Tuesday, November 24, 2020
US District Court Welcome's IRS new Sec 965 wealth tax. Inside the horrible decision of Moore v. US
US District Court Welcome's IRS new Sec 965 wealth tax. Inside the horrible decision of Moore v. US
The US tax code is so complicated that US Federal Judges are wholly incompetent to adjudicate tax matters. That is the claim. But seriously, how smart should we expect federal judge to be? In fact, the judge who got the result in Moore v US is probably a VERY smart person. But he was no match for the utter density and complete disaster that the US Tax Code has devolved into. The judge was must have been completely oblivious to what he signed on to. Section 965 Transition Tax -What is it really? In 2018, the IRS imposed a tax on foreign corporations based upon assets the foreign corporations held. In this case, the asset tax was the foreign corporations’ Earnings and Profits. But the IRS did not hold the foreign corporations responsible for payment of the taxes, but rather, its US shareholders. It is important to note that “Earnings and Profits” are not the same thing as “Income.” “Earnings and Profits” are assets located on a balance sheet. Meanwhile income is calculated with an income statement. Taxes on assets are called property or wealth taxes. The Court in Moore didn’t even require the taxpayers to receive any money to pay this tax bill. You can be taxed on property that isn’t really yours, in a country where you don’t actually live that you must pay with income you never received. Section 965 of the US. And now we wonder. What could be worst than this? IRSMedic Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 https://youtu.be/BQd6YODiTIg IRS Medic
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