Tuesday, August 26, 2014

Invert This.

Corporate "inversions" have been in the news a lot lately. An inversion takes place when a US corporation merges with a foreign corporation and re-incorporates outside the US in a jurisdiction with lower effective tax rates than in the US. The latest inversion making waves is the pending merger of Miami-based Burger King with Canadian donut purveyor Tim Horton's which will have the effect of re-domiciling Burger King to Canada and dropping its effective tax rate by at least 15%.

At 40%*, the United States has the second highest corporate tax rate in the world (UAE is #1 at 55%). it is also one of only two nations that I’m aware of (the other is Eritrea) that applies that rate extra-territorially. In other words, the US government applies that tax rate to all of a company's (or individual's) income no matter where it is earned, not just to that which is earned within the borders of the United States.

The first duty of a company's management is the fiduciary duty to maximize the return to its owners. It has no duty, patriotic or otherwise to pay more taxes than it is required to. The case law says so. In an opinion written by Second Circuit judge Learned Hand in the case Helvering v. Gregory in 1934 he wrote:

"Any one may so arrange his affairs that his taxes be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes."

If the US government wants to stop the wave of inversions that has been taking place it needs to make the US tax system more competitive with the rest of the world. Lowering the corporate tax rate would be a good start. Ending universal taxation as well would be even better. Trying to prevent companies from leaving will be futile.
 
*The corporate income tax rate is approximately 40%. The marginal federal corporate income tax rate on the highest income bracket of corporations (currently above USD 18,333,333) is 35%. State and local governments may also impose income taxes ranging from 0% to 12%, the top marginal rates averaging approximately 7.5%. A corporation may deduct its state and local income tax expense when computing its federal taxable income, generally resulting in a net effective rate of approximately 40%. The effective rate may vary significantly depending on the locality in which a corporation conducts business. The United States also has a parallel alternative minimum tax (AMT) system, which is generally characterized by a lower tax rate (20%) but a broader tax base.




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Friday, July 04, 2014

Reason Magazine: A Slippery Slope In the Right Direction?

Reason has an excellent article up about not only why the Hobby Lobby ruling was correct, but also why it didn’t go far enough. This part perfectly encapsulates the Libertarian argument:

A group of politicians cannot legitimately have the power to compel one group of people—employers, taxpayers, or insurers—to pay for things that another group wants. That's immoral, and it violates inalienable rights. Moreover, when government has the power to issue such commands—always backed by force, let us never forget—it sets off a mad interest-group scramble for control of the government machinery—because control is a license to steal. Is it any wonder that people are willing to spend billions of dollars to influence who makes government policy? If people face the alternative of controlling the government or being controlled by it, those who have resources will buy power and influence, even if only in self-defense.

Supporters of the Affordable Care Act (ACA) say the court decision permits the favored employers to make health-care decisions for women. No it doesn't. It only prohibits women, unfortunately in only a narrow set of cases, from being able to use government to force their employers to pay for those decisions. When did we start equating the right to buy contraceptives—which hardly anyone disputes—with the power to compel others to pay? It is demagogic to insist that prohibiting the latter violates the former.

Read the whole thing.

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Monday, June 02, 2014

Turmoil In Thailand–Corruption As Catalyst

In February I put up a post about what was happening in Thailand from my perspective back at the beginning of February. I left it off with a sort of “here’s how we are, now how did things get here? To be continued” ending. Well, I’ve found someone who can lay it out far better than I could hope to. So, here is what you need to know about the history of the Thaksin regime: The Thaksin regime in perspective. A sample:
Thaksin was a divisive figure. To his opponents, he was a devil who greedily exploited his office and the trust of the people for personal gain, abused human rights mercilessly, and was rapidly becoming a dictator. To his admirers, he was an angel, a champion of the poor laid low by the forces of darkness and backwardness from which he had been trying to save his country. A more balanced perspective is needed.
Thaksin was a Thai variant of a type recognisable in the history of other countries – the tycoon capitalist emerging during the transformation of a pre-industrial world of small business into today’s world of large corporations and conglomerates. He took the obsessive, aggressive and ruthless attitudes of the business tycoon into politics. His outlook differed from that of the old robber barons principally in that it found expression through his ideas of “new management.” This ideology was centralist and authoritarian, and fundamentally incompatible with democratic governance. Hence the damage Thaksin did to the limits on executive power created by the 1997 reforms, and hence his aggressive attitude towards people who did not fit his vision. It was this attitude, which more than anything else, underpinned his mishandling of the crisis in the deep south.
Thaksin learned how to push the buttons of the Thai people, how to manipulate popular sentiment by telling people what they wanted to hear and making them believe it. All he needed for the stamp of legitimacy, or so he thought, was to win an election. He “won” his first election with only about 40% of the vote and bought off some of the lesser parties to form a government. He has never been able to honestly command a true majority of the Thai People.
Read the whole thing.
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Sunday, May 18, 2014

