Tax Complexity

A Private Letter Ruling is a letter the IRS issues to a particular taxpayer—corporate or business—to provide specific instructions/clearance to a specific taxpayer about that taxpayer’s particular circumstance.  PLRs set no precedent for any other taxpayer; even if that other has a substantially similar circumstance.  The price for such a Letter, charged by the IRS to the Letter’s recipient, ranges from $2,200 to $28,300.

The procedure for getting a PLR is set out in Internal Revenue Bulletin:  2016-1, which runs past 260 .pdf pages (the Table of Contents runs nearly 6 pages).  There’s a hint there.

Here’s another hint, from the opening paragraph of 2016-1‘s Section 1, which lays out the purpose of this procedure:

This revenue procedure explains how the Service provides advice to taxpayers on issues under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Tax Exempt and Government Entities). It explains the forms of advice and the manner in which advice is requested by taxpayers and provided by the Service. A sample format for a letter ruling request is provided in Appendix B. See section 4 of this revenue procedure for information on certain issues outside the scope of this revenue procedure on which advice may be requested under a different revenue procedure.

Seven different tax specialist head lawyers are needed by the IRS to explain the IRS’ own tax rules to prospective tax advice seekers.

Hmm….

Tony Blair Misunderstands

Great Britain’s Ex-Prime Minister Tony Blair has sensed danger from the Brits’ vote to leave the European Union.

Blair said in a Friday column in The Daily Telegraph that the future of the United Kingdom is at stake as the country faces negotiations on the terms of leaving the European Union.

Of course there’s danger—there always is when a change as large as this is embarked on.  But Great Britain didn’t get to be as great as it was and still is by being timid.  This move is a great opportunity for the nation, much more so than it is a risk, however real that risk is.

Blair also worried:

Britain is dangerously divided, with “profound dismay” felt by many of the 48 percent who wanted to remain in the EU.

He’s missing the other question, though: would Great Britain be any less divided had they voted to Remain?  Not a bit.

Look forward, not backward.

Another Government Overreach?

Before the government can measure the size of the gig economy—or is it the sharing economy? The digital economy?—the sector needs to be defined.

No, it doesn’t.  It doesn’t even need to measure the size of the gig economy; government has shown it’s not going to do anything useful, or freedom-promoting, with that measurement.

And this misconception, by Commerce Department Acting Under Secretary for Economic Affairs Justin Antonipillai:

In order to have good policy making, you have to have good data[.]

Again, no.  Government doesn’t need to make any policy in this area.  Not at all.  Government just needs to butt out, and let American entrepreneurs make their own way.

Only our Liberals are unable to function without being told every little thing every step of the way.  Even Liberals can learn how, though.

This is News?

US Secretary of State John Kerry on Sunday urged Britain and the European Union to manage their divorce responsibly for the sake of global markets and citizens….

Kerry said

The most important thing is that all of us, as leaders, work together to provide as much continuity, as much stability, as much certainty as possible[.]

Empty remarks by the motorboat skipper who sits in the Secretary of State’s chair.  After all, what else would he say—that the EU and Great Britain should go for each other’s throats, and the first slash wins?

On the other hand, after President Barack Obama threatened the Brits should they go against their Betters and vote to leave, maybe this is news.

EU and Taxes

The European Union agreed Tuesday on a set of rules and standards aimed at closing loopholes that allow wealthy multinationals to shift profits and avoid footing large tax bills.

“Today’s agreement strikes a serious blow against those engaged in corporate tax avoidance,” said Pierre Moscovici, the bloc’s tax affairs commissioner.

Notice that.  There’s not the slightest glimmer of a concept of discouraging corporate tax avoidance by lowering tax rates.  No, it’s not the corporation’s money; it’s the EU’s, and they’ll decide how much of the money gained by a corporation the EU will permit it to retain.