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Useful information on 501(c)(4)s and 527s and the IRS’s scrutiny dilemma

by Linda Beale

Useful information on 501(c)(4)s and 527s and the IRS’s scrutiny dilemma

A fellow tax professor at Loyola University, Ellen Aprill, has put together a useful powerpoint on the way political activity comes into play in deciding whether an organization is eligible for 501(c)(4) status or should instead be treated as a 527 organization that is required to disclose donors.

Download Aprill. Primer on political activity of 501(c)s and 527s. May 2013.

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Remember When the IRS Targeted Liberals?

by Linda Beale

Remember When the IRS Targeted Liberals?

Salon’s Alex Seitz-Wald has a story that provides additional context on the difficulty the IRS has in determining appropriate filters for political activity. See “When the IRS targeted liberals: Under George W. Bush, it went after the NAACP, Greenpeace, and even a liberal church,” Salon.com (May 14, 2013).

While few are defending the Internal Revenue Service for targeting some 300 conservative groups, there are two critical pieces of context missing from the conventional wisdom on the “scandal.” First, at least from what we know so far, the groups were not targeted in a political vendetta — but rather were executing a makeshift enforcement test (an ugly one, mind you) for IRS employees tasked with separating political groups not allowed to claim tax-exempt status, from bona fide social welfare organizations. Employees are given almost zero official guidance on how to do that, so they went after Tea Party groups because those seemed like they might be political. Keep in mind, the commissioner of the IRS at the time was a Bush appointee.

The second is that while this is the first time this kind of thing has become a national scandal, it’s not the first time such activity has occurred.

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How Apple avoids US taxes with shell games

by Linda Beale

How Apple avoids US taxes with shell games

Tomorrow’s Congressional hearing on the ability of major multinationals to shift profits offshore to avoid US tax (and everywhere-else tax) may finally get the attention of the American public onto a tax issue worth thinking about.

As today’s New York Times makes clear, Apple has used sophisticated tax planning to shift its assets offshore, often to employee-less shells that are run from Apple’s US headquarters. See Nelson Schwartz, Apple avoided billions in US taxes, Congressional panel says, New York Times (May 20, 2013).

Even as Apple became the nation’s most profitable technology company, it avoided billions in taxes in the United States and around the world through a web of subsidiaries so complex it spanned continents and surprised experts, a Congressional investigation has found.

Some of these subsidiaries had no employees and were largely run by top officials from the company’s headquarters in Cupertino, Calif., according to Congressional investigators. But by officially locating them in places like Ireland, Apple was able to, in effect, make them stateless – exempt from taxes, record-keeping laws and the need for the subsidiaries to even file tax returns anywhere in the world.

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How The Great Moderation Destroyed the Fed’s Credibility

Much ado is made of the Fed’s “credibility,” which is dog-whistle-speak for its ability, willingness, and decided inclination to jump all over any (expected or imagined) whiff of that horrifying threat — inflation! — especially the most terrifying bogeyman, “wage inflation.”

You won’t, on the other hand, find “credibility” discussed when people speak of the Fed’s inevitably weak-kneed inclination to raise inflation (expectations).

So after thirty years of diligently establishing its reputation for credibility, the Fed has no credibility. They announce on December 12 that they’ll allow inflation to go as high as 2.5% (shock! awe!). And what happens to inflation expectations?

Screen shot 2013-05-22 at 8.13.29 AM

Yes, it was a limp-wristed “promise”: they would only allow that irresponsibly dangerous hyperinflationary jump to 2.5% if unemployment remained above 6.5%. (Pick a mandate, any mandate. You know which one they’ll choose.)

So after three decades of diligently protecting responsible creditors from the manifest evils of inflation, and imposing responsibility on feckless, impatient entrepreneurial, risk-taking borrowers, nobody believes for an internet minute that the Fed can or will address the unemployment side of their mandate — that it has the wherewithal to do so, or the inclination if it did.

Got credibility?

Cross-posted at Asymptosis.

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Fed’s Dudley Agrees: QE is Not About the Reserves, or “Printing Money”

Or: “Dudley Makes Mock of the Monetarists.”