You Aren't Going Crazy. You Are Being Gas-Lighted

Bill Whittle explains in his latest Firewall video.




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Tuesday, April 15, 2014

Disarming the Warriors - Bill Whittle

Another great Afterburner video from a very pissed-off ( and rightfully so) Bill Whittle. Watch.

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Thursday, March 20, 2014

Thai Turmoil: Some Observations and Thoughts from Michael Yon

Michael Yon has been on the ground and talking to the protesters, including the leadership, and doing research since December. He’s been posting brief thoughts and updates to Facebook all along. He has just completed his first of what will probably be 10 major dispatches at his website.  It’s worth the time to read the whole thing. Nobody else from the Western media (if they’re even paying attention still) is doing this.

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Sunday, February 09, 2014

Turmoil in Thailand–My View of the Situation.

I have been following the political crisis in Thailand very closely. My interest in the situation is due to the fact that I am married to a Thai and have both family and friends in the country. They are on both sides of the issue, some support the government, others the protesters. I can speak a little of the language. Let's call my fluency level; enough to make the in-laws careful about what they say around me because they aren't entirely sure what I do or don't understand, and I tend to surprise them once in a while.

I have been alarmed (but not really surprised) to see the Western press and punditocracy trotting out the very simple and simplistic narrative that what is happening is that a bunch of anti-government mobs (a very loaded word) are trying to overthrow a democratically elected government and that it's the Bangkok "elites" versus the rural poor. It's an easy narrative and also a very lazy one. Reality is, as usual, a lot more complicated than that. Very few of the people, if any, in the Western media opining on the situation are actually on the ground in Thailand and talking to the parties and that being the case they are getting the story entirely wrong.

One person who is on the ground and talking to the protesters and their leadership is writer and war correspondent Michael Yon. He is posting throughout the day at his Facebook page and if you want to know what is really happening, in near real-time, that is the place to go.

The main body of the protesters are represented by the People's Democratic Reform Council or PDRC. The Western press has been portraying the protesters as "violent mobs," most likely because they are being fed that line by the government and are too lazy to question that narrative. In reality the protest sites have more of the atmosphere of a series of block parties, complete with food stalls, live music and speeches, than a bunch of unruly mobs. These are the kind of people the Thai government claims are terrorists. Quite a bit different than the press accounts would lead us to believe, no?

There has been some violence. So far 9 protesters have died and a little more than another 600 have been wounded, 3 just this evening in an M79 grendade atttack ( as I write this on my Satrurday morning, 14 hours behind the events) at the Chaeng Watthana protest venue. All of these attacks have been by "Red Shirts" who are on the side of the government, or "Black Shirts," also on the side of the government (and widely thought to be former Prime Minister Thaksin Shinawatara's private enforcers), on the protesters who are armed with nothing more than whistles. So violence all goes almost all one way. The Red/Black Shirts have been employing hit-and-run tactics, firing guns and grenades into crowds of unarmed people, exactly like tonight's grenade attack. PDRC is allied with another group, Kor Por Tor or KPT (People and Student Network for the Reform of Thailand) who have been serving as guards at the protest sites. They will fight, but only if provoked, and they have taken casualties. The PDRC protesters have done nothing violent to bring violence upon themselves.

One Red Shirt leader, quoted in this Daily Telegraph article, is Ko Tee:
"If anyone doubted the abyss into which Thailand could be heading, Ko Tee - who has been accused of orchestrating grenade attacks on anti-government marches in the Thai capital - is the living proof.
"I want there to be lots of violence to put an end to all this," he said. "I'm bored by speeches. It's time to clean the country, to get rid of the elite, all of them."

