Do You Know what Territorial Taxation Is?

The United Kingdom’s Move

to Territorial Taxation

from the National Center  for Policy Analysis

Until recently, the United Kingdom had a similar taxation system to the United States. At one point, both countries had a “worldwide” tax system in which companies were taxed at home for any earnings that were made in foreign countries, says the Tax Foundation.

However, the United Kingdom has pivoted to what is known as a “territorial” tax system, in which earnings made overseas are not taxed domestically. This move has been lauded by an overwhelming number of companies and a majority of countries in the Organization for Economic Cooperation and Development, which have already adopted the territorial tax system.

There are many reasons that the United Kingdom ultimately decided to make this switch:

• First, it allows the country to remain a competitive place to set up businesses.
• Second, there are steep compliance costs associated with the worldwide tax system.
• Moreover, it was very simple for companies to avoid payment of taxes.

The United Kingdom’s tax system is now a model for how the United States should change its tax system. There are several features of the United Kingdom’s tax code that make it competitive.

• There are exemptions for various foreign-source dividends.
• Furthermore, it allows domestic tax deductions for foreign-source expenses.
• Additionally, there are strengthened anti-avoidance measures such as limits on the deductibility of interest payments, enforcement of tax on controlled foreign affiliates based in low-tax jurisdictions, and regulations that qualify diverted intellectual property as taxable.

The success of the United Kingdom’s transition should allay any fears that U.S. policymakers have about shifting to a territorial tax system. For instance, unemployment has leveled off and is not affected by the recent policy change in the United Kingdom. Furthermore, tax revenues as a share of the gross domestic product have also increased despite the tax rate cut.

Source: “The United Kingdom’s Move to Territorial Taxation,” Tax Foundation, November 13, 2012.

Canada’s Experience with Territorial Taxation

from the National Center for Policy Analysis:

Recently, there have been several debates over the merits of a territorial tax system. In essence, such a tax system allows a company to be exempt from any domestic taxes for earnings made in another country. The United States currently adheres to a “worldwide” tax system in which earnings that are made abroad are still subject to the U.S. tax code. Canada provides a model for the United States to look at, as it has essentially pivoted to a territorial tax system to much success, says the Tax Foundation.

Canada’s tax system is sometimes referred to as a “hybrid system” because it does not adhere fully to a territorial tax system. Instead, Canada creates treaties with other countries and any Canadian company that makes income in one of those countries is exempt from paying domestic taxes. But since Canada has expanded this treaty network to include 91 countries and all major trading partners, it is considered a territorial tax system. Theoretically, however, Canada can still tax income earned in non-treaty countries.

To keep its tax base from eroding, Canada treats all passive income as Foreign Accrued Property Income (FAPI). This classifies interest, royalties, rent and other passive investment income and income from unincorporated branches as taxable. This prevents companies from shifting to low-tax jurisdictions.

Canada continues to make its tax system highly competitive.

• Canada’s corporate tax rate has been lowered from 42.9 percent to 26.1 percent.
• In 2007, the dividend exemption was applied to affiliates in countries with a bilateral Tax Information Exchange Agreement.
• Furthermore, Canada has facilitated foreign investment by Canadian companies.

As a result of these competitive tax changes, Canada has experienced stronger economic performance.

• Canada’s economy has grown at an average real rate of 2.61 percent since 1995.
• This is 0.02 points stronger than the U.S. average.
• Moreover, more jobs have been added to the Canadian economy.
• Finally, Canada is still able to yield consistently large tax revenues that have out-collected the United States.

Source: “Canada’s Experience with Territorial Taxation,” Tax Foundation, November 12, 2012.

Obama’s Obamacare….the One needed to become Law before One could Discover its Benefits

And to this date, no one has been able to discover its benefits beyond the words of Obamanoise.

What is its future?