In my post The Fed is not “Printing Money.” It’s Retiring Bonds and Issuing ReservesI said:

…when the Fed gives the banks reserves and retires bonds, it’s taking on market risk/reward, replacing it with absolutely nonvolatile, risk/reward-free assets (at least in nominal terms). It’s removing leverage and volatility from the banking system.

And:

The banking system doesn’t “take money” out of total reserves, or reduce those reserves, to fund loans.

And now I find this in a speech today at the Japan Society by FRBNY President and CEO William Dudley (HT Matthew Klein). Emphasis mine:

asset purchases work primarily through the asset side of the balance sheet by transferring duration risk from the private sector to the central bank’s balance sheet.  This pushes down risk premia, and prompts private sector investors to move into riskier assets.  As a result, financial market conditions ease, supporting wealth and aggregate demand.  The fact that such purchases increase the amount of reserves in the banking system and the size of the monetary base is a byproduct — not the goal — of these actions.

Or to put it another way: when you increase M in MV = PY, the most likely result — the result you have to assume by default absent some convincing story about real-economy incentives, causes, and effects —  is a purely arithmetic decline in V (cf. Dudley’s “byproduct”), with zero effect on P or Y.

This is doubly true if by M you mean the Monetary Base (as monetarists do, inconsistently but often) — the only measure of money that includes reserve balances. Increasing the quantity of reserve balances (hence the monetary base) does not magically increase either P or Y.

Cross-posted at Asymptosis.

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The Internal Blue Cross/Blue Shield Revenue Service. Awesome!

“Since the I.R.S. also is the chief enforcer of Obamacare requirements, [Michele Bachmann] asked whether the I.R.S.’s admission means it ‘will deny or delay access to health care’ for conservatives. At this point, she said, that ‘is a reasonable question to ask.’ ”

— Bob Unruh, Why Obama Released Embarrassing IRS Bombshell, WND Exclusive, May 13

Yes, that’s right.  You read the title of this post correctly.  Obamacare turns out to be a single-payer healthcare insurance program, after all!

Or so says Michele Bachmann, anyway.  And she certainly would know.

This is great news, in my opinion.  But, I mean, who knew?  I’d thought until now that the only role that the IRS plays in Obamacare was to collect the penalty, via the tax apparatus, from individuals who aren’t insured through their (or a family member’s) employer and who choose to pay the penalty rather than buy insurance in the private market.  In other words, that the IRS role concerns only people who don’t have healthcare insurance, not people who do.

But apparently I was wrong.  I haven’t actually read the statute, which is infamously long, and somewhere in it, it requires all healthcare insurance premiums to be paid to the IRS.  The  name of which, once the full law kicks in next year, will be the Internal Blue Cross/Blue Shield Revenue Service.

Yes, the agency will still collect ordinary income taxes as it does now.  But it also become our healthcare insurer. Unless you are a conservative, in which case it will still require you or your employer to pay your insurance premiums to that agency. Or maybe just through that agency; I’m not sure which.  As I said, I haven’t read the statute, so I don’t know whether this will be like the Medicare system, or instead the agency will forward the premiums to your chosen private insurer, at least unless you’re a conservation, in which case the agency might use your premiums to pay for daycare for the young children of liberals.

Or maybe I’m misunderstanding completely, because of wishful thinking on my part.  Maybe instead, the statute requires the private insurance companies to get the agency’s approval before agreeing to pay a policyholder’s medical bills.

Yeah, that must be it.  The statute requires the private insurance companies to get the agency’s approval before agreeing to pay a policyholder’s medical bills. It’s odd, though, that three years after the statute’s enactment, this has never been mentioned before. By anyone.  Which makes that report about the Bachmann interview truly an exclusive.

