I've been thinking about the issue of "guardrails" in relation to the passthrough rules in the House and Senate bills, with regard to whom they are supposed to keep out.
The problem I'm having in thinking about it is that, since there is no coherent underlying theory regarding who should get the benefit and why, it becomes difficult to figure out who would be getting it "improperly," and contrary to legislative intent, if we require defining such intent at a more general level than "industries that are friendly with the Congressional Republicans."
Let's take the underlying question of how the special rate for passthroughs relates to labor income, or wages in the economic (as opposed to the legal) sense. Wages in the legal sense don't get the special rate, but is it supposed to be for people who are providing labor income (even if combined with the use of capital) in the economic sense? Note that labor income in this sense, of course, extends to thinking about how to run the business, making decisions about its possible expansion, etc.
Both the House and the Senate bills appear to gesture in the direction of trying to reduce its association with doing work. But they do so ineffectively. The House bill has the supposed guardrail of reducing the benefit if you materially participate as defined by the passive loss rules, which would mean that the mere idler who owns a perhaps inherited business and trusts the hired hands to run it does better than the one who actually works.
But what's the reason for rewarding the idler? Doesn't it have something to do with decisions we think this person is making, which again is a form of work?
Note, BTW, that the passive loss rules were written to dampen the use of claimed managerial oversight as a mechanism for establishing material participation. But if you go back to the 1986 legislative history of the passive loss rules, you will see that this was based on a concern that people could fake exercising managerial oversight that was actually de minimis. (E.g., you just rubber-stamp whatever the folks whose business it actually is tell you to rubber-stamp.)
Then there is the exclusion in the House bill for personal service businesses. I have tended to interpret this as just reflecting that the House Republicans aren't particularly good friends with lawyers, doctors, consultants, etc. They are better friends with the real estate industry, the oil industry, etc. But there's a fig leaf on it of trying to sort out what's purely labor income - except that the people in the favored industries really have predominantly labor income too, at least if one defines it in the economic sense and they are actually running their businesses (not skiing in Gstaad while daddy's henchmen run the business).
We get to the Senate bill, and the personal service industries get some moolah from the provision until one's taxable income gets too high. And one doesn't get the special rate for W-2 wages that are actually paid, so long as they are reasonable compensation. But there's no requirement that one pay reasonable compensation - one can underpay oneself and get the passthrough deduction so long as one otherwise qualifies. So it taxes labor income favorably, so long as you aren't stupid enough (or constrained by liquidity concerns) to pay it to yourself as formal wages.
The whole thing also really has nothing to do with taxing "capital income" at more favorable rates than labor income. The way to lower the tax burden on capital income, relative to a pure income tax, is to have expensing or its equivalent, not to tax interest income or the normal return, etc. The tax bills do this to a degree, e.g., by allowing a lot of expensing (plus interest deductions to make some capital income affirmatively subsidized rather than exempt!), although they don't exempt interest income.
But the favorable rate for passthroughs really has almost nothing to do with any of this. Again, those businesses are getting expensing, and if they're getting extra-normal returns (rents in economic lingo), without which all this becomes less interesting, then taxing these returns is efficient.
So one main aspect of the passthrough rule is a special, lower tax rate for labor income when it's done through a passthrough, the definition of which is pretty much circular (you qualify if you qualify, and it's hard to see why in terms of an underlying theory). Plus, Junior at Gstaad gets the special rate, reflecting others' past labor income that presumably is continuing to play out nicely, and again it's not quite clear why.
Against this background, what exactly is the guardrails' proper reach? It's quite hard to say when the underlying theory in support of the rules is so lacking. By lacking, of course, I mean not just incorrect but incoherent or nonexistent.
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A MUST READ :Me and my family has been in poverty for about five years now and my husband have left us six years ago and he was very rich he was with another woman who do not even have a child for him and abandon me with my 4 children so one day my son said that his friend saw a post of one woman saying that he can help someone get a loan then my son use his friend's phone to email the woman then he cheated with her so the woman said that he will help us I said he was joking so he told us what to do then we did it 4 days later i got a loanand me and my family were living very fine then three days ago my husband came home on his knees he was pleading but now we are now back together again so am telling you now if you need a loan etc email her now on jasminnoorloancompany01@gmail.com,
good day, my name is torres i am a citizen of the united state of america i want to testify of the good loan lender who showed light to me after been scammed by 4 different internet international lender, they all promise to give me a loan after making me pay alot of fees which yield nothing and amounted to no positive result. i lost my hard earn money and it was a total of 8,000usd. one day as i was browsing through the internet looking forsterated when i came across a testimony man who was also scammed and eventually got linked to a legit loan company called Jasmin Noor loan company (jasminnoorloancompany01@gmail.com) where he finally got his loan, so i decided to contact the same loan company and then told them my story on how i have been scammed by 4 different lenders who did nothing but to course me more pain. i explain to the company by mail and all they told me was to cry no more because i will get my loan in their company and also i have made the right choice of contacting them, so if there is anyone who need a loan should email them
Dear Customer, I am George Smith, I give out loans with 3% interest rate..