OBAMACARE WILL CREATE TWO AMERICAS

FOR HEALTHCARE

by KEN KLUKOWSKI 

If Obamacare survives the 2016 election after it is fully implemented, there will be two healthcare systems in America from which our citizens will choose.As former Ohio Treasurer Ken Blackwell and I explained months ago, the fifty states can freely choose whether to participate in two central pillars of Obamacare. Conservative governors will be glad in the end, if they hold true to their principles to reject this big-government takeover of healthcare.First, Obamacare expands taxpayer-funded healthcare under Medicaid. The one part of Obamacare that the Supreme Court struck down was the provision allowing the federal government to withdraw all Medicaid funds from states that decline to go along with the expansion. As a result, states can either stay with Medicaid as it currently is, for citizens up to 100% of the poverty line, or they can join Medicaid 2.0, which goes up to 133% of the poverty line, with billions of extra federal dollars to pay for much of the expansion, but leaving states to pay collectively $50 billion more per decade.Second, Obamacare requires insurance exchanges where people can buy coverage, but the Constitution forbids the federal government from commanding the states to pass legislation or run a federal program. States must choose to do so.

If states set up the exchanges, then people between 134% of the poverty line and 400% of the poverty line can get taxpayers to subsidize their insurance—with massive subsidies at 134% of poverty and trailing off as income increases—and dropping to zero at 400%.

But the way the statute is written, those tax subsidies only flow through exchanges set up by a state. If a state refuses, then the U.S. Department of Health and Human Services (HHS) will set up the exchange, but there will be no subsidies. This issue is currently in court, where the states are very likely to prevail because of the plain wording in the statute and the clear legislative history that Democrats in Congress deliberately chose, in order to push states in the direction of choosing to create exchanges on their own.  

States would irrevocably surrender critical aspects of their sovereignty if they agree to either of these new programs. Once you’re in, a state’s programs must not only conform to the words of the Obamacare statute—the 2,700-page Affordable Care Act—but must also comply with all regulations issued by HHS. New regulations are coming out all the time (such as the now-infamous HHS contraception mandate), so the federal government has a blank check to profoundly change the system anytime it chooses.

Among other things, healthcare providers will become subject to vast new regulatory regimes in those states. Doctors and providers in those states will be far more limited in how they can practice medicine, especially if they want to be reimbursed for their services.

As a consequence, you’ll see two mass migrations after Obamacare’s major provisions go into effect in 2014.

First, states that adopt these massively-expanded entitlements will become magnets for low-income people. Many will choose to move to states where they can get “free” healthcare—meaning healthcare paid for by other people.

Second, doctors and healthcare providers will flock to states that resist these big-government programs, since doctors will be free there to practice medicine as they know best, without bureaucratic controls. So “Obamacare states” will see a growing shortage of doctors, while free-market states will see an increasing abundance of doctors. This trend will only accelerate if these states also enact medical tort reform and other pro-doctor laws.

Consequently, successful professionals—and especially those with young families—will increasingly gravitate to the free-market states. Just as parents look at the quality of local schools when deciding what township to live in, so too parents will look to the statewide healthcare system of a potential employer when deciding where to live and raise their family.

This should lead to increased economic and population growth in free-market states. That in turn should result in increased tax revenue to those states’ coffers, even as Obamacare states see increasing drains on the public fisc with fewer people contributing to the tax base.

After the 2020 census, this reality will be seen in congressional reapportionment and redistricting, as well, resulting in an increasingly-unbalanced national complexion on healthcare. But aside from that, and long before 2020, we could likely see a growing disparity in economic prosperity and availability of quality healthcare between these two types of states.

Thus the brilliance of the Framers of our Constitution becomes manifest. The states truly are the laboratories of democracy, as Justice Louis Brandeis described them. People will vote with their feet, and this will serve to accentuate which economic and healthcare approaches best serve the American people.

And that’s how our nation’s founders would have wanted it.  

Ken Klukowski is a legal contributor to Breitbart News and represented Members of Congress in the Obamacare litigation.  

Article sent by Mark Waldeland, survivor of Obamacare’s Obama’s re-election.

Obama’s Muslims on the Attack in Denmark fighting Christmas trees

Journalists attacked for reporting

on Christmas tree controversy

AF The Copenhagen Post<“cB”>

A private donor may have stepped in to pay for the axed Christmas tree, but the controversy will continue as the board are now being accused of racism The on-going controversy over theChristmas tree and the housing association in Kokkedal,…

A private donor may have stepped in to pay for the axed Christmas tree, but the controversy will continue as the board are now being accused of racism

The on-going controversy over theChristmas tree and the housing association in Kokkedal, a town north of Copenhagen, took another turn this weekend, when two journalists from TV2 News escaped unharmed after their van was attacked by 25 masked individuals.

The journalists had gone to the Egedalsvænget housing complex to report on a petition that was gathering signatures of those who had lost confidence in the housing association’s board.

The board had voted against paying 8,000 kroner for the annual Christmas tree and party, but had earlier in the year approved the payment of 60,000 kroner for a party celebrating the Muslim holiday of Eid. Five out of nine of the board members are Muslims.

After the men arrived and exited the van, the attackers promptly began throwing bricks and cobblestones at it. The attackers shouted slurs at the journalists, such as “Neo-Nazi”, and told them to leave.

Following the attack that damaged the windows, doors and the dashboard of the van, the head of TV2 News condemned the treatment of his journalists.

“It’s completely outrageous that things like this happen, but I’m glad it was only our hardware that was attacked and that our personnel were unharmed,” Jacob Nybroe told Jyllands-Posten newspaper. “But it’s disappointing that we can’t cover the news everywhere in Denmark.”

The North Zealand Police has said it is now investigating the incident.

The story of the axed Christmas tree was taken up by the Danish media with gusto after several politicians and commentators suggested it demonstrated an intolerance towards Danish customs held by the minority Muslim population.

But not everyone on the board can agree on why the proposal to have a Christmas tree was rejected.

“No-one wanted to take on the responsibility of getting it,” one board member, Ismail Mestasi, told the press. “A vote was taken and it ended as it ended. I don’t celebrate Christmas, but I was asked to get the tree. And I didn’t want to.”

But the board’s chair, Karin Leegaard Hansen, denied this and has said she offered to take on the responsibility, but that her offer was not noted down in the minutes of the meeting.

The decision of one housing association threatens to turn into a nationwide conflict between Muslims and ethnically Danish Christians. The Islamic association, Islamisk Trossamfund, told Ekstra Bladet that it has received some threatening phone calls since the issue was first covered.

“We have received direct threats, verbal abuse and other forms of taunting as though it was us who were responsible for this case,” spokesperson Imran Shah said, before adding that Muslims are not allowed to deny other groups their right to celebrate their holidays.

“If there is even one non-Muslim in the housing association who wants to hold Christmas, they have to take account of that,” Shah said.

Steffen Morild, the chairman of 3B, the company responsible for the housing complex, said that the housing association’s vote might not be legitimate, as the proper procedures weren’t followed. He added that a meeting was planned for this week where the case would be fully examined, and where the proper procedure for voting on issues like this would be explained.

The issue is likely to remain a hot topic, despite the fact that a private donor has offered to pay an equal amount for both a Christmas tree and next year’s Eid party.

The police announced that they were now investigating an accusation of racism made against the board regarding its decision.

“It needs to be determined to what extent the decision by the Muslim members of the board to first vote ‘yes’ to a 60,000 kroner Eid party, then ‘no’ to a 8,000 kroner Christmas tree to celebrate Christian traditions, violates laws by discriminating against Christians and their traditions,” police spokesperson Karsten Egtved wrote in his report.

Related articles: 

Cancelled Christmas party revived by private donors

Concerns of ethnic bullying after housing board axes Christmas tree

Have a Happy Holiday, fellow Americans.    Be certain to avoid any use of the words, Merry Christman.

We live in Obamatime.

 

Annoncer fra Google

Petraeus Scandal another Obama Grease Job?

Silencing General Petraeus

by Andrew Napolitano:

The evidence that Gen. David Petraeus, formerly the commander of U.S. troops in Afghanistan, the author of the current Army field manual, Princeton Ph.D. and, until last week, the director of the Central Intelligence Agency, was forced to resign from the CIA to silence him is far stronger than is the version of events that the Obama administration has given us.

The government would have us believe that because the FBI confronted Petraeus with his emails showing a pattern of inappropriate personal private behavior, he voluntarily departed his job as the country’s chief spy to avoid embarrassment. The government would also have us believe that the existence of the general’s relationship with Paula Broadwell, an unknown military scholar who wrote a book about him last year, was recently and inadvertently discovered by the FBI while it was conducting an investigation into an alleged threat made by Broadwell to another woman. And the government would as well have us believe that the president learned of all this at 5 p.m. on Election Day.

We now know that the existence of a personal relationship between Broadwell and Petraeus had been suspected and whispered about by his senior-level colleagues and by his personal staff in the military, who worried that it might become publicly known, since before the time that he came to run the CIA.

We also know that when he was nominated to run the CIA, that nomination was preceded by a two-month FBI-conducted background check that likely would have revealed the existence of his relationship with Broadwell. The FBI agents conducting that background check surely would have seen his visitor logs while he commanded our troops and would have interviewed his military colleagues and regular visitors and those colleagues who knew him well and worked with him every day, and thus learned about his personal life. That’s their job.

And that information would have been reported immediately to President Obama and to the Senate Intelligence Committee, prior to Petraeus’ formal nomination and prior to his Senate confirmation hearing.

In the modern era, office-holders with forgiving spouses simply do not resign from powerful jobs because of a temporary, non-criminal, consensual adult sexual liaison, as the history of the FDR, Eisenhower, JFK, LBJ, and Clinton presidencies attest. So, why is Petraeus different? Someone wants to silence him.

Petraeus told the Senate and House Intelligence Committees on September 14, 2012, that the mob attack on the U.S. consulate in Benghazi, Libya, three days earlier, was a spontaneous reaction of Libyans angered over a YouTube clip some believed insulted the prophet Muhammad. He even referred to that assault—which resulted in the murders of four Americans, now all thought to have been CIA agents—as a “flash mob.” His scheduled secret testimony this week before the same congressional committees will produce a chastened, diminished Petraeus who will be confronted with a mountain of evidence contradicting his September testimony, perhaps exposing him to charges of perjury or lying to Congress and causing substantial embarrassment to the president.

It’s obvious that someone was out to silence Petraeus. Who could believe the government version of all this? The same government that wants us to believe that FBI agents innocently and accidentally discovered the Petraeus/Broadwell affair a few months ago and confronted Petraeus with his emails a few weeks ago is a cauldron of petty jealousies. From the time of its creation in 1947, the CIA has been a bitter rival of the FBI. The two agencies are both equipped with lethal force, they both often operate outside the law, and they are each seriously potent entities. Their rivalry was tempered by federal laws that until 2001 kept the CIA from operating in the U.S. and the FBI from operating outside the U.S.

In one of his many overreactions to the events of 9/11, however, President George W. Bush changed all that with an ill-conceived executive order that unlawfully unleashed the CIA inside the U.S. and the FBI into foreign countries. Rather than facilitating a cooperative spirit in defense of individual freedom and national security, this reignited their rivalry. FBI agents, for example, publicly exposed CIA agents whom they caught torturing detainees at Gitmo, and Bush was forced to restrain the CIA.

Isn’t it odd that FBI agents would be reading the emails of the CIA director to his mistress and that the director of the FBI, who briefs the president weekly, did not make the president aware of this? The FBI could only lawfully spy on Petraeus by the use of a search warrant, and it could only get a search warrant if its agents persuaded a federal judge that Petraeus himself—not his mistress—was involved in criminal behavior under federal law.

The agents also could have bypassed the federal courts and written their own search warrant under the Patriot Act, but only if they could satisfy themselves (a curious and unconstitutional standard) that the general was involved in terror-related activity. Both preconditions for a search warrant are irrelevant and would be absurd in this case.

All this—the FBI spying on the CIA—constitutes the government attacking itself. Anyone who did this when neither federal criminal law nor national security has been implicated and kept the president in the dark has violated about four federal statutes and should be fired and indicted. The general may be a cad and a bad husband, but he has the same constitutional rights as the rest of us.

No keen observer could believe the government’s Pollyanna version of these events. When did the CIA become a paragon of honesty? When did the FBI become a paragon of transparency? When did the government become a paragon of telling the truth?