Monthly Archives: August 2004

US Taxation of Multinational Enterprise: Part XIII

Michael Froomkin will be back full-time tomorrow, so this is my last post. I still have a lot of stuff to say on the threads to my posts, however, which I will do over the weekend, so you are not rid of me quite yet.

Thank you all! I learned a lot about stuff and the blogosphere. Thank you Michael! It has been as much work as I expected. I cannot imagine how Michael finds time to blog, maintain this remarkable site (which I had no responsibility for, and which must take up as much time as blogging), and have a life. Amazing….. And Michael just emailed that I should have my own blog….

Well, I have been stalling for weeks on the fundamental issue of international tax policy: As a practical matter, in an open worldwide economy, can one country impose an income tax? There are two sub-issues: First, can a country tax residents (or citizens) on their worldwide income. Here, can the US tax Sue on her foreign surgeries, given that she can move? Second, can one country tax income related to mobile local factors of production? For example, can the US tax the capital of Ford Motor invested in a US factory if Ford can close the factory and move production to low-tax Mexico?

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Posted in Law: Tax | 2 Comments

Why Isn’t This A Public Record?

United Press International: Florida's RNC delegation a secret:

Florida Republicans refused to release the names of the state's delegates to the national convention in New York later this month, citing privacy concerns.

“Some delegates are not comfortable speaking and don't want their information given out, and we've honored their requests. Our priority is putting the interests and welfare of our delegates first,” Florida party spokesman Joseph Agostini told the Miami Herald.

Reporters and editors were provided with contact information weeks in advance for Florida's delegation to the Democratic National Convention in Boston last month, including photos of some of the more high-profile delegates. Most other state Republican delegations are providing contact information as well.

I can't understand why the identity of the delegates — the result of a state-sponsored, public electoral process — is not a public record.

And it certainly makes visible the mockery of the idea that “delegates” are in some way representative of anyone but themselves.

Posted in Politics: US: 2004 Election | 4 Comments

US Taxation of Multinational Enterprise: Part XII

I am sitting here reading the fine print in a contract to buy a house for a price that is three times what I sold my house in Minnesota for. I am not UMC in Miami, I guess. Forgive me if I am even less coherent than normal — and that I haven't had a chance to do more commenting.

Oh, well, back to taxing the nowhere and everywhere profits of multinationals. The world-wide network of tax treaties rests on the arm's-length notion, which, I have argued (and the comments seem to be moving somewhat — somewhat — toward accepting), misses nowhere and everywhere profit. This is real important, as failure to tax nowhere and everywhere profit guts business income taxes as a source of revenue for countries. (Yes, tax jocks, the current US regs, whiile pretending to be arm's-length regs, do capture some nowhere and everywhere income.)

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Posted in Law: Tax | 8 Comments

Freudian Slip?

IS this the ultimate Freudian slip? Bush Insists His Administration Seeking 'new Ways to Harm Our Country':

Bush Insists His Administration Seeking 'new Ways to Harm Our Country'
The Associated Press
Published: Aug 5, 2004

WASHINGTON (AP) – President Bush offered up a new entry for his catalog of “Bushisms” on Thursday, declaring that his administration will “never stop thinking about new ways to harm our country and our people.”

Bush misspoke as he delivered a speech at the signing ceremony for a $417 billion defense spending bill.

“Our enemies are innovative and resourceful, and so are we,” Bush said. “They never stop thinking about new ways to harm our country and our people, and neither do we.”

No one in Bush's audience of military brass or Pentagon chiefs reacted

Posted in Politics: US: 2004 Election | 6 Comments

Eric Muller Is Demolishing the ‘Defense of Internment’

Eric Muller is guest blogging at the Volokh Conspiracy, and he has a fabulous series of posts about the (in)accuracy of Michelle Malkin's new book, In Defense of Internment: The Case for 'Racial Profiling' in World War II and the War on Terror.

Here are the links to the ones so far: 1, 2, 3, 4a, 4b, and 5.

Posted in Civil Liberties | Comments Off on Eric Muller Is Demolishing the ‘Defense of Internment’

Abu Ghraib Photos

Ghastly Abu Ghraib photos at The Memory Hole (via The Yin Blog).

Posted in Iraq Atrocities | 13 Comments