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Good Day I am Vanessa Cowen from California and i have a broken up business, until i found this company who help me to gain a loan for business, and now i want to used this short medium to congratulate the company for the fast and safe funds they loan to me without any form of delay, i loan 180,000.00USD from the company at a very low interest rate of 2% to save my business and lots more. i first saw their mail on the internet, everyone always give testimony for what they did, so i quickly contacted them and they all did everything for me without stress and my funds was sent to my account within 24hrs, i was surprise and feel glad, now i now have a standard business control agent who help me, now i will advice those who need urgent loan to contact them now via email : {jonesloanfinance@yahoo.com} OR Text him +1(307) 217-5388.....
A MUST READ :Me and my family has been in poverty for about five years now and my husband have left us six years ago and he was very rich he was with another woman who do not even have a child for him and abandon me with my 4 children so one day my son said that his friend saw a post of one woman saying that he can help someone get a loan then my son use his friend's phone to email the woman then he cheated with her so the woman said that he will help us I said he was joking so he told us what to do then we did it 4 days later i got a loanand me and my family were living very fine then three days ago my husband came home on his knees he was pleading but now we are now back together again so am telling you now if you need a loan etc email her now on jasminnoorloancompany01@gmail.com,
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HOW I BECAME A VICTOR AFTER SO MANY FAILED ATTEMPT OF GETTING A LOAN.
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Finding a legitimate loan lender (mrdonaldmooreloanfirm@gmail.com) have always been a huge problem to clients who have financial problem and in need of solution to it. The issue of credit and collateral are something that clients are always worried about when seeking a loan from a legitimate lender. But we have made that difference in the lending industry by offering loans to individual and public sector that are in need of financial Assistance in a low interest rate of 2%. Bad credit acceptable, The Terms and Conditions are very simple and considerate. You will never regret anything in this loan transaction because we will make you smile. Our company has recorded a lot of breakthroughs in the provision of first class financial services to our clients, especially in the area of Loan syndication and capital provision for individuals and companies.
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Helen Truong is my name from 1731 Hilltop Haven Drive, Red Bank, NJ 07701 USA. It lifts my heart to actually use this medium to save innocent people who would have fallen into the wrong hands in quest to obtain an online loan. With all humility I want to personally warn all online loan seekers to be very careful while trying to get a loan, because it is no news that scammers are rampant everywhere all over the internet claiming to offer loan. I was a victim before now and I solemnly hope that you are a victor if you care to take my word of advise. Few months ago I was financially strained, and due to my desperation I was scammed by several online lenders. All hope was nearly lost until a co-employee suggested 'JOSH LOANS FINANCIAL SERVICE' an online reliable and trustworthy lender for me, as I was almost at the edge of taking my life considering a loss of about $83,000; As God would have it, I applied for a loan from 'Josh Loans Financial Service' under Cynthia's (co-employee) recommendation and WOW in less than 72 working hours I got a credit alert confirming that my account has been credited with the loan fund of $220,000.00 which i originally requested. If after loosing much God has shown me light with the help of 'JOSH LOANS FINANCIAL SERVICE', you too without doubt can as well obtain a loan from this reputable lending institution. IN ALL, if you, your relation or any closed person desperately need a loan, DO CONTACT or help that soul to communicate with JOSH LOANS FINANCIAL SERVICE via email on joshloancompany@gmail.com OR text/call them on +1(215)-874-8060
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Company Registration No. 02587815
Treg Finance Limited provides personal loans/business loans/trade finance/import & export loans/project loans to companies of all sizes ranging from individuals, globally without restriction to location, border or country.
Interest rate of 2%
Minimum loan amount of $25,000
No credit check required
Bad credit can apply
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Executive Business Summary for business loans/trade finance
Loan Duration from 1 year - 20 years maximum
Grace period of 12 - 24 months for large business loans/trade finance
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Website: http://www.tregfinance.net
Email: info@tregfinance.net
Tel: +44 (287) 114-0153
Skype id: treg.finance1@outlook.com
201 Bishopsgate, London, EC2M 3AE
Company Registration No. 02587815
Treg Finance Limited provides personal loans/business loans/trade finance/import & export loans/project loans to companies of all sizes ranging from individuals, globally without restriction to location, border or country.