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High Marginal Tax Rates are Associated with High GDP Growth

After hinting at it for months, I can finally post the abstract of and a link to

“Top Marginal Taxation and Economic Growth”

by my student Santo Milasi

The paper explores the relationship between statutory top marginal tax rates on personal income and long-run economic growth. While theoretical models of endogenous growth explicitly allow for nonlinear effects of taxation on economic growth, the majority of existing empirical studies assume a linear association. By contrast, this paper investigates both a linear and a non-monotonic relationship between top tax rates and GDP growth. Using a panel of 18 OECD countries over the period 1960-2009, this paper finds support in favor of a quadratic top tax-growth relationship. Results are robust to different model specifications and estimation techniques. The point estimates of the regressions suggest that the marginal effect of higher top tax rates becomes negative above a growth maximizing tax rate on the order of 60 percent. The quadratic relationship found for the whole sample period does not hold over the period 1975-2009. Instead, the link between top tax rates and GDP growth after 1975 is well summarized by a linear and positive top tax-growth relationship. Since top marginal tax rates after 1975 are well below the estimated growth maximizing level, such a result suggest that the top tax-growth relationship after 1975 might be placed on the upward-sloping side of the “growth-hill”. There is an even stronger positive top tax-growth relationship after 1985, when average top tax rates across OECD are lower than 50%.

 

update 2: new new link to a new pdf with less round off error in some calculations

 

 

Personally I think the null that there is any justification for the continued existence of the Republican party has now been rejected at standard confidence levels.  Your milage may vary.

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The Fed Is Not Printing Money: Two Updates

I’d like to reply to one confusion and one set of pushbacks on yesterday’s post:

Currency and Reserve Balances

I buried one fact: banks can reduce total Fed reserve balances by withdrawing currency — physical cash — from their Fed reserve accounts. I only gestured toward this in a parenthetical and a link. It’s a trivial point for this discussion, but it raises confusion. This is the other thing (besides bonds) that the Fed issues and retires in return for reserve balances. As with bonds, it’s purely an exchange between banks and the Fed (though it’s driven by customers’ cash needs).

Banks actually have nominal control over this. The Fed has to issue currency to them (retiring reserves in exchange) when they ask for it, and they have to retire currency (issuing reserve balances) when banks send it back.

But this in no way suggests that reserve balances are money. You can withdraw currency (notes) from your bank. Does that mean that your checking account contains currency? That checking deposits are currency? No.

This issue is unimportant here because it’s essentially a mechanical function. As long as it’s working properly — ATMs dispense cash and people can deposit cash — it has no effect on things. (And cash is pretty small magnitude in the total system). Banks keep enough cash on hand to handle their customers’ needs, and the Fed accomodates that. Aside from drug dealers, etc., nobody holds much physical currency.

The only reason cash would be an important consideration would be if the Fed starting paying (significant) negative interest on reserve balances — charging the banks to to hold their reserve deposits. Banks might decide to build secure warehouses and drive cash to and from the Fed, trading it for reserve balances, when they needed to fund loans or when loans got paid off. (It’s kinda tricky to fund a $400,000 mortgage with cash…)

Otherwise it’s a nonissue for this discussion. But I should have made it clear.

Whaddaya Mean by M, Buster?

People really don’t like the idea that the Fed’s not printing “money.” MV=PY adherents especially object.

Let’s look at the standard definitions. None of the monetary aggregate definitions M0 through MZM includes reserve balances. By those definitions, reserves are not money. (Ditto the divisia measures.) So by those definitions, when the Fed issues new reserves, it’s not “printing money.”

The one exception is the “Monetary Base,” or “base money.” That definition of money includes currency, coins, and reserves. Here’s a handy chart from Wikipedia:

Type of money M0 MB M1 M2 M3 MZM
Notes and coins in circulation (outside Federal Reserve Banks and the vaults of depository institutions) (currency) [8]
Notes and coins in bank vaults (Vault Cash)
Federal Reserve Bank credit (required reserves and excess reserves not physically present in banks)
Traveler’s checks of non-bank issuers
Demand deposits
Other checkable deposits (OCDs), which consist primarily of Negotiable Order of Withdrawal (NOW) accounts at depository institutions and credit union share draft accounts. [9]
Savings deposits
Time deposits less than $100,000 and money-market deposit accounts for individuals
Large time deposits, institutional money market funds, short-term repurchase and other larger liquid assets[10]
All money market funds

So fine: M in the equation of exchange means Base Money. But if you look at the data using that definition, it seems like there’s some serious explainin’ to do. Here’s the velocity of MB:

A 60+% decline since 2008? Hmm…

Cross-posted at Asymptosis.

 

 

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