zeke5123
2yr ago
There are zillions of cases where there is phantom income. OID is but one. See 951, 951A, 1293, 475.
Then there are the more elective provisions like S Corp’s or partnerships.
zeke5123
2yr ago
Kavanaugh is largely responsible for the major questions doctrine. I also expect BK to be very key in the Chevron decision upcoming (his concurrence in Kisor was different that Roberts in some subtle but important ways).
zeke5123
2yr ago
What’s odd is that the court took this up in the first place. First, tax cases aren’t popular at the court. Second, there was no circuit split. Third, the amount at stake was small.
It seems to me there are five votes to say 965 was wrong (why else would they take this case). But there are maybe a few ways to get there.
First, they could put teeth back into the rule against retroactive law. That is, they could say there can be a deemed distribution but such distribution could not cover earnings in a prior year (ie congress had a chance to tax that earnings but choose not to do so).
Second, they could limit any deemed distribution to taxpayers that control (taxpayers here own less than 50% and therefore don’t control).
Third, they could somehow try to distinguish between individuals and corporations. Doing so is hard in light of Moline Properties.
In short, I expect the Moore’s to win but narrowly in a way that does not upend the entire US international tax system.
zeke5123
2yr ago
Been married for 8 years. Still have regular sex! Shouldn’t be something you give up. Honestly it makes the other stuff easier (eg free and intimate entertainment)
zeke5123
2yr ago
That honestly breaks my mind. I didn’t have a bad relationship with parents nor was I particularly rebellious. But by and large I went out and hung out with my friends where and when I wanted to on the weekends when I was 17 and 18. and it would never occur to me that it was my parents’ role to know exactly where I was. I understood the basic limits on me and sure sometimes broke those rules. But provided I didn’t go too crazy (i didnt) I was permitted to act like someone with autonomy.
zeke5123
2yr ago
Well I guess sexual satisfaction less cost to acquire could be greater in situation one v. situation 2 even if situation 2 has greater sexual satisfaction.
It seems like marriage solves the cost to acquire factor though…
zeke5123
2yr ago
I just don’t buy it. We figured out ways. Why not turn off your phone or leave it somewhere etc.
zeke5123
2yr ago
As someone who is somewhat socially conservative it does bother me that the youth seem uninterested in vice. It is one thing to want but push a vice off until it becomes virtue (eg having sex in the right situation isn’t vice but virtue; that is many vices are not inherently immoral but become vices based on context in which the action occurs).
So I would celebrate young people having less sex if it was because they controlled their desires when the context was wrong. But it’s troubling to me they don’t seem to even have desire!
zeke5123
2yr ago
Do they? There is at least in my experience a big divide pre and post kids.
zeke5123
2yr ago
Fed Soc events (and members) were more energetic and competent compared to ACS events.
zeke5123
2yr ago
It’s been awhile but I want to an elite law school and while Fed soc wasn’t busting with larger numbers the members were smart and (dare I say) better than the law school average.
Progs may make fun of Fed soc at school but that doesn’t mean there aren’t competent people within Fed soc.
zeke5123
2yr ago
It seems oddly kids fifty years ago had both more freedom and more specific rules. Modern liberal parents are both deeply involved but have a weird “well they are going to do it anyway attitude” to many things they shouldn’t.
zeke5123
2yr ago
Or radical idea just cut funding to NGOs. Why am I taxed to fund shitty NGOs I hate?
zeke5123
2yr ago
Either chatgpt has been around for much longer or Journo-list (or equivalent) still exists. It is creepy how quickly the same terms get used, even in opinion rags, to describe something.
zeke5123
2yr ago
How else do you measure how successful a company is compared to how much value it is worth?
zeke5123
2yr ago
The only one that really fits the bill is Tesla. And even then, he helped Tesla go from very small to very large.
My question for you is can you find one guy who was an early founder of two 100b+ companies?
Let’s figure out the list (and we can normalize for today’s dollars). Do you think it large or small?
zeke5123
2yr ago
You wildly understate how hard it is to start and build massive companies. Doing it three times in different fields (with two of them being crazy) is insane.
zeke5123
2yr ago
Might be a slight exaggeration but the number of people instrumental in creating two hundred billion dollar companies is pretty small. Three is unheard of. Three in different areas? Totally unprecedented.
You could put Musk up with Alexander, Khan, Ford, John Galt…
zeke5123
2yr ago
It is funny how many people believe themselves smarter than Musk yet he is probably the most accomplished person in human history in pursuits that clearly require a lot of intelligence.
zeke5123
2yr ago
I don’t get this view. What has DeSantis done that makes your trust Trump more? Trump turned most of the country over to Fauci.
zeke5123
2yr ago
Where there is an in your face coup? What if the president calls up the national guard?
The bigger issue is that the investors invested under regime X. The CFC earned money. Then years later Congress decided to have a deemed distribution of the earnings earned back in time. That is, there was a change in law that basically changed how that historic income was taxed. I could see a fifth amendment issue there.
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