philiphodgen

1. Why am I hearing this?

2. Why am I hearing this NOW?

Try to drop your pre-existing beliefs about the topic for a moment (rich people bad, FedBots evil, etc) and ask why this attempt at persuasion has been brought to your attention.

Who benefits from the agitation that occur in your mind when you read this?

Source: am a lawyer.

Extreme privacy is extremely expensive and permanently lifestyle-altering.

Take your strategic and tactical cues from Cold War-era spycraft and from current-day hyperparanoid internet security practices.

I was in DC on a boondoggle maybe 15 years ago and had a meeting with an old-time staffer (and lawyer) for the Senate Finance Committee. Attached to the Democrat side of the SFC for what it’s worth.

He had been on the tax policy scene long enough to see the pre-1976 carryover basis days and the post-1976 step-up basis days.

He was adamant that a return to carry-over basis would be a shitshow for IRS administrative purposes and fervently argued for the current step-up at death law.

This is a Chesterton’s Fence situation.

The collective “we” seem to forget that many of these ideas have been tried before. This “soak the rich” idea (look at the CRS report and see the reference to an exemption for the little guy so we can tax the billionaire) is one such idea.

The other idea — floated by our current president — is to crank up the capital gains tax rate. This one has been tried (and reversed) before. It would be instructive to find out what those politicians Back In The Day were thinking when the capital gains tax rate went up and why it went down again.

A little bit of humility and history might save some optional wounds.

Loans must be interest-bearing. This makes your life as an entrepreneur more complex. Your tax return and the corporate tax return will cost more to prepare.

Optimize for simplicity in legal structure, bookkeeping, and tax return preparation.

(1) Why corporation?

(2) Why C corporation?

(3) Unless you’re injecting multiple millions of your own money into your new venture, whatever perceived tax benefit you can imagine will be dwarfed by the overhead and cognitive opportunity cost of getting clever.

(4) If you add investors, the first thing they’ll want to do is clear all the bullshit off your balance sheet. Why add it in the first place?

Just contribute capital, unless you can think of a damn good reason to do otherwise.

You need real tax advice. Go get some.

Is this sudden oh-so-close-to-libel wave of stories coordinated? Or is it a viral pile-on sparked by someone, somewhere?

Truly, these stories say more about the storyteller than they do about Elon Musk.

Cui bono?

Status with an airline is useful for (a) free upgrades, (b) lounge access, and (c) better phone service when you need to fix things.

I have Diamond status on Delta. (Top tier before their invite-only tier).

Upgrades. The only value I get out of it is that I can book a generic economy seat and immediately get upgraded to Comfort+ for free. I rarely get upgrades to First Class since Delta sells out the seats to real people for real money. I'm frequently #1 of a bunch of people on the upgrade list for nonexistent First Class seats.

Lounge access. I have the Delta Reserve Amex card that gets me into the lounges anyway.

Phone service. This is really an indictment of the shit service that airlines give. For a while, even with the priority phone service I would be on hold for an hour or so. It's far better now, admittedly.

Delta is making it drastically harder to achieve status in 2024. In all probability I am going to go free agent and fly any airline that gets me where I want to go, when I want to go, at a reasonable price.

The airline miles are useful. I don't think I've paid for a flight for my kids with money once in all the years they've been at university in other states. But that's just a "charge enough money on a credit card" thing. It has nothing to do with status.

Paste the URL in a comment.

Reason: U.S. tax reporting requirements create high accounting costs.

Your problem is not “controlled foreign corporation” status. That’s only for U.S. persons who are shareholders of non-U.S. corporations.

Your primary tax returns will be Form 1120 (the income tax return for a corporation) and Form 5472 (required when a U.S. corporation has at least one non-U.S. shareholder owning 25%+ of the stock).

Form 5472 is the anti-transfer pricing form used by the U.S. tax system to make sure that taxable income remains in the USA to get taxes. Penalties for screwing this up are steep: $25,000.

This means you will want to hire competent tax professionals. Competent U.S. international tax specialists tend to be rare and expensive.

Your tax reporting will also get more complicated in Germany.

I am a big believer in doing things correctly. Future You will reap the rewards that Today You made possible through hard work and solid foundations. Life is a marathon with no finish line.

That said, there are different gradients of “correct” at each stage of business growth.

I don’t know where you are now. I don’t know your revenue, your business needs, your product, where your customers are, whether you will hold this business forever or are building to be acquired, etc.

I will give you a data point for you to make a management decision, because this is a management decision and not an engineer decision. You are making a decision with significant opportunity cost to it, even if it is the correct decision.

Here you go. Money. Order of magnitude for a tax return for a simple U.S. corporation with ownership as you describe and minimal transactions between you and the corporation and the corporation and the outside world. $10,000. Reason: Form 5472. That’s the peak of the bell curve.

Opportunity cost of time and brain damage. 40 hours of your time per year (or pay someone and buy their time). You could be building a product or creating new customers.

At some point you need the infrastructure. Choosing the right time to buy it? That’s hard and there is no right answer.

Source: am international tax lawyer.

Standard legal waiver/disclaimer/pre-emptive strike/warning shot applies: I’m an idiot and I am not your lawyer, so this is not legal advice and if you think it is, you are an idiot.

1. How do I know you are who you say you are? (You don't identify yourself).

2. How do I know that you will do what you say you will do? (The website says says nothing).

3. How do I know that all spammers, worldwide, will do what you tell them to do and delete my email address from their databases permanently and forever? (Are you God?)

I'm sorry, but color me skeptical. Here's what I would want to see before accepting your offer:

A. Tell me who you are.

B. Tell me why I should trust you.

C. Tell me what you will do for me.

D. Tell me why you will succeed while Google, Barracuda, and countless other juggernauts have failed to keep spam out of my inbox.

"They sell you the benefits and give you the harms for free."

Your HN post sells me the benefits (no spam). That means you're giving me the harm for free. I don't know what harm is bundled with your benefits, so I will pass on buying the benefits.

My interpretation is that “strategy” as he defines it is an exercise in human whimsy. “I choose to play in this playing field.” “My theory for why I can achieve the objective — which is inherently outside my control — is xyz.” In other words, strategy is first a moment of creation. Ex nihilo.

After selecting a strategy the AI berserkers* take over and relentlessly and pitilessly drive you forward to Total World Domination.

So I guess what I’m saying is: I don’t understand how AI participates in that “In the beginning . . . “ creation of a strategy. Unless, of course, AI is God.

What am I not seeing?

* when I read all of the breathless doomer “AI is going to eat babies” articles online I am reminded of Fred Saberhagen’s Berserker series.

Thanks for posting this.

This is an effort at political persuasion, just as the concept of “tax gap” is a deliberately manufactured effort of political persuasion by the government. It’s a great phrase to focus your attention on something, isn’t it? Ask yourself what you’re focusing on, and whose interests are served by directing your focus.

In a sense, this article is correct. The only thing that matters is whether I have a dollar in my pocket to spend on anything I want.

From a different perspective, I am converting an irreplaceable hour of my brief existence into money so I can eat and sleep in a warm, dry place. This author is telling me to ignore the gauntlet of pickpockets (government included) that make my quest harder.

Hell, no. I will keep my eyes wide open. Just as I, as a business owner, keep my eyes wide open on my financial statements, from gross revenue and pricing to net after-tax profit.

Yes, after-tax profit is the only thing I can use to go buy a hamburger. But I don’t ignore everything else upstream from that.

The Ghost of Bernays is hard at work with this article.

I'm not saying whether interference occurred or not and I don't know whether CBC knows the answer, either. I'm just seeing CBC's opportunity for manipulating public opinion.

- Why am I hearing this?

- Why am I hearing this now?

Verdict: noise, not signal.

* Data in some mysterious location "in the browser" with a promise of future export capability which will be delivered at the worst possible time of a product's life-cycle: when the company is dying.

* Data in plain text on my computer right now and always.

No aspersions cast on either company's people, intentions, goodwill, or the products' (Roam and Recall) quality and value. It's just that "I own my own life" is an organizing principle that I violate at my peril. My life is more important to me than your app.

As for the comment "ideas are cheap and execution is everything," I'm not sure how to connect that question to the success/failure of recall-app.com. The IF/THEN does not compute in my brain.

And yeah, the [[keyword]] thing is something I'd like to replicate in my knowledge base. It would make life easier for the users, and thereby increase the likelihood that they'll, y'know, actually use the knowledge base.

You should be proud of your accomplishment. Even I, an international tax lawyer with negligible programming exposure (i.e., decades ago), was able to successfully get Docusauras installed and operational on my MacBook. :-)

I have considered using Obsidian Publish. My objective is to build an internal knowledge base: SOPs for a business. It won't be publicly visible. Obsidian Publish would require me to password protect the site, and that's an unacceptable addition of friction to day-to-day use.

Collaborative editing is the other problem to solve. In my world, "here's the repo on Github" draws blank stares. I have to use Google Docs or endless iterations of Word files.

Nobody will actually use an SOP in a Google Doc online, of course, and the trove of Word files on our server collects dust.

That's why a website (built using Docusaurus or similar) appears to be the best way to reduce friction and inertia. The path of least resistance should be the website full of SOPs, not "I remember how this works" or "I'll just re-invent the wheel."

I sympathize with your plight and I'm busily trudging along a parallel path.

Because you don't know where to look, or what you're seeing.

