how we manufacture is about often wanting to have our commodity source locally.

  • Third point is our own strategy around intellectual property. 3M"s intellectual property is owned in the United States, and then under the current discussions around border adjustment that also would be a benefit for 3M. But as you started out saying, it"s early.

General Electric (GE) Investor Meeting – December, 2017: We"re a big exporter and not a big importer.


  • Tax reform…based on everything that the new Secretary of Treasury said, the President-elect has said, leader – Speaker Ryan has said, I can never dictate the puts and takes, but I think there is – if you"re a net exporter, manufacturer, stuff like that, I think there"s opportunities…It is a huge incentive and it is a – it"s accretive to the company.

And then, a potential negative:


  • Michael Kors (KORS) 10K: In fiscal 2016, by dollar volume, approximately 97.2% of our products were produced in Asia and Europe….We primarily use foreign manufacturing contractors and independent third-party agents to source our finished goods.

  • Nike (NKE) 10K: Virtually all of our footwear is manufactured outside of the United States by independent contract manufacturers who often operate multiple factories. In fiscal 2016, contract factories in Vietnam, China and Indonesia manufactured approximately 44%, 29% and 21% of total NIKE Brand footwear, respectively.

  • Target (TGT) 10K: In addition, a large portion of our merchandise is sourced, directly or indirectly, from outside the United States, with China as our single largest source.

  • Emerson (EMR): We manage businesses with manufacturing facilities worldwide, a majority of which are located outside the United States, and also source certain materials internationally.

The bank next points out that companies already “manufacturing” (at least partially) in the U.S. could be in a better position under tax reforms:



A factor here would be the domestic manufacturing deduction (DMD):


  • Although subject to complex rules, the DMD provides a tax break for certain U.S. based manufacturing and production activities.

  • Those activities can range from basic manufacturing to the production of software and can include products that are partially “manufactured” outside the U.S..

  • Note that this benefit could go away under new U.S. tax reforms. Nevertheless it provides an indicator that companies have some U.S. based manufacturing and could be in a better position to avoid border  adjustments.

On the other hand, companies with high levels of foreign earnings and very low foreign tax rates, are at increased risk:



Profit shifting


  • Having international exposure is not a risk under pending reforms and could actually be a benefit (no U.S. tax on exports, territorial system).

  • However, the location (i.e. low tax country) of multinational profits will be under continued pressure by the OECD, EU, and U.S. tax Reforms.

  • Companies with high levels of foreign based earnings relative to foreign sales and unusually low foreign tax rates could be at risk to global tax reforms (U.S. Border Adjustments, EU, OECD,).

Finally, here is a practical example of how BTA might work in real life: