The Presidential debate had massive lies in it. I have one article in progress on taxes to show the lie.
We have media who covers "body language" and "facial cues" with sophisticated AI to analyze second by second expression.
If only they would devote themselves to the facts.....wouldn't that be nice.
Then we have the government, where spin is in. We even have some economists spinning their statistical weave of lies to ensnare us in their political agenda web. I've seen it many times with variables set to zero, absurd assumptions, buried way deep in the mathematics so no one (except one bored geek who doesn't surf for porn)....would find them.
We need a culture of objectivity, a culture which respects scientific methods, where manipulating raw data is a sin akin to being a child molester. We need a culture of respect for science, statistics, and objectivity is paramount.
With this FUBAR Congress and these politicians pulling the strings, think we'll get that?
Anyone realize corporations force government statisticians to sign NDAs and repress a host of data which might expose the fact they are offshore outsourcing our jobs?
Since when can a corporation force the government to sign NDAs to even get a hint of data?
We can spy on the people and lock 'em up indefinitely via the patriot act yet somehow corporations are exempt? I thought corporations were people and government should trump private businesses in obtaining data for accurate portrayal of the U.S. economy and especially labor markets.
I see it on this site. The entire purpose of EP is to amplify facts and by that amplification get people to realize they should be outraged. But spin, we do not. Who needs spin when with a little math and graphs one can see the U.S. middle class being sent to the globalization garbage heap on a daily basis?
Come on people, math is your friend, logic is your friend and facts are your friend.
That's the problem, one doesn't "feel" statistics, one learns and understands them.
Folks, drink some coffee, sit down, let your logic brain take over for just two minutes and try to comprehend just one number and one graph, anywhere, not just this site.
That's the entire point as well as the complaints about the survey, it's facts, evidence, logic, numbers...
One cannot "feel" and just say "I believe" therefore it must be so.
They accused the BLS of throwing the Presidential election, so despite the fact I think she's a lobbyist tool. Solis loves outsourcing, foreign guest workers and she's LABOR secretary??? R u kiddin' me???
Back to this, I think she had every right to be emotional with an accusation such as someone stuffing the statistics in order to obtain an employment rate that could win an election.
Honestly, I've been reading BLS statistics for some time now and frankly this happens every month, so that's one hell of a planning schedule to throw off one number by 0.3 percentage points!
That said, we clearly need better metrics and I want objective accurate ones, without "politics".
Case in point is the false assumption the Census cannot ask about immigration status for that will be "sensitive" to survey respondents. Hello, that's a key critical piece of information we need to know about labor markets and I doubt, in 2012, with 80k illegals showing up in a day to get work permits, being interviewed on every local and national news channel, is that question "too sensitive".
If you can have hundreds of thousands line up for work permits you can ask survey respondents if they are on a guest worker Visa, which type, or are they "undocumented".
So, in spite of Solis being perfectly within reason to be insulted that the BLS or Census (who performs the CPS) would throw a Presidential election,
she still is a political crony to me.
We need accurate, objective, direct data methods and points requests from statisticians, economists and frankly us, it's our damn data in reality, we pay for it, so we should have some input in obtaining better statistics, of course the public has to have a clue about them in the first place.
Nice thorough breakdown. People should be disturbed (outside the blog reading public) with massive problems in sampling and other issues. It's pretty funny the way the Secy. of Labor and everyone else in the govt. was all of a sudden offended and so disturbed by the claim that the govt. could actually manipulate numbers. So emotional, so offended. Really? People question stats and reliability and they get emotional? Odd. Almost like they expected questions and people to disbelieve them. Yeah, because the govt. must be believed 100% of the time. Without even getting into recent events, didn't a certain govt. conduct medical experiments on its own citizens without their consent over many years involving all sorts of people and diseases? Or create a second incident in the Gulf of Tonkin to justify military conflict? So forgive the US people for asking questions, I thought that was our duty. We're simply questioning labor and unemployment statistical differences of .3%, I think the howls and protests from govt. officials and political + media puppets seems a bit over-the-top and in the realm of "doth protest too much." Now, when it comes to the real unemployment rate, U-6, and the massive numbers of people not working, working part-time, and historic levels of food stamp usage, come on, this country is down the crapper (both D & R to blame so again, this ain't partisan and won't be fixed by charades practiced every early November). Besides which, experience out here in the field among those looking for work or in jobs says these people are all jacked up and excited over sh*t jobs. The jobs someone could look to to help America prosper, along with helping himself/herself are gone, gone, gone. Selling crap on eBay or passing out election pamphlets doesn't an American feed.
I'm saying submit this post to other sites in the comments, use the share buttons, put on Facebook and so on. You're right about Jack Welsh but most people do not understand how the corporate tax code is rigged to offshore outsource jobs, or how the corporate tax code is rigged generally.
Posting some FTC stuff doesn't help because people need to have this stuff explained in very simple English to understand.
Hell, to write up this overview I had to study some tax code plus review the hearing documents and exhibit. It ain't easy to boil it down.
The empirical case for outsourcing is on the tax returns of the remaining onshore shell companies who continue to designate themselves "domestic", for the IRS. We Know these companies are the provinces of their offhore masters.
The reason for an impassioned plea for a tax holiday putting the money back onshore. The Foreign Tax Credit, the name of the Beast, is not temporary.
Obama and the Democrats lost the battle to repeal the FTC. If there is one reason, and one reason only to re-elect the President, in spite of his flaws and weaknesses, it is his unflinching opposition (expressed in the Presidential Debate) against the Foreign Tax Credit.
If there is only one reason to oppose Romney, it is his denial that there is a problem with the Foreign Tax Credit.
The option to rebuild America industry, must not be an option.
In 2008, we made the historical case for success vs. failure,
for economic systems which could not support industrial activity.
To move money to fixed investments means create the incentives
to move the offshore money back directly to Fixed investment
as we said in "Back to the Future". All fixed personal property (IRC Section 167) are the appropriate targets of all tax incentives. In other words, no 167 property you pay tax, corporate or personal.
Here it is for the record. As an attachment. The I.R.C. Section 4.6.10. My dad and I worked in this stuff, even though he was a Libertarian Republican, he like many patriots despised the FTC. This is the work of the Chamber of Commerce and the Jack Welchs of this country. This is the world and substance of the outsourcers who have ruined this country's industrial base. Liberals like Matthews are
far to kind to the predators.
Take a look in the mirror Jack(W), you like conspiracies. Here is your favorite and that of your buddies in the Chamber of Commerce have used to keep your foot on the necks of the American worker and send our jobs offshore.
You say the USDOL Unemployment numbers are a conspiracy? Take a look at your conspiracy to gut GE and the rest of the Industrial Base. The double taxation in the Code Section refers to the ability to get a credit for U.S. Corporate tax for paying taxes to foreign countries, say China. In other words, when you box a factory in Ohio and send it to China, you get a credit on your U.S 1120 for the
tax you pay in China. The Chinese will also give you credit, land, water, labor and innumerable other subsidies that you and the rest of the U.S. corporate Pond Scum will
be delighte to accept.
The purpose of the Foreign Tax Credit (FTC) is to provide relief from double taxation. Double taxation may occur, for example, when the U.S. taxes foreign sourced income. FTC limits the overall tax rate on foreign sourced income to the higher of the taxpayer's foreign or U.S. tax rate. The United States does not impose additional tax on foreign income when the foreign tax rate is higher than
the U.S. rate. Conversely, if the tax rate on the foreign sourced income is lower than the U.S. tax rate, the FTC causes the overall tax on the foreign income to approximate the U.S. rate.
This table summarizes the Code sections that authorize and limit the FTC:
Summary of IRC Sections Authorizing and Limiting the FTC
Code Section Description
901 Allows direct credit for taxes paid to a foreign country by a U.S. taxpayer based on realized net income.
902 Allows deemed paid or indirect credit for foreign taxes based on the proportion of taxes paid by a corporation on its distributed earnings and profits.
903 Allows direct credit for taxes (typically foreign withholding taxes based on gross receipts) and paid "in lieu of" the generally imposed net income tax.
904 Limits the amount of credit available in each year, including carryovers of credit.
905 Provides guidelines on foreign tax adjustments, redeterminations and proof of credits.
906 Allows the foreign tax credit for nonresident alien individuals and foreign corporations engaged in a trade or business in the United States.
907 Contains credit limitation for foreign oil and gas income.
960 Allows an indirect credit for deemed distributions.
There are two types of FTCs.
Direct credits are for taxes withheld or taxes paid on the profits of a foreign branch.
Indirect or deemed paid credits are for taxes paid by foreign corporations with 10 percent U.S. shareholders.
There are two types of FTCs.
Direct credits are for taxes withheld or taxes paid on the profits of a foreign branch.
Indirect or deemed paid credits are for taxes paid by foreign corporations with 10 percent U.S. shareholders.
4.61.10.1.1 (05-01-2006)
1986 Law Changes
The FTC regime changed in 1986. For tax years after 1986, taxpayers must:
Maintain multi-year pools for undistributed earnings and taxes of foreign subsidiaries for purposes of calculating indirect credits
Categorize income into nine or more baskets, each with a separate limitation
The foreign source income categories are:
Passive income
High withholding tax interest
Financial services income
Shipping income
Dividends from each noncontrolled IRC section 902 corporation [See IRM 4.61.10.9.1(5).]
Dividends from a DISC or former DISC
Taxable income attributable to foreign trade income
Certain FSC distributions
All other income (general limitation)
Note:
The taxpayer may have certain types of income segregated into additional baskets such as income from blacklisted countries and income treated as foreign sourced under a tax treaty. [See IRC section 901(j), IRC section 904(g)(10), 246(a)(10), and IRC section 865(h)(1)(B). ]
IRC section 904(d) provides that the FTC limitation of IRC section 904(a)–(c) applies separately to the income in each basket.
If a distribution is from pre-1987 earnings, the old rules apply. Pre-1987 earnings and profits and taxes use a separate calculation for each year. After the 1986 Act, taxpayers main Eligible Taxpayers
The first step in an FTC examination is to assess the taxpayer’s eligibility for the credit. Taxpayers subject to U.S. taxation on foreign sourced income are generally entitled to the FTC.
US. citizens and domestic corporations may generally claim a credit for the eligible foreign taxes they pay or accrue. Foreign taxes paid on the following types of income, that are generally exempt from U.S. taxation in the hand of U.S. citizens, are not eligible for a FTC.
Income from sources within possessions of the United States by certain bona fide residents of the possession [see IRC sections 931, 932, and 933]
All excluded foreign earned income [See IRC section 911(d)(6)]
Foreign corporations and Individuals and corporations residing in a U.S. possession (except Puerto Rico) that are not otherwise citizens and not residents of the United States are generally not subject to tax on non-US source income and so are not entitled to the FTC .
4.61.10.2.1 (05-01-2006)
Resident Aliens
Resident aliens in the United States are subject to U.S. taxation and are, therefore, eligible for the FTC. The following limitations apply:
The general rules applicable to U.S. citizens apply to this category of taxpayers.
Only those foreign taxes on income earned while in the status of a resident are eligible for credit (consult the specific treaty involved).
Aliens residing in U.S. possessions (excluding those in Puerto Rico for the entire year) do not get the benefit of the FTC since they are not generally subject to U.S. taxation on non-U.S. source income.
4.61.10.2.2 (05-01-2006)
Other Taxpayers
Nonresident aliens and foreign corporations are eligible for FTC relating to qualified taxes paid on foreign source income effectively connected with a U.S. trade or business (See IRC section 906). A flat 30 percent tax (or lower treaty rate) applies to investment and other fixed or determinable periodical income whether or not the recipient engages in a trade or business in the United States.
But it's not enough to explain the difference. I always do this from first principles, number crunch directly. After I figure it out I might go check what others are claiming, but I do these always from the data series and methods directly. I'm taking your complaints and will see also what I can dig out in terms of "quality of jobs", which is very hard due to the way the BLS categories the sectors, occupational detail has a lag of 1-4 years from the monthlies.
I'll put up something in the CES in the interim since it's looking like I need to do some linear regression (unsure), hold on, don't want to say something until I'm sure of what I'm looking at.
Apparently a massive surge (unprecedented) in 20-24 year olds getting part-time work. Even if there is no "conspiracy," the fact that it's common knowledge no Pres. can get elected with unemployment at 8%+ only creates the appearance that all stats must be fixed to achieve the goal. And again, this whole debate is kind of ridiculous because people are jumping up and down in front of cameras on both sides ignoring the fact that most any jobs added in 2012 completely suck (e.g., no benefits, part-time, can't cover cost of fuel, housing, food).
Even without addressing statistical issues and random sampling questions and quality of jobs in 2012, Bloomberg's Trish Regan was still going on about how unemployment benefits might cause people to drop out of looking for work. Trish, wake the F up, once those benefits end, people starve or go homeless or both. Most self-employed people never got Day 1 of unemployment, so ask them how they survive. People aren't opting out of food and homes because they're so lazy after up to 99 weeks of "living the good life." Trish Regan, another overpaid puppet that is paid not to think.
Ok, this is going to take me a while for I have to do some fairly deep number crunching this month to explain a host of statistics from the CPS.
Bottom line, the CPS survey to me just doesn't have enough accuracy generally, needs to be expanded and more real time.
This is going to take me some hours though because I have to run some serious statistics and make some custom graphs, pull up some special numbers from databases and so on to explain how the hell one could get only 114,000 payroll jobs yet see outrageously bizarre inceases in the CPS.
So, I'm working on it, for all EP fans out there who are probably wondering where our overview is.
I also called up the BLS and got some pointers on some places to look for the hidden weirdness.
CT stands for conspiracy theory, so I will make a point to look at those writing up CT posts con graphs and "data" to refute (or confirm), but the real problem to me has always been the CPS survey size is way too small and we're missing concurrent other data to correlate as well, need more definitions in our disposable worker society.
The BLS is just a bunch of geeky people, doing their survey, statistical methods, number crunching groove thing. There is kind of a firewall between the geek people vs. the political/administration folk.
I'm writing up overviews now on how that is happening, yes that's absurd. Takes a while to graph up everything to show how that happened, working on it right now.
Seriously, the rate drops to 7.8% with basically no jobs added? Election time shenanigans full speed ahead. "Conspiracy" theories seem to be correct and not so insane after all - anything to secure elections and political offices. When no one's working, seeking work because there are no jobs, not filing initial claims, and can't collect unemployment anymore, we'll have 0% unemployment.
We all know Romney claimed there is no tax break for offshore outsourcing jobs. There indeed is and then some, but because the corporate tax code is so complex, one has to follow the details to understand how the trick works.
This article overviews some of those tricks. Obama is right, Romney is not only wrong, he wants to give tax loopholes to offshore outsourcing jobs an absurd increase in tax breaks by changing the status of territories outside the U.S., known tax havens, to be defacto U.S. lands for tax purposes! Major disaster in terms of trying to keep jobs in America.
Anyway, this post overviews the details on how the corporate tax code rewards offshore outsourcers and if you do not like this overview, the actual hearing exhibit does a good job in boiling down the complex so we all can follow along at home.
Seriously, the press with their "fact check" is burying this fact!
$10,074 per year is $839.5 per month, take home. Food for one by the low balled USDA numbers is between $204-$371 per month for an adult individual and there the USA claims women can eat way less than a male, which should say something about their estimates. Now, we have transportation, health care, clothing, utilities, such as heat, water and these expenses are mandatory to live.
Sorry, even under rent control in NYC, which means someone has been there for over 20 years and are not a large percentage of rentals, is an amazing showing of denial when it comes to the plight of 20% of America.
This site overviews all sorts of statistics and being in denial, writing an opinion simply does not make it so. The reality is the U.S. has terrible income inequality and also very low social mobility. The opportunities to pull one's self "up by their own bootstraps" are simply not there by the statistics and the facts. One statistic, the fact that 53% of those graduating from college cannot get a job should really show this, that's people who actually made it, in spite being saddled with debt, being denied opportunity not just in their field of study, but general work.
Whatever mobility is, 5% to 10% or whatever, that is what people do, not what opportunities there are. Anyone can be a millionaire in the USA by the time they are 40 and it's not fantastic. The world needs lawyers, doctors, engineers, consultants, computer specialists, etc. and all it takes is time (not a lot of money). The public school system and libraries are abundant to provide a sober diligent student the means to gain those skills in life.
But how many coast through until 35 having a fun life and the grouse?
The American Dream is better than ever; ask those poor dirt-caked aspirants who risk limb and life and often lose limb or life to get here from everywhere else. Places where there are no dreams, just dirt-poverty or some kind of corrupt compliance with a fascist system.
Too bad Sherlock Holmes is dead ... and was imaginary. But perhaps another detective will solve this one.
The black market is large and in a scholarly way I hope that explains it because otherwise social scientists are not doing well.
A trailer in rural Oklahoma or Florida? Come on. That's $300-$500 a month, still. [Note there are hundreds of thousands of people paying $500 a month rent in New York City (under rent laws). But I remember looking for a place in upstate NY in the 90s in a thriving medium sized town and I could have gotten something for $300 or $400. So, no. Rent $5000 or less for a year very doable, especially with roomates.
Could be that; technically the unemployed can live off savings and then there is the elderly.
The Presidential debate had massive lies in it. I have one article in progress on taxes to show the lie.
We have media who covers "body language" and "facial cues" with sophisticated AI to analyze second by second expression.
If only they would devote themselves to the facts.....wouldn't that be nice.
Then we have the government, where spin is in. We even have some economists spinning their statistical weave of lies to ensnare us in their political agenda web. I've seen it many times with variables set to zero, absurd assumptions, buried way deep in the mathematics so no one (except one bored geek who doesn't surf for porn)....would find them.
We need a culture of objectivity, a culture which respects scientific methods, where manipulating raw data is a sin akin to being a child molester. We need a culture of respect for science, statistics, and objectivity is paramount.
With this FUBAR Congress and these politicians pulling the strings, think we'll get that?
Anyone realize corporations force government statisticians to sign NDAs and repress a host of data which might expose the fact they are offshore outsourcing our jobs?
Since when can a corporation force the government to sign NDAs to even get a hint of data?
We can spy on the people and lock 'em up indefinitely via the patriot act yet somehow corporations are exempt? I thought corporations were people and government should trump private businesses in obtaining data for accurate portrayal of the U.S. economy and especially labor markets.
I see it on this site. The entire purpose of EP is to amplify facts and by that amplification get people to realize they should be outraged. But spin, we do not. Who needs spin when with a little math and graphs one can see the U.S. middle class being sent to the globalization garbage heap on a daily basis?
Come on people, math is your friend, logic is your friend and facts are your friend.
Respect the number, read it, study it, love it!
That's the problem, one doesn't "feel" statistics, one learns and understands them.
Folks, drink some coffee, sit down, let your logic brain take over for just two minutes and try to comprehend just one number and one graph, anywhere, not just this site.
That's the entire point as well as the complaints about the survey, it's facts, evidence, logic, numbers...
One cannot "feel" and just say "I believe" therefore it must be so.
They accused the BLS of throwing the Presidential election, so despite the fact I think she's a lobbyist tool. Solis loves outsourcing, foreign guest workers and she's LABOR secretary??? R u kiddin' me???
Back to this, I think she had every right to be emotional with an accusation such as someone stuffing the statistics in order to obtain an employment rate that could win an election.
Honestly, I've been reading BLS statistics for some time now and frankly this happens every month, so that's one hell of a planning schedule to throw off one number by 0.3 percentage points!
That said, we clearly need better metrics and I want objective accurate ones, without "politics".
Case in point is the false assumption the Census cannot ask about immigration status for that will be "sensitive" to survey respondents. Hello, that's a key critical piece of information we need to know about labor markets and I doubt, in 2012, with 80k illegals showing up in a day to get work permits, being interviewed on every local and national news channel, is that question "too sensitive".
If you can have hundreds of thousands line up for work permits you can ask survey respondents if they are on a guest worker Visa, which type, or are they "undocumented".
So, in spite of Solis being perfectly within reason to be insulted that the BLS or Census (who performs the CPS) would throw a Presidential election,
she still is a political crony to me.
We need accurate, objective, direct data methods and points requests from statisticians, economists and frankly us, it's our damn data in reality, we pay for it, so we should have some input in obtaining better statistics, of course the public has to have a clue about them in the first place.
Nice thorough breakdown. People should be disturbed (outside the blog reading public) with massive problems in sampling and other issues. It's pretty funny the way the Secy. of Labor and everyone else in the govt. was all of a sudden offended and so disturbed by the claim that the govt. could actually manipulate numbers. So emotional, so offended. Really? People question stats and reliability and they get emotional? Odd. Almost like they expected questions and people to disbelieve them. Yeah, because the govt. must be believed 100% of the time. Without even getting into recent events, didn't a certain govt. conduct medical experiments on its own citizens without their consent over many years involving all sorts of people and diseases? Or create a second incident in the Gulf of Tonkin to justify military conflict? So forgive the US people for asking questions, I thought that was our duty. We're simply questioning labor and unemployment statistical differences of .3%, I think the howls and protests from govt. officials and political + media puppets seems a bit over-the-top and in the realm of "doth protest too much." Now, when it comes to the real unemployment rate, U-6, and the massive numbers of people not working, working part-time, and historic levels of food stamp usage, come on, this country is down the crapper (both D & R to blame so again, this ain't partisan and won't be fixed by charades practiced every early November). Besides which, experience out here in the field among those looking for work or in jobs says these people are all jacked up and excited over sh*t jobs. The jobs someone could look to to help America prosper, along with helping himself/herself are gone, gone, gone. Selling crap on eBay or passing out election pamphlets doesn't an American feed.
I feel that the survey itself was manipulated.
I'm saying submit this post to other sites in the comments, use the share buttons, put on Facebook and so on. You're right about Jack Welsh but most people do not understand how the corporate tax code is rigged to offshore outsource jobs, or how the corporate tax code is rigged generally.
Posting some FTC stuff doesn't help because people need to have this stuff explained in very simple English to understand.
Hell, to write up this overview I had to study some tax code plus review the hearing documents and exhibit. It ain't easy to boil it down.
The empirical case for outsourcing is on the tax returns of the remaining onshore shell companies who continue to designate themselves "domestic", for the IRS. We Know these companies are the provinces of their offhore masters.
http://www.irs.gov/pub/irs-soi/10intertax.pdf
The reason for an impassioned plea for a tax holiday putting the money back onshore. The Foreign Tax Credit, the name of the Beast, is not temporary.
Obama and the Democrats lost the battle to repeal the FTC. If there is one reason, and one reason only to re-elect the President, in spite of his flaws and weaknesses, it is his unflinching opposition (expressed in the Presidential Debate) against the Foreign Tax Credit.
If there is only one reason to oppose Romney, it is his denial that there is a problem with the Foreign Tax Credit.
The option to rebuild America industry, must not be an option.
In 2008, we made the historical case for success vs. failure,
for economic systems which could not support industrial activity.
To move money to fixed investments means create the incentives
to move the offshore money back directly to Fixed investment
as we said in "Back to the Future". All fixed personal property (IRC Section 167) are the appropriate targets of all tax incentives. In other words, no 167 property you pay tax, corporate or personal.
Here it is for the record. As an attachment. The I.R.C. Section 4.6.10. My dad and I worked in this stuff, even though he was a Libertarian Republican, he like many patriots despised the FTC. This is the work of the Chamber of Commerce and the Jack Welchs of this country. This is the world and substance of the outsourcers who have ruined this country's industrial base. Liberals like Matthews are
far to kind to the predators.
Take a look in the mirror Jack(W), you like conspiracies. Here is your favorite and that of your buddies in the Chamber of Commerce have used to keep your foot on the necks of the American worker and send our jobs offshore.
You say the USDOL Unemployment numbers are a conspiracy? Take a look at your conspiracy to gut GE and the rest of the Industrial Base. The double taxation in the Code Section refers to the ability to get a credit for U.S. Corporate tax for paying taxes to foreign countries, say China. In other words, when you box a factory in Ohio and send it to China, you get a credit on your U.S 1120 for the
tax you pay in China. The Chinese will also give you credit, land, water, labor and innumerable other subsidies that you and the rest of the U.S. corporate Pond Scum will
be delighte to accept.
What many refer to a "Free Trade".
"
4.61.10.1 (05-01-2006)
Foreign Tax Credit Audit Guidelines
The purpose of the Foreign Tax Credit (FTC) is to provide relief from double taxation. Double taxation may occur, for example, when the U.S. taxes foreign sourced income. FTC limits the overall tax rate on foreign sourced income to the higher of the taxpayer's foreign or U.S. tax rate. The United States does not impose additional tax on foreign income when the foreign tax rate is higher than
the U.S. rate. Conversely, if the tax rate on the foreign sourced income is lower than the U.S. tax rate, the FTC causes the overall tax on the foreign income to approximate the U.S. rate.
This table summarizes the Code sections that authorize and limit the FTC:
Summary of IRC Sections Authorizing and Limiting the FTC
Code Section Description
901 Allows direct credit for taxes paid to a foreign country by a U.S. taxpayer based on realized net income.
902 Allows deemed paid or indirect credit for foreign taxes based on the proportion of taxes paid by a corporation on its distributed earnings and profits.
903 Allows direct credit for taxes (typically foreign withholding taxes based on gross receipts) and paid "in lieu of" the generally imposed net income tax.
904 Limits the amount of credit available in each year, including carryovers of credit.
905 Provides guidelines on foreign tax adjustments, redeterminations and proof of credits.
906 Allows the foreign tax credit for nonresident alien individuals and foreign corporations engaged in a trade or business in the United States.
907 Contains credit limitation for foreign oil and gas income.
960 Allows an indirect credit for deemed distributions.
There are two types of FTCs.
Direct credits are for taxes withheld or taxes paid on the profits of a foreign branch.
Indirect or deemed paid credits are for taxes paid by foreign corporations with 10 percent U.S. shareholders.
There are two types of FTCs.
Direct credits are for taxes withheld or taxes paid on the profits of a foreign branch.
Indirect or deemed paid credits are for taxes paid by foreign corporations with 10 percent U.S. shareholders.
4.61.10.1.1 (05-01-2006)
1986 Law Changes
The FTC regime changed in 1986. For tax years after 1986, taxpayers must:
Maintain multi-year pools for undistributed earnings and taxes of foreign subsidiaries for purposes of calculating indirect credits
Categorize income into nine or more baskets, each with a separate limitation
The foreign source income categories are:
Passive income
High withholding tax interest
Financial services income
Shipping income
Dividends from each noncontrolled IRC section 902 corporation [See IRM 4.61.10.9.1(5).]
Dividends from a DISC or former DISC
Taxable income attributable to foreign trade income
Certain FSC distributions
All other income (general limitation)
Note:
The taxpayer may have certain types of income segregated into additional baskets such as income from blacklisted countries and income treated as foreign sourced under a tax treaty. [See IRC section 901(j), IRC section 904(g)(10), 246(a)(10), and IRC section 865(h)(1)(B). ]
IRC section 904(d) provides that the FTC limitation of IRC section 904(a)–(c) applies separately to the income in each basket.
If a distribution is from pre-1987 earnings, the old rules apply. Pre-1987 earnings and profits and taxes use a separate calculation for each year. After the 1986 Act, taxpayers main Eligible Taxpayers
The first step in an FTC examination is to assess the taxpayer’s eligibility for the credit. Taxpayers subject to U.S. taxation on foreign sourced income are generally entitled to the FTC.
US. citizens and domestic corporations may generally claim a credit for the eligible foreign taxes they pay or accrue. Foreign taxes paid on the following types of income, that are generally exempt from U.S. taxation in the hand of U.S. citizens, are not eligible for a FTC.
Income from sources within possessions of the United States by certain bona fide residents of the possession [see IRC sections 931, 932, and 933]
All excluded foreign earned income [See IRC section 911(d)(6)]
Foreign corporations and Individuals and corporations residing in a U.S. possession (except Puerto Rico) that are not otherwise citizens and not residents of the United States are generally not subject to tax on non-US source income and so are not entitled to the FTC .
4.61.10.2.1 (05-01-2006)
Resident Aliens
Resident aliens in the United States are subject to U.S. taxation and are, therefore, eligible for the FTC. The following limitations apply:
The general rules applicable to U.S. citizens apply to this category of taxpayers.
Only those foreign taxes on income earned while in the status of a resident are eligible for credit (consult the specific treaty involved).
Aliens residing in U.S. possessions (excluding those in Puerto Rico for the entire year) do not get the benefit of the FTC since they are not generally subject to U.S. taxation on non-U.S. source income.
4.61.10.2.2 (05-01-2006)
Other Taxpayers
Nonresident aliens and foreign corporations are eligible for FTC relating to qualified taxes paid on foreign source income effectively connected with a U.S. trade or business (See IRC section 906). A flat 30 percent tax (or lower treaty rate) applies to investment and other fixed or determinable periodical income whether or not the recipient engages in a trade or business in the United States.
But it's not enough to explain the difference. I always do this from first principles, number crunch directly. After I figure it out I might go check what others are claiming, but I do these always from the data series and methods directly. I'm taking your complaints and will see also what I can dig out in terms of "quality of jobs", which is very hard due to the way the BLS categories the sectors, occupational detail has a lag of 1-4 years from the monthlies.
I'll put up something in the CES in the interim since it's looking like I need to do some linear regression (unsure), hold on, don't want to say something until I'm sure of what I'm looking at.
Apparently a massive surge (unprecedented) in 20-24 year olds getting part-time work. Even if there is no "conspiracy," the fact that it's common knowledge no Pres. can get elected with unemployment at 8%+ only creates the appearance that all stats must be fixed to achieve the goal. And again, this whole debate is kind of ridiculous because people are jumping up and down in front of cameras on both sides ignoring the fact that most any jobs added in 2012 completely suck (e.g., no benefits, part-time, can't cover cost of fuel, housing, food).
Even without addressing statistical issues and random sampling questions and quality of jobs in 2012, Bloomberg's Trish Regan was still going on about how unemployment benefits might cause people to drop out of looking for work. Trish, wake the F up, once those benefits end, people starve or go homeless or both. Most self-employed people never got Day 1 of unemployment, so ask them how they survive. People aren't opting out of food and homes because they're so lazy after up to 99 weeks of "living the good life." Trish Regan, another overpaid puppet that is paid not to think.
Ok, this is going to take me a while for I have to do some fairly deep number crunching this month to explain a host of statistics from the CPS.
Bottom line, the CPS survey to me just doesn't have enough accuracy generally, needs to be expanded and more real time.
This is going to take me some hours though because I have to run some serious statistics and make some custom graphs, pull up some special numbers from databases and so on to explain how the hell one could get only 114,000 payroll jobs yet see outrageously bizarre inceases in the CPS.
So, I'm working on it, for all EP fans out there who are probably wondering where our overview is.
I also called up the BLS and got some pointers on some places to look for the hidden weirdness.
CT stands for conspiracy theory, so I will make a point to look at those writing up CT posts con graphs and "data" to refute (or confirm), but the real problem to me has always been the CPS survey size is way too small and we're missing concurrent other data to correlate as well, need more definitions in our disposable worker society.
The BLS is just a bunch of geeky people, doing their survey, statistical methods, number crunching groove thing. There is kind of a firewall between the geek people vs. the political/administration folk.
I'm writing up overviews now on how that is happening, yes that's absurd. Takes a while to graph up everything to show how that happened, working on it right now.
Seriously, the rate drops to 7.8% with basically no jobs added? Election time shenanigans full speed ahead. "Conspiracy" theories seem to be correct and not so insane after all - anything to secure elections and political offices. When no one's working, seeking work because there are no jobs, not filing initial claims, and can't collect unemployment anymore, we'll have 0% unemployment.
We all know Romney claimed there is no tax break for offshore outsourcing jobs. There indeed is and then some, but because the corporate tax code is so complex, one has to follow the details to understand how the trick works.
This article overviews some of those tricks. Obama is right, Romney is not only wrong, he wants to give tax loopholes to offshore outsourcing jobs an absurd increase in tax breaks by changing the status of territories outside the U.S., known tax havens, to be defacto U.S. lands for tax purposes! Major disaster in terms of trying to keep jobs in America.
Anyway, this post overviews the details on how the corporate tax code rewards offshore outsourcers and if you do not like this overview, the actual hearing exhibit does a good job in boiling down the complex so we all can follow along at home.
Seriously, the press with their "fact check" is burying this fact!
$10,074 per year is $839.5 per month, take home. Food for one by the low balled USDA numbers is between $204-$371 per month for an adult individual and there the USA claims women can eat way less than a male, which should say something about their estimates. Now, we have transportation, health care, clothing, utilities, such as heat, water and these expenses are mandatory to live.
Sorry, even under rent control in NYC, which means someone has been there for over 20 years and are not a large percentage of rentals, is an amazing showing of denial when it comes to the plight of 20% of America.
This site overviews all sorts of statistics and being in denial, writing an opinion simply does not make it so. The reality is the U.S. has terrible income inequality and also very low social mobility. The opportunities to pull one's self "up by their own bootstraps" are simply not there by the statistics and the facts. One statistic, the fact that 53% of those graduating from college cannot get a job should really show this, that's people who actually made it, in spite being saddled with debt, being denied opportunity not just in their field of study, but general work.
That's not fair.
Whatever mobility is, 5% to 10% or whatever, that is what people do, not what opportunities there are. Anyone can be a millionaire in the USA by the time they are 40 and it's not fantastic. The world needs lawyers, doctors, engineers, consultants, computer specialists, etc. and all it takes is time (not a lot of money). The public school system and libraries are abundant to provide a sober diligent student the means to gain those skills in life.
But how many coast through until 35 having a fun life and the grouse?
The American Dream is better than ever; ask those poor dirt-caked aspirants who risk limb and life and often lose limb or life to get here from everywhere else. Places where there are no dreams, just dirt-poverty or some kind of corrupt compliance with a fascist system.
No.
Too bad Sherlock Holmes is dead ... and was imaginary. But perhaps another detective will solve this one.
The black market is large and in a scholarly way I hope that explains it because otherwise social scientists are not doing well.
A trailer in rural Oklahoma or Florida? Come on. That's $300-$500 a month, still. [Note there are hundreds of thousands of people paying $500 a month rent in New York City (under rent laws). But I remember looking for a place in upstate NY in the 90s in a thriving medium sized town and I could have gotten something for $300 or $400. So, no. Rent $5000 or less for a year very doable, especially with roomates.
Could be that; technically the unemployed can live off savings and then there is the elderly.
Combination of the above?
Interesting. Very interesting.
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