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View Diary: Romney Parks Millions in Offshore Tax Havens UPDATE 2 (309 comments)

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  •  HUH? (4+ / 0-)

    It's Mitt's money. Precisely how is he not responsible for using these shelters?

    In theory, there is no difference between theory and practice; but in practice, there always is a difference. - Yogi Berra En théorie, il n'ya aucune différence entre théorie et pratique, mais en pratique, il ya toujours une différence. - Yogi Berra

    by blue aardvark on Wed Jan 18, 2012 at 03:52:21 PM PST

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    •  he gets no tax benefit from it. (2+ / 0-)
      Recommended by:
      Argyrios, VClib

      The benefit is for the investors: US charities and pensions avoid ubit tax, and foreigners don't have to disclose their info to the IRS.

      But because the offshore makes an election to be treated as a US partnership, from a tax perspective these entities aren't Cayman Islnds entities; they're US partnerships.  

      •  Thank you, thank you... (2+ / 0-)
        Recommended by:
        Argyrios, johnny wurster

        For a breath of reason and understanding.

      •  No (2+ / 0-)
        Recommended by:
        Marie, flitedocnm

        A Cayman Islands entity that makes an election under 301.7702 to be taxed as a partnership does not become a U.S. partership by virtue of such election.  It becomes a foreign partnership.

        Also, pension funds (or other tax-exempt investors) do not avoid UBTI by investing in an offshore fund;  the structure that allows them to avoid UBTI is to use a blocker corporation to funnel the investment to the offshore fund.

        "Well, I'm sure I'd feel much worse if I weren't under such heavy sedation..."--David St. Hubbins

        by Old Left Good Left on Wed Jan 18, 2012 at 05:33:38 PM PST

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        •  Yes (0+ / 0-)

          For US tax purposes, a foreign partnership is treated just like a US one.  Blocker corps are always foreign entities.

          •  well you and OLGL are certainly (0+ / 0-)

            raising MY awareness. and i hope that's a good thing. ;)

            Addington's perpwalk is the trailhead of accountability for this wound to our national psyche. (But go ahead and arrest Rumsfeld, too.)

            by greenbird on Thu Jan 19, 2012 at 04:18:24 AM PST

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          •  No (1+ / 0-)
            Recommended by:

            A foreign partnership is a foreign partnership is a foreign partnership.

            There is a difference between "taxed as a partnership for U.S. tax purposes" and a "U.S. partnership."  For example, all U.S. partnerships (i.e., those organized in a state or D.C.) must file a U.S. tax return.  A foreign partnership--even one that makes an election to be taxed as a partnership for U.S. tax purposes--files only if it has a U.S. trade or business, or income effectively connected with the United States.  Withholding rules are also different.

            "Well, I'm sure I'd feel much worse if I weren't under such heavy sedation..."--David St. Hubbins

            by Old Left Good Left on Thu Jan 19, 2012 at 08:15:03 AM PST

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      •  none the less: we should USE THIS for.... (2+ / 0-)
        Recommended by:
        OleHippieChick, dannyinla

        ... all it's worth.

        Look: it doesn't matter if he broke the law. What matters is to get him to deny that he broke the law.

        We are at war: the climate war, the culture war, the class war, and the basic sanity war.  That's war on all fronts.  And the way to win is to do whatever works (except: no violence, and nothing more illegal than a sit-in).  

        If smearing Romney by using words like tax cheat and Cayman Islands costs him votes, then that's what we have to do.  Let him "explain himself."  Make him explain himself!  

        He who attacks, wins!

        He who explains, loses.

        "Minus two votes for the Democrat" equals "plus one vote for the Republican." Arithmetic doesn't care about your feelings.

        by G2geek on Wed Jan 18, 2012 at 11:13:18 PM PST

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