Source: am tax lawyer. In California. Have seen and helped individuals with hundreds of millions in annual income escape to other places.

https://www.youtube.com/watch?v=THU9zfWCUr0 (Sistine Chapel Choir).

Make a to do list of the tasks you are attempting to achieve today. Do one thing only today. When it is all too overwhelming, break it down into tiny self-evident steps. Micromanage your brain.

Not too much coffee.

Without a doubt you need to make a drive up 395 on the Eastern side of the Sierra Nevada. Stop in Bishop at Mahogany. Get some jerky. Hint: the habanero is HOT!

This is the real deal. No industrial processed BS.

Continue driving north to Lee Vining. Eat at Mono Cone. Look across Mono Lake to where High Plains Drifter was filmed. Go further north to Bodie. (You have already eaten all of your jerky, because you didn’t buy enough).

Or just get mail order deliveries. Not quite the same. But excellent nonetheless.

Greetings from Mammoth Lakes, CA.

Flagged. Avoid this link.

Usually, when you want your financials vetted you go to an accounting firm. I find it curious that they chose a law firm — with some PR-value name like Louis Freeh attached to it. Celebrity endorsement?

Why not get a proper audit by Ernst & Young, Deloitte or PwC?

We don’t see mutual fund financials vetted by law firms. Tether is a type of money-market fund.

It doesn’t add up. People behaving strangely . . . .

Chesterson’s Fence.

Having said that, I am a tax lawyer and I view the output of the Federal government as astonishingly bad. Poorly-written laws cause millions or billions of dollars of friction to taxpayers.

There are many reasons for why laws are written so poorly:

- the people are stupid or malicious or lazy (appealing but this conclusion reveals more about its holder than its object)

- the task of writing the law is impossible

- the people writing the law are technically deficient in this style of writing

I’m sure you can think of others.

There is another factor. After you have been a lawyer for a long time, you see the folly of believing it is possible to write binary yes/no rules to govern human behavior. Politicians believe this. An economist would call this a belief in a static economic model.

Thus, politicians think “we will impose this tax and collect a lot of money”. Then they are shocked because people change their behavior and avoid paying the tax. I do not mean maliciously. I mean like a toll-road. Imposing a toll for driving on a road will affect the traffic patterns and fewer people will drive on the road. Less money will be collected. Economists think that way. Politicians are not as . . . astute. (That statement reveals more about me than it reveals about politicians as a group). :-)

Back to why laws are so badly written. There is a second reason and it is mentioned in another comment. Lawyers and judges are comfortable with ambiguity. In tax law, we often ask for penalties to be waived for “reasonable cause”. WTF is that? Yet it (more or less) works. At the margin, some people get away with stuff that “should” be penalized. And some people are penalized “unjustly”.

This discovery in law is the result of centuries of evolution. It works. So if you see ambiguity, understand that it is a feature, not a bug.

But for tax law, quite often I think of the rules as a broken set of algebra rules written by teenage sociology majors while drunk, for bribes. Over decades. Again, this reveals more about me than the United States Code and the Treasury Department.

1. Own property.

2. Borrow big bag of cash from Bad Guy.

3. Gamble or spend the cash.

4. Pay back the loan from clean sources.

I understand it, but I guess I have never dealt with the KYC people at a casino. I still see obvious choke points (for the conversion of drug-laden currency into gambling chips, for instance) at which Explanations Must Be Made, but perhaps there are channels that I do not know about.

Let’s just say my experiences with the KYC systems have been rigorous.

1. Bad person sells drugs for cash.

2. Bad person has cash.

3. Bad person lends borrower cash to buy real estate.

Step 3 is the mystery.

— Bad person could give a bag of cash to the borrower. Now the borrower has a banking problem. How does that cash get into a bank account so the real estate purchase can happen?

— Bad person masquerading as a legit lender could give a bag of cash to the seller at closing. Now the seller has a banking problem.

— Bad person masquerading as a lender can give a bag of cash to the closing agent who is facilitating the real estate transaction. Now the closing agent has a banking problem.

There will be a huge pile of cash that must somehow enter the banking system. Someone must do this. How does it happen?

And no it doesn’t not suffice to tell the seller or the closing agent “I brought a giant bag of Canadian currency with me when I flew in from China to buy this property.” Banks didn’t fall off the back of the turnip truck yesterday.

As the article notes, this is a money laundering problem. But the article postulates a moment of magic — the moment where a bag of tainted cash becomes a recorded mortgage lien on real estate.

I’m saying this as an international tax lawyer who has structured hundreds of millions of dollars of US real estate purchase by foreigners. Maybe I just deal with legit people. We always get wire transfers from real banks, whether the investment is debt or equity.

Export can be to text or Markdown. No need to be fancy.

This would replace Evernote for me. It looks better and organization is better (compare RexPad to Evernote’s stacks and notebooks, which are difficult to work with).