Friday, April 12, 2019

Gutting the IRS: Where in The U.S. Are You Most Likely to Be Audited by the IRS?:

The toxic sludge and workplace adjustments are great for us: Caring Privateers During Caretaker Modes - Job no longer required due to changes in operational requirements

Humphreys County, Mississippi, seems like an odd place for the IRS to go hunting for tax cheats. It’s a rural county in the Mississippi Delta known for its catfish farms, and more than a third of its mostly African American residents are below the poverty line. But according to a new study, it is the most heavily audited county in America.

CHAIR: So the time for the government to respond appropriately is a little limited but you would expect government would respond in as timely a manner as possible. I just want to ask some questions about multinational tax avoidance, which we normally would direct to the commissioner because he loves to talk about it. I specifically want to ask about the result that the ATO has seen since the implementation of the multinational anti-avoidance laws and the diverted profits tax.
Ms Curtis : You're quite correct. If he were here, he would definitely like to take that question. Given he's not here, we will give it to Mr Hirschhorn.
CHAIR: Mr Hirschhorn knows almost as much.
Mr Hirschhorn : Perhaps even more, Senator. I will approach this in two parts. The multinational anti-avoidance law is a law that is really directed at business models where people had a selling presence in Australia but billed from overseas. So you thought that you were buying a service and dealing with a salesperson in Australia, but, when you finally got the bill, it came from Ireland or somewhere else. The multinational anti-avoidance law said that, where that was a deliberate structure to avoid having a taxable presence in Australia, it would apply to strike out those schemes. The great news about the multinational anti-avoidance law is that 44 companies have restructured or are in the course of restructuring their operations to move to a model where they actually bill from Australia and recognise a taxable presence in Australia. That has brought about $7 billion of sales per annum onshore—so billed by the Australian company instead of being billed from Ireland, say, or somewhere else—with the consequential increases to tax. Obviously, those companies are allowed reasonable expenses against that $7 billion, but that is leading to significant increases in income tax and also in conjunction with some of the GST measures—some significant
ATO Senate Estimates Hansard

Margaret Ryznar (Indiana-Indianapolis), Tax Reform's Contribution to #Metoo, 161 Tax Notes 1101 (Nov. 26, 2019):

This article considers the 2017 tax reform provision that disallows tax deductions for sexual harassment settlements subject to nondisclosure agreements. It examines the possible effects on sexual harassment in the workplace, as well as remaining questions about the tax provision itself.

Former Wall Street trader Edgar Fernandez used some of his Bitcoin as collateral to borrow nearly $100,000, a move that let him keep his cryptocurrency and avert a tax bill on the newly acquired cash.

The tax perk stems from a longstanding principle that assets aren’t taxed until sold, much like borrowing against stock holdings. Yet digital currency carries far greater risks, from price volatility, to hacks and thefts that can make the collateral disappear, to sometimes shadowy players without long track records in the field.

Since last fall, when the value of digital money plummeted, lenders have been pushing people who have paper profits to leverage them into cash by borrowing against their cryptocurrencies. And the fact that there’s no tax bill on the transactions is a big selling point. The Internal Revenue Service treats crypto money as a capital asset like stocks or property, not as a currency. ...

The Hill op-ed:  Congress' Worst Tax Idea Ever, by Edward Kleinbard (USC):

There’s $400 billion or so lying on the sidewalk of the tax landscape that can fund really useful public spending, if only Congress could be bothered to pick it up. That’s what Congress gave away in 2017 in the form of a tax subsidy for “qualified business income.”

New data from Congress’ own tax watchdog, the Staff of the Joint Committee on Taxation (JCT) [Overview of Deduction for Qualified Business Income: Section 199A], confirms what many of us suspected all along: The subsidy isn’t targeted to small business, or yeomen farmers but rather simply excuses the affluent from taxes imposed on the rest of us.

FAS – Secrecy News: “The number of leaks of classified information reported as potential crimes by federal agencies reached record high levels during the first two years of the Trump Administration, according to data released by the Justice Department last week. Agencies transmitted 120 leak referrals to the Justice Department in 2017, and 88 leak referrals in 2018, for an average of 104 per year. By comparison, the average number of leak referrals during the Obama Administration (20092016) was 39 per year. There are a “staggering number of leaks,” then-Attorney General Jeff Sessions said at an August 4, 2017 briefing about efforts to prevent the unauthorized disclosures. “Referrals for investigations of classified leaks to the Department of Justice from our intelligence agencies have exploded,” AG Sessions said at that time. He outlined several steps that the Administration would take to combat leaks of classified information, including tripling the number of active leak investigations by the FBI. “We had about nine open investigations of classified leaks in the last 3 years,” he told the House Judiciary Committee at a November 2017 hearing. “We have 27 investigations open today.” (Some of those investigations pertain to leaks that occurred before President Trump took office.) “We intend to get to the bottom of these leaks. I think it reached—has reached epidemic proportions. It cannot be allowed to continue,” Sessions said then, “and we will do our best effort to ensure that it does not continue.” But it has continued. Despite preventive efforts, the 2018 total of 88 leak referrals was still higher than any reported pre-Trump figure. (The previous high in recent decades had been 55 referrals in 2013 and in 2007. The lowest was 18 in 2015.)..”