To me Ko Tee sounds like he wants to be the second coming of Pol Pot (and I wouldn't be surprised to learn that he has more than one Che Guevara T-shirt in his drawer). He is a very dangerous man.
So, how did things come to this pass in Thailand? In a word, corruption. There will have to be a part two to this post but I wanted to paint the scene as I see it now.
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In the Interests of Public Safety, Ban Everything!

 Do it for The Children TM

Truly weapons-grade satire here.

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Saturday, February 01, 2014

Bill Whittle - Boiling Frogs

I have been so busy with other things I didn't realize I haven't posted anything in nearly two months. I'll try to do better. Here's a new Bill Whittle Afterburner video to start with.


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Thursday, December 05, 2013

Shards. Bill Whittle Returns to the Long-Form Essay

Before Bill Whittle started producing the Afterburner and Firewall videos he wrote a number of long-form essays that were eventually published as a book, “Silent America.” You can still find those essays at his old website, Eject! Eject! Eject!. They are all well worth your time to read but today Bill just posted a new essay, “Shards,” that is as good as any of the essays that precede it. A sample: 

There’s not a person reading these words who, raised with an understanding that Freedom is not the default state of man but rather a force field against tyranny that must be maintained every day through effort and hard work – there’s not one among you that does not look out into the free land that was handed to us by our ancestors with dismay, and the same sense of unfocused dread that a thousand generations felt as the sun dipped ever lower, day by day – because this time, perhaps, it will not climb again.

The history of mankind has been to rule and to be ruled. For reasons that you and I will never understand, there exists in some people an insatiable desire to tell other people what to do; to bend others to their will. I suspect that every single one of those hearts is filled with a dread, a genuine horror, at the wasteland of their own emptiness, and so the bombast and the narcissism and the arrogance; the legions of fainting faithful and the roar of the applause; the reflections, the logos, the insertion of themselves into every event in history; the mind-numbing obsession with power – all of these, I think, are just shovels full of coal being pitched into the bottomless furnace of their own self-hatred.

Read the whole thing.

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Sunday, November 24, 2013

When Politics Collides With Reality…..

….The results are rarely pretty.

They have a saying in the world of Engineering; Sure you can have it better, faster, cheaper. Pick any two.

This was the undoing of Obamacare, why it blew up on the launch pad so to speak. Politicians (the Democrat variety, that is) tried to will into existence a whole new way of delivering heath care without having any understanding of the complexity of what they were asking for. Clay Shirky has a great article about this phenomenon over at his blog. It’s a read-the-whole-thing kind of post but this part is worth highlighting:

If I had to design a litmus test for whether our political class grasps the internet, I would look for just one signal: Can anyone with authority over a new project articulate the tradeoff between features, quality, and time?

When a project cannot meet all three goals—a situation Healthcare.gov was clearly in by March—something will give. If you want certain features at a certain level of quality, you’d better be able to move the deadline. If you want overall quality by a certain deadline, you’d better be able to simplify, delay, or drop features. And if you have a fixed feature list and deadline, quality will suffer.

Intoning “Failure is not an option” will be at best useless, and at worst harmful. There is no “Suddenly Go Faster” button, no way you can throw in money or additional developers as a late-stage accelerant; money is not directly tradable for either quality or speed, and adding more programmers to a late project makes it later. You can slip deadlines, reduce features, or, as a last resort, just launch and see what breaks.

Denying this tradeoff doesn’t prevent it from happening. If no one with authority over the project understands that, the tradeoff is likely to mean sacrificing quality by default. That just happened to this administration’s signature policy goal. It will happen again, as long politicians can be allowed to imagine that if you just plan hard enough, you can ignore reality. It will happen again, as long as department heads imagine that complex technology can be procured like pencils. It will happen again as long as management regards listening to the people who understand the technology as a distasteful act.

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Saturday, November 09, 2013

Thanksgiving Is Almost Here and That Means It’s Chestnut Soup Time

I have made this soup recipe every Thanksgiving (and usually Christmas too) for as long as I can remember. It is really, really good.

