tag:blogger.com,1999:blog-2135788133426971614.post7502421478385096383..comments2024-03-28T01:09:48.303-07:00Comments on 21st Century Taxation: Tax Reform Framework ObservationsProfessor Nellenhttp://www.blogger.com/profile/03288632402197167948noreply@blogger.comBlogger10125tag:blogger.com,1999:blog-2135788133426971614.post-21211476945652394512021-12-21T04:31:48.035-08:002021-12-21T04:31:48.035-08:00Very interesting blog. A lot of blogs I see these ...Very interesting blog. A lot of blogs I see these days don't really provide anything that attract others, but I'm most definitely interested in this one. Just thought that I would post and let you know.tushar shrivastavahttps://advocatetusharsrivastava.com/noreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-91739354061858465672018-03-03T00:38:08.950-08:002018-03-03T00:38:08.950-08:00I am extraordinarily affected beside your writing ...I am extraordinarily affected beside your writing talents, Thanks for this nice share.<br />App Development Company Delhihttp://www.defuzed.innoreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-14763744689622464612017-11-20T03:43:48.813-08:002017-11-20T03:43:48.813-08:00Hi, Really great effort. Everyone must read this a...Hi, Really great effort. Everyone must read this article. Thanks for sharingProperty Lawyer Delhihttp://www.karanthukral.comnoreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-56038947905737769842017-11-14T20:26:33.265-08:002017-11-14T20:26:33.265-08:00Thanks for the insightful "Tax Reform" F...Thanks for the insightful "Tax Reform" Framework piece, Annette, Be looking for your critique of the Senate and Conference versions... Sausage is looking more delectable as this goes on...<br />As the The Donald's NOL it might be useful to remember that it's Section 172 and more broadly the entirety of Title 26 that is embarrassing to me... 45+ years in the academic & Tax consulting world... plying at a profession legislated into existence...Hummm?<br /><br />As the NOL, as you know, the modifications required by section 172(d) are intended to reduce the loss to reflect a real, economic, hard-dollar loss...(i.e. real money) so, if calculated correctly, that would mean, in the Donald's case, he lost $900+ Million which congress said write it off... It also means that during the C/O period he earned real hard dollar income of the same amount in order to absorb it... among Forbes 400 richest in one year, negative net worth the next...now who really knows...Hope to catch up with you and Gray for your update class.. <br /><br />Phil Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-78341480061820204892017-10-11T04:26:27.243-07:002017-10-11T04:26:27.243-07:00I really appreciate your proficient approach. Thes...I really appreciate your proficient approach. These Measure area unit of measurement unit things of really useful knowledge which is able to be of nice use on behalf of me in future.<br />Buy Contact Lenseshttp://www.lensico.com/noreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-87353938813887664672017-09-30T15:56:26.500-07:002017-09-30T15:56:26.500-07:00James, thanks for the comment. If he continues to ...James, thanks for the comment. If he continues to have a net operating loss carryover, he is today at least paying AMT because he can't he can only use an AMT NOL to reduce is AMT income by no more than 90%. So he pays AMT unless he continues to generate losses every year.Professor Nellenhttps://www.blogger.com/profile/03288632402197167948noreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-62776547509121813802017-09-30T15:22:56.028-07:002017-09-30T15:22:56.028-07:00Professor Annette Nellen,
Appreciate your "t...Professor Annette Nellen,<br /><br />Appreciate your "tracking" and analysis for "Tax Reform" (?? - really) proposal. I noticed you mentioned that Donald Trump (in spite of his claim of no personal tax benefits) would be a beneficiary of proposed "Tax Reform". After contemplating this for a while, I realized that he is actually correct given his massive ("grossly offensive") Net Operating Loss carry-forward even though he has refused to release his personal tax returns contrary to other US Presidents. Any individual marginal income tax rate changes proposed under "Tax Reform" won't really have any impact for him. Wondering if you think this makes sense given what we know about DT personal taxes ?James Kronenberghttps://www.blogger.com/profile/00056799849135383668noreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-9894239646781159692017-09-30T14:49:33.629-07:002017-09-30T14:49:33.629-07:00This: But why are we talking about fitting a 21st ...This: <i>But why are we talking about fitting a 21st century tax system on a postcard return rather than having a just-in-time filing system?</i><br /><br />Also, why are we still stuck with April 15 as a filing date for individuals? Why not your birthday as your year end and 30 days later (or 60) for a filing due date? That would eliminate major time crunches and in the just-in-time system you're talking about could easily be managed.<br /><br />Yeah, I know, pie in the sky. Government inefficiency means many jobs and lifetime paychecks for government employees.L Carpenternoreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-25111595626470211742017-09-30T13:50:57.483-07:002017-09-30T13:50:57.483-07:00David, thanks for the comments. I think guaranteed...David, thanks for the comments. I think guaranteed payments to partners for services will be taxed at usual individual rates rather than capped at 25% to be sure suchcompensatuon is taxed similar to that of an employee. Professor Nellenhttps://www.blogger.com/profile/03288632402197167948noreply@blogger.comtag:blogger.com,1999:blog-2135788133426971614.post-18068799712841629572017-09-30T10:49:37.074-07:002017-09-30T10:49:37.074-07:00Many high net-worth taxpayers in California curren...Many high net-worth taxpayers in California currently are subject to a top federal 28% AMT marginal tax rate. Since many of the tax preferences, adjustments and deductions would be eliminated under this Framework, the top marginal rate (and potentially top effective rate) might increase to 35%, or at a rate that is in excess of 28%. You are correct in saying that the details of the brackets are important. Many in California with personal real estate holdings might find that they are subject to an increase in their federal tax rate, since they are currently subject to the AMT.<br /> <br />With respect to the top 25% rate for certain flow-through entities, some are questioning if guaranteed payments made to partners would be taxed at a rate different/higher than the top 25% rate. One would hope that the drafters would also tax guaranteed payments at the top 25% rate. This of course would not remove the exposure of partnership income being subject to the self-employment tax.David Sacareloshttps://www.linkedin.com/in/david-Sacarelos-939316/noreply@blogger.com