Incremental change with a minimum of controversy must be Mr. Camp’s goal. That would explain why he takes the corner wide, steering clear of the most controversial aspect of partnership tax: carried interest. Carried interest refers to the share of partnership profits earned by an investment fund manager, and under current law it is often [...]
Lynnley Browning has a story in today’s NYT about Supercharged IPOs, drawing in part on my study with Nancy Staudt. “They involve millions, often billions, of dollars in cash transfers from newly public companies to a small group of pre-I.P.O. owners,” Victor Fleischer, a tax professor at the University of Colorado, and Nancy Staudt, a [...]
Yahoo’s chief executive, Marissa Mayer, inspired much debate and rebuke when she recently abolished Yahoo’s work-at-home policy. In academia, “working from home” is a treasured euphemism for heading home after your morning class to have lunch, read the newspaper and take a nap. I hate to see anything that would endanger this hallowed tradition. via [...]
Representative Dave Camp, the Michigan Republican and chairman of the House Ways and Means Committee, recently released a discussion draft of proposed legislation that would tax most financial derivatives on a “mark-to-market” basis. This means that at the end of each year, derivative holders would estimate the market value of the derivative, recognizing tax gains [...]
From my column today: Consider the special provision for “qualified small business stock,” which provides a zero percent tax rate on capital gains from certain investments. A better name would be the “angel investor loophole.”The tax break mainly benefits angel investors, who are individuals often retired entrepreneurs who invest in early stage companies. As these [...]
Many companies use tax planning to create a competitive advantage. If your competitors pay taxes at a 35 percent rate, but you have figured out a way to greatly reduce your effective tax rate, then the status quo is valuable to you. via Not All Companies Would Welcome a Lower Tax Rate – NYTimes.com.
My latest column: The Wall Street Rule is objectionable from a tax policy perspective when aggressive tax lawyers sanction a deal structure that contravenes the rules, or one that resides in a gray area but is contrary to what Congress intended.I do not think that is the case here. The Remic rules are designed to [...]
The transcript of Romney’s testimony about Staples is pretty interesting. Romney told the truth under oath, as best I can tell, but not when it came to reporting the true value of common stock for tax purposes. Romney, as a director of Staples, approved the valuation of the common stock for tax purposes as worth [...]
Thoughtful article by an experienced PE investor: Romney’s financial success is admirable and enviable, but it came by following the mantra of increasing cash flow, cutting jobs and minimizing taxable income. Though the Obama campaign has tried to exploit this with millions of dollars in anti-Bain ads, the real issue is how Romney’s experience relates [...]
The legality of this loan program is questionable. In similar cases, the Internal Revenue Service has successfully argued that a series of short-term loans should be recast as what it is in substance: a single long-term loan that would be treated as a cash repatriation under Section 956 of the tax code. In an e-mail [...]