If you don’t want to go through the work of roasting and shelling chestnuts (an it can be pretty tedious) Williams-Sonoma (for one place) sells them in jars pre-peeled. I just bought two today for $15 each on sale.

Did I mention how good this soup is?

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Sunday, November 03, 2013

And the Winner Is (and always will be): Arithmetic

Charlie Martin over at PJ Media has a great post on Obamacare vs. Arithmetic that explains why the promises of Obamacare can’t be kept and never could have been. You should go and read the whole thing of course but this part on Gammon’s Theory of Bureaucratic Displacement is worth excerpting:

What does change the relationship is that we start to run into something Milton Friedman called “Gammon’s Law,” which originated with a study of Britain’s National Health Service done by Dr. Max Gammon. Friedman called it the Theory of Bureaucratic Displacement:

In a bureaucratic system, increases in expenditure are paralleled by a corresponding decrease in production.

Translated from the economist-ese, that means in a bureaucratic system, the more you spend on something, the less you get of it.

Gammon’s original work in which he identified this found the correlation was very nearly perfect: as the number of pounds spent on the National Health System increased, the number of hospital beds declined. The correlation was    -0.99.

Aside: for those of you who don’t eat and breathe statistics. Imagine you have a loaf of sliced bread. You weigh the bread, then take out a slice, then weigh it again; keep taking out slices of bread and re-weighing.

The correlation between the number of slices taken out, and the weight of the remaining bread, will be around -0.99.

Why does this happen? There are at least a couple of reasons. As more money goes into the bureaucracy, there’s more pressure to make sure it’s being spent well, which means more forms, more auditors, more independent review boards. All of that takes time and money, and that time and money are being taken away from what used to be the goal.

The second reason is that as administration develops, it becomes its own constituency. Administrators are more important that the people doing the work — they must be, right? I mean, they’re the managers. Administrators get paid more, and in a bureaucracy, administration is the route to higher pay, better offices, and more perks. What’s more, the people doing the work have to do more work to support the administrators. Doctors are seeing that now — new record-keeping requirements, from HIPAA to electronic record systems.

The upshot, though, is that once a system becomes bureaucratic, adding money makes it worse.

And that’s the arithmetic of Obamacare. You start off with something that makes some sense — it’s perfectly reasonable to want insurance against the chance you’ll be hurt in a car accident or develop cancer. Then, because of weird tax incentives, you start doing something that makes less sense: asking insurance companies to pay for things instead of giving you the money to pay for them yourself. Then we start mandating coverage too — so I have to pay for maternity and OB/GYN coverage, even though I’m a 58-year-old single man with no obvious prospect of impending pregnancy.

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Wednesday, October 23, 2013

Maybe This Is Appropriate for a Website That Was DOA

Is it just me or does  lower part of the circular graphic on the left of the Healthcare.gov busy screen below look like a pair of toe tags?

Healthcare-gov-notice-e1382458666117

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Monday, October 21, 2013

Dear Liberal, Here’s Why I’m So Hostile

I just discovered a blog I’ve never run across before; Sufficient Reason. Proprietor Jeremy Choate has an awe-inspiring rant against the “Liberal” creed. A sample:

The fact is, you can rail against my conservatism all you wish.  You can make fun of my Tea Party gatherings, and you can ridicule patriots in tri-corner hats until you wet yourself from mirth, but one thing is for certain: my political philosophy will NEVER be a threat to your freedom.  If you feel a burning responsibility to the poor, conservatism will never prevent you from working 80 hours per week and donating all of your income to charity.  If you feel a strong sense of pity for a family who cannot afford health insurance, my political philosophy will never prevent you from purchasing health insurance for this family or raising money to do so, if you cannot afford it, personally.  If you are moved with compassion for a family who is homeless, a conservative will never use the police power of government to prevent you from taking that family in to your own home or mobilizing your community to build one for them.

However, you cannot say the same for liberalism.  If I choose not to give to the poor for whatever reason, you won’t simply try to persuade me on the merits of the idea — you will seek to use the government as an instrument of plunder to force me to give to the poor.  If we are walking down the street together and we spot a homeless person, using this logic, you would not simply be content with giving him $20 from your own pocket — you would hold a gun to my head and force me to give him $20, as well.

Read it all.

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