Interest rate of 2%
Minimum loan amount of $25,000
No credit check required
Bad credit can apply
Fast reliable loan with flexible repayment schedules
Executive Business Summary for business loans/trade finance
Loan Duration from 1 year - 20 years maximum
Grace period of 12 - 24 months for large business loans/trade finance
Treg Finance Company Limited
Website: http://www.tregfinance.net
Email: info@tregfinance.net
Tel: +44 (287) 114-0153
Skype id: treg.finance1@outlook.com
201 Bishopsgate, London, EC2M 3AE
Company Registration No. 02587815
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.............................
Hello everyone, My name is Mr mike I am from the Alabama, United State, am here to testify of how i got my loan from Mr mike Alex Loan Company{ ( (davidmike01477@gmail.com)} after i applied Two times from various loan lenders who claimed to be lenders right here this forum, i thought their lending was real and i applied but they never gave me loan until a friend of mine introduce me to Mr mike Alex Loan Company, who promised to help me with a loan of my desire and he really did as he promised without any form of delay, I had doubts but i never seize to believe. I never thought there are still reliable loan lenders until i met Mr mike Alex, who really helped me with my loan and changed my life for the better. I know there are still many good lenders out there but i would advise you to try Mr mike Alex Loan Company, his caring and understanding. don't know if you are in need of an urgent loan also or want funding for your projects, So feel free to contact Mr mike Alex Loan Company his email address is ( (davidmike01477@gmail.com)or Text: +19513561932 10 augustus, 2018
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Good day if you need a loan of any kind then you have to contact me for a convenient loan service at interest of 2%, if you need loans such as -
Home loan
Car loan
Truck Loan
Business loan
Education loan
Repair loans
Small loans
Big loans
Contract or Project loans
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Greetings to you by (BFGL).
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Mrs Rose Larsson.
(Personal Assistant)
Bentex Funding Group Ltd(BFGL)
501 Avenue Montaigne,75008 Paris-France
Paris-France.Bentex Funding Group Ltd (BFGL)
Hello Everybody,
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Hello Everybody,
My name is Mrs Sharon Sim. I live in Singapore and i am a happy woman today? and i told my self that any lender that rescue my family from our poor situation, i will refer any person that is looking for loan to him, he gave me happiness to me and my family, i was in need of a loan of S$250,000.00 to start my life all over as i am a single mother with 3 kids I met this honest and GOD fearing man loan lender that help me with a loan of S$250,000.00 SG. Dollar, he is a GOD fearing man, if you are in need of loan and you will pay back the loan please contact him tell him that is Mrs Sharon, that refer you to him. contact Dr Purva Pius,via email:(urgentloan22@gmail.com) Thank you.
Finding a legitimate loan lender (mrdonaldmooreloanfirm@gmail.com) have always been a huge problem to clients who have financial problem and in need of solution to it. The issue of credit and collateral are something that clients are always worried about when seeking a loan from a legitimate lender. But we have made that difference in the lending industry by offering loans to individual and public sector that are in need of financial Assistance in a low interest rate of 2%. Bad credit acceptable, The Terms and Conditions are very simple and considerate. You will never regret anything in this loan transaction because we will make you smile. Our company has recorded a lot of breakthroughs in the provision of first class financial services to our clients, especially in the area of Loan syndication and capital provision for individuals and companies.
We Render The Following Services:
Mortgages,
Home Loans/Business Loans,
Bad Credit Loans/Commercial Loans,
Start-Up Working Capital Loans,
Construction Loans,
Car loans/Hotel Loans,
Personal Loans/Student loans,
Debts Consolidation Loans
OUR LOAN is 100% GUARANTEE with No social security, no credit check up and with 2% interest rate. We have a network of Investors that are willing to provide funds of whatever amount to individuals and organizations to start business and operations, All you need to do is let us know exactly what you want and we will surely make your dream come true. Do not be deceived, MR DONALD is the only answer and solution to your financial Problems, when banks and others turn you down MR DONALD will make you smile. For more details about our loan contact us via
Email: mrdonaldmooreloanfirm@gmail.com
phone contact: +1-202-381-1907
website: www.mrdonaldmooreloanfirm.bravesites.com
Do You Seek Funds To Pay Off Credits and Debts? { FIFOCapitals@gmail.com } Is Here To Put A Stop To Your Financial Problems. We Offer All Kinds Of Loan (Personal Loan, Commercial Loan, etc.) We Give Out Loan With An Interest Rate Of 1.00%. Interested Applicants Should Contact Us Via Email: FIFOCapitals@gmail.com
Please Fill the Application Form Below:
- Complete Name:
- Loan Amount Needed:
- Loan Duration:
- Purpose Of Loan:
- City / Country:
- Telephone:
- How Did You Hear About Us:
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financial stress or do you need funds to start up
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Thanks And God Bless
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MINIMUM FACE VALUE OF BG/SBLC = EUR/USD 1M
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FOR PURCHASE OF FRESH CUT BG/SBLC
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Skype ID: stacygabriele07@gmail.com
WhatsApp: +12098004843
Haven come across David Benjamin on Quora while in search of a reliable trader after being scammed, has proven to be the best thing that has happened to me. In November of 2021, I lost over $20,000 to a scam who took my money without delivering on their promise. I came in contact with David Benjamin and I started my first investment with $2,000. To be honest it was just a leap of faith and I wanted to see what his services entails after seeing such a great review. Its exactly 2 months now, and I have made over a $100,000 as return on investment. This has changed my life and improved my business a great deal. Words alone cannot express my gratitude to this God sent trader. David Benjamin is really skilled in trading and employs advanced technology you will not find anywhere else. I am certain this information will be helpful to someone.
Email :davidbenjaminexptrader@outlook.com
WhatsApp :+1 408 500 0775
We are project funder with our cutting edge and group capital fund we can finance your signatory projects and help you to
enhance your business plans,this offer is open to both individuals and corporate bodies.
Our financial instrument can be used for purchase of goods from any manufacturer irrespective of location. We specialized
in BG, SBLC, MTN, CD,LC,Bank Bonds,Non collateral loan, confirmable Bank Draft and other financial assistance from AAA
rated bank (Prime Bank). The financial instrument can be invested into High Yield Trading Program or Private Placement
Programme (PPP). We work directly with issuing bank lease providers,this Instrument can be monetized on your behalf for
100% funding.Please see our instrument description as follow.
DESCRIPTION OF INSTRUMENT:
(1) Instrument: Bank Guarantee {BG} /StandBy Letter of Credit.{SBLC} (Appendix A).
(2) Total Face Value: Eur/USD 1M{Minimum} to Eur/USD 100MNJH{Maximum}.
(3) Issuing Bank: AAA Rated Bank (Prime Bank).
(4) Age: One Year and One Day.
(5) Leasing Price: 4% of Face Value plus 2% commission.
(6) Delivery: bank to bank SWIFT MT-799 and/or MT-760.
(7) Payment: MT103 (TT/WT).
(8) Hard Copy: Bonded Courier Service.
Intermediaries/Consultants/Brokers are welcome to bring their clients and are 100% protected. In complete confidence, we
will work together for the benefits of all parties involved,If in need of our services, contact me for detail
For further inquiry contact:
Email: inquiry.trustedfinanceplc@gmail.com
Skype : inquiry.trustedfinance@gmail.com
Whatsapp : +17329300338
Hi Guyz
We have got Freshest Fullz
USA UK CANADA & many other countries
Recent spammed DEC-2023 updated fullz
Valid & Guaranteed info
Legit vendor you can try us for sure
SSN DOB DL ADDRESS USA
SIN DOB ADDRESS CANADA
NIN DOB ADDRESS UK
HIGH CREDIT SCORES FULLZ 700+
CC WITH CVV FULLZ
REAL ID/DL SCAN FRONT BACK WITH SELFIE
YOUNG AGE FULLZ
BUSINESS EIN COMPANY FULLZ
LOAN METHODS|CARDING METHODS
CARD CLONNING DUMPS TRACK 101 & 202 WITH PIN CODES
FULLZ FOR TAX RETURN|KYC|PUA|UI|SBA|UBEREATS|DOORDASH
BULK QUANTITY FULLZ AVAILABLE
SPAMMING TOOLS & TUTORIALS (SMPT|RDP|C-PANLES|SHELLS)
Offering many stuff in discounted price
Fresh stuff will be provided NO SCAM
Payment in BTC|ETH|USDT
Here we're:
ICQ 752822040 | @killhacks
Telegram @killhacks | @leadsupplier
Email hacksp007@ mail 2 tor . com
Skype @peeterhacks
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