EU, Great Britain, and Taxes

Some…suggestions…from continental leaders regarding Great Britain’s departure from the EU and the Exchequer’s suggestions of British corporate tax rate reductions, via The Wall Street Journal:

  • German Finance Minister Wolfgang Schäuble: we can’t have a “race to the bottom, now can we?”

Why not, I ask—what are you so terrified might result from letting those who earned the money keep more of it?

  • Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs: let’s not have any of this “exacerbated(?) fiscal competition between ourselves” nonsense.

I ask—why not?  What’s so terrible about competition, which spurs innovation, holds down costs for the citizenry, limits government power.  Oh, wait….

  • French Finance Minister Michel Sapin: “Whether you’re in the union or yo’’re out, we should all adopt a friendly attitude.” Or else.

So I ask—when are you going to adopt that friendly attitude, M Sapin?

Cut the taxes, guys.  If the continent want to run, screaming, away from the terror of competition, you’ll still have the Irish and the Icelanders with whom to play.  And a whole, wide world outside the European continent and its special snowflakes.

Another IRS Assault

This time on private enterprise and a private economy company that’s nominally outside the scope of the government economy.

US tax officials sued Facebook Inc to force the company to hand over documents related a transfer of assets to Ireland in 2010, part of a yearslong investigation into whether some of those assets were undervalued “by billions of dollars.”

Because, of course, John Koskinen and his IRS minions know better how to value a private enterprise than does the private enterprise.

Alternatively, Koskinen has reason to believe the company has falsified its valuations, which raises the question: what’s your probable cause, Mr Koskinen?

Whose Money Is It?

Another in the annals: what is OPM—the EU’s use of money earned by European national citizens and paid over to the EU in the form of taxes?  Or is it the EU’s money, and it’s the citizens who are using OPM—the money the EU allows the citizenry to have?

This one comes from the world of (Spanish) sports.

Real Madrid, FC Barcelona, and five other Spanish soccer clubs will have to return tens of millions of euros to Spain’s government after benefiting from illegal tax breaks, the European Union’s antitrust regulator said Monday.

The European Commission said the tax breaks, property deals, and loans and bank guarantees granted by the Spanish government gave those clubs an unfair advantage over their competitors.

Because the worthies of the EU Know Better what the Spanish should do with their money than does the Spanish government.

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.