Thomas Piketty1 360x1000
4confidencegames
1defense
Adam Gopnik 360x1000
3defense
Maurice B Foley 360x1000
1paradide
Tad Friend 360x1000
Anthony McCann1 360x1000
Lafayette and Jefferson 360x1000
12albion
1madoff
399
299
Spottswood William Robinson 360x1000
2gucci
3albion
2albion
1empireofpain
199
George M Cohan and Lerarned Hand 360x1000
Margaret Fuller2 360x1000
Mary Ann Evans 360x1000
Office of Chief Counsel 360x1000
1lauber
2paradise
1trap
Ruth Bader Ginsburg 360x1000
1theleasofus
storyparadox3
Mark V Holmes 360x1000
9albion
Gilgamesh 360x1000
Thomas Piketty3 360x1000
1confidencegames
Margaret Fuller 360x1000
Margaret Fuller1 360x1000
499
Thomas Piketty2 360x1000
2confidencegames
Susie King Taylor 360x1000
1jesusandjohnwayne
James Gould Cozzens 360x1000
1falsewitness
11albion
8albion'
George F Wil...360x1000
1gucci
Margaret Fuller4 360x1000
Maria Popova 360x1000
5confidencegames
7albion
Margaret Fuller5 360x1000
2trap
lifeinmiddlemarch1
Storyparadox1
7confidencegames
3theleastofus
Samuel Johnson 360x1000
2defense
1lookingforthegoodwar
Margaret Fuller 2 360x1000
10abion
AlexRosenberg
2theleastofus
6albion
4albion
Betty Friedan 360x1000
1lafayette
14albion
Richard Posner 360x1000
2lafayette
6confidencegames
Learned Hand 360x1000
LillianFaderman
5albion