Continuing with "Offsets" to The American Jobs Act
Subtitle E -- Dual Capacity Taxpayers
Sec. 441. Modifications of Foreign Tax Credit Rules Applicable to Dual Capacity Taxpayers
(a) IN GENERAL.—Section 901 of the Internal Revenue Code of 1986 (relating to credit
for taxes of foreign countries and of possessions of the United States) is amended by
redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection:
The contradictory statements below are from the US Chamber of Commerce
A dual capacity taxpayer is a multinational company click here) that pays a levy to a foreign country and also receives a specific economic benefit from that foreign country. Nearly all dual capacity taxpayers are U.S. based oil and gas companies that have operations in foreign countries....
...Limiting the creditability of foreign taxes paid by dual capacity taxpayers would impose double taxation on these taxpayers and make them uncompetitive in the global market....
So, let me get this right, the primary Dual Capacity Taxpayers are oil and gas companies, yet, they are uncompetitive in the global market place. This is the USA Chamber of Commerce making the argument that US Oil and Gas Companies are uncompetitive in the market place.
Sure.
And whom is it that owns the Republicans in the US House and Senate, exactly? And why is it the Republicans obstructed the President's Job's Bill? The COST? It wasn't the cost, it was the fact their cronies were disgruntled over NOTHING, but, their greed.
(b) CONTRARY TREATY OBLIGATIONS UPHELD.—The amendments made by this
section shall not apply to the extent contrary to any treaty obligation of the United States.
The Offset is not breach treaties which are passed by the Congress after negotiations with the President. This strictly applies only to the IRS tax forms.
That provision is definitely a paradigm the Plutocrats understand. Definitely. The learning curve would be short. The stroke of midnight, New Years Eve, tears start to roll. Be prepared with hankies for friends affiliated with same.
Sec. 442. Separate Basket Treatment Taxes Paid on Foreign Oil and Gas Income
(a) SEPARATE BASKET FOR FOREIGN TAX CREDIT.—Paragraph (1) of section
904(d) of the Internal Revenue Code of 1986 is amended by striking ‘‘and’’ at the end of
subparagraph (A), by striking the period at the end of subparagraph (B) and inserting ‘‘, and’’, and by adding at the end the following:
‘‘(C) combined foreign oil and gas income (as defined in section 907(b)(1)) (below).’’
President Obama has gone to every extent to make sure none of the Offsets effect 'the individual' because they are the STRENGTH of the economy. Don't tell me he doesn't know what he is doing, he does. His focus in extremely consistent.
The Obama Mandate for Recovery is to empower the Middle Class as consumers and provide every aspect of that consumerism at all levels of income. Where the incomes of Americans begin to reach a level of unfairness in loss of tax payments; adjustments have to occur. We have a national debt to pay down. Those best to help the most need to participate in a way the empowers the USA. Unfairness in the tax code is draconian.
The continued tax cuts for all would be wonderful, no one denies that, but it is not possible. NOT POSSIBLE. It will not injure the USA economy. The greatest number of consumer comes from the Middle Class. Maximizing the power of the Middle Class consumer adds income/profit to those wealthy when that wealth comes from business. I don't care if it is small business or Wall Street big box stores. The Middle Class consumer is the venue of growth. Look to the Friday after Thanksgiving to understand that paradigm is real.
When job growth occurs the income through the entire economy is exponential. So, while the wealthy would be paying more in taxes to the US Treasury, they would be receiving more income. They wouldn't feel it. Guaranteed.
The Republicans are simply wrong. They never came to the side of President Obama to end the disaster that occurred in 2008 beginning in 2007.
I'll start here next time.
Subtitle F – Increased Target and Trigger for Joint Select Committee on Deficit Reduction
Sec. 451. Increased Target and Trigger for Joint Select Committee on Deficit Reduction
Subtitle E -- Dual Capacity Taxpayers
Sec. 441. Modifications of Foreign Tax Credit Rules Applicable to Dual Capacity Taxpayers
(a) IN GENERAL.—Section 901 of the Internal Revenue Code of 1986 (relating to credit
for taxes of foreign countries and of possessions of the United States) is amended by
redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection:
Sec. 901. Taxes of foreign countries and of possessions of United
States (click title to entry - thank you)The contradictory statements below are from the US Chamber of Commerce
A dual capacity taxpayer is a multinational company click here) that pays a levy to a foreign country and also receives a specific economic benefit from that foreign country. Nearly all dual capacity taxpayers are U.S. based oil and gas companies that have operations in foreign countries....
...Limiting the creditability of foreign taxes paid by dual capacity taxpayers would impose double taxation on these taxpayers and make them uncompetitive in the global market....
So, let me get this right, the primary Dual Capacity Taxpayers are oil and gas companies, yet, they are uncompetitive in the global market place. This is the USA Chamber of Commerce making the argument that US Oil and Gas Companies are uncompetitive in the market place.
Sure.
And whom is it that owns the Republicans in the US House and Senate, exactly? And why is it the Republicans obstructed the President's Job's Bill? The COST? It wasn't the cost, it was the fact their cronies were disgruntled over NOTHING, but, their greed.
And why is it Republicans see deregulation and tax reduction as the answer to job creation? Because it works? No. Because it feeds their cronies regardless of the suffering of the American citizen.
Uncompetitive in the global market. What a joke!
The tax burden to the USA by the petroleum industry has been absorbed by the USA Treasury. This Offset requires the USA to receive their taxes along with the foreign nation.
The Petroleum Industry pays less taxes operating in foreign countries. They not only receive subsidies from the USA Treasury, they don't pay taxes to the USA Treasury.
Last time I checked Nova Scotia, Canada has a 17% tourism tax. It is applied to hotels, food and all the amenities a tourist would encounter including shops where tourists occur. As a tourist that tax is paid. Nova Scotia is a beautiful place with wonderful people, there are many reasons to travel there. The tax is simply part of the vacation a person takes.
When the tourist comes home to the USA they don't claim "I am a Dual Capacity Citizen Taxpayer," they simply pay the taxes due to the USA Treasury.
I remind the Petroleum Industry has legitimate costs to their business. They are allowed to reduce their tax burden while the USA Treasury absorbs their costs and accepts a lower tax rate. So, for all the claims the petroleum industry creates jobs, the salaries paid to those employees are absorbed by the USA Treasury to the extent they can be deducted from profits. So, don't tell me the petroleum industry isn't taken care off if they are not exempt from a Dual Capacity Taxpayer.
‘‘(1) GENERAL RULE.—Notwithstanding any other provision of this chapter, any amount paid or accrued by a dual capacity taxpayer or any member of the worldwide affiliated group of which such dual capacity taxpayer is also a member to any foreign country or to any possession of the United States for any period shall not be considered a tax to the extent such amount exceeds the amount (determined in accordance with regulations) which would have been required to be paid if the taxpayer were not a dual capacity taxpayer
The Petroleum Industry pays less taxes operating in foreign countries. They not only receive subsidies from the USA Treasury, they don't pay taxes to the USA Treasury.
Last time I checked Nova Scotia, Canada has a 17% tourism tax. It is applied to hotels, food and all the amenities a tourist would encounter including shops where tourists occur. As a tourist that tax is paid. Nova Scotia is a beautiful place with wonderful people, there are many reasons to travel there. The tax is simply part of the vacation a person takes.
When the tourist comes home to the USA they don't claim "I am a Dual Capacity Citizen Taxpayer," they simply pay the taxes due to the USA Treasury.
I remind the Petroleum Industry has legitimate costs to their business. They are allowed to reduce their tax burden while the USA Treasury absorbs their costs and accepts a lower tax rate. So, for all the claims the petroleum industry creates jobs, the salaries paid to those employees are absorbed by the USA Treasury to the extent they can be deducted from profits. So, don't tell me the petroleum industry isn't taken care off if they are not exempt from a Dual Capacity Taxpayer.
(b) CONTRARY TREATY OBLIGATIONS UPHELD.—The amendments made by this
section shall not apply to the extent contrary to any treaty obligation of the United States.
The Offset is not breach treaties which are passed by the Congress after negotiations with the President. This strictly applies only to the IRS tax forms.
(c) EFFECTIVE DATE.— The amendments made by this section shall apply to amounts that, if such amounts were an amount of tax paid or accrued, would be considered paid or accrued in taxable years beginning after December 31, 2012.
This Offset was not even immediate. The petroleum industry would have time to ready themselves to pay those taxes so it would not effect operations today. The ADJUSTMENT of the petroleum industry would not begin until immediately after midnight on New Years Eve of 2012.That provision is definitely a paradigm the Plutocrats understand. Definitely. The learning curve would be short. The stroke of midnight, New Years Eve, tears start to roll. Be prepared with hankies for friends affiliated with same.
Sec. 442. Separate Basket Treatment Taxes Paid on Foreign Oil and Gas Income
(a) SEPARATE BASKET FOR FOREIGN TAX CREDIT.—Paragraph (1) of section
904(d) of the Internal Revenue Code of 1986 is amended by striking ‘‘and’’ at the end of
subparagraph (A), by striking the period at the end of subparagraph (B) and inserting ‘‘, and’’, and by adding at the end the following:
TITLE 26 - INTERNAL REVENUE CODE
Subtitle A - Income Taxes
CHAPTER 1 - NORMAL TAXES AND SURTAXES
Subchapter N - Tax Based on Income From Sources Within or Without
the United States
PART III - INCOME FROM SOURCES WITHOUT THE UNITED STATES
Subpart A - Foreign Tax Credit (click here)Sec. 904. Limitation on credit(d) Separate application of section with respect to certain categories of income(1) In general.--The provisions of subsections (a), (b), and (c) and sections 902, 907, and 960 shall be applied separately with respect to-- (A) passive category income, and (B) general category income.(C) combined foreign oil and gas income (as defined in section 907(b)(1)).’
‘‘(C) combined foreign oil and gas income (as defined in section 907(b)(1)) (below).’’
(1) Personal exemptions
For purposes of subsection (a), the taxable income in the case
of an individual, estate, or trust shall be computed without any
deduction for personal exemptions under section 151 or 642(b).Internal Revenue Code:Sec. 151. Allowance of deductions for personal exemptions (click here)
Internal Revenue Code:Sec. 642. Special rules for credits and deductions (click here)
(b) Deduction for personal exemption
President Obama has gone to every extent to make sure none of the Offsets effect 'the individual' because they are the STRENGTH of the economy. Don't tell me he doesn't know what he is doing, he does. His focus in extremely consistent.
The Obama Mandate for Recovery is to empower the Middle Class as consumers and provide every aspect of that consumerism at all levels of income. Where the incomes of Americans begin to reach a level of unfairness in loss of tax payments; adjustments have to occur. We have a national debt to pay down. Those best to help the most need to participate in a way the empowers the USA. Unfairness in the tax code is draconian.
The continued tax cuts for all would be wonderful, no one denies that, but it is not possible. NOT POSSIBLE. It will not injure the USA economy. The greatest number of consumer comes from the Middle Class. Maximizing the power of the Middle Class consumer adds income/profit to those wealthy when that wealth comes from business. I don't care if it is small business or Wall Street big box stores. The Middle Class consumer is the venue of growth. Look to the Friday after Thanksgiving to understand that paradigm is real.
When job growth occurs the income through the entire economy is exponential. So, while the wealthy would be paying more in taxes to the US Treasury, they would be receiving more income. They wouldn't feel it. Guaranteed.
The Republicans are simply wrong. They never came to the side of President Obama to end the disaster that occurred in 2008 beginning in 2007.
I'll start here next time.
Subtitle F – Increased Target and Trigger for Joint Select Committee on Deficit Reduction
Sec. 451. Increased Target and Trigger for Joint Select Committee on Deficit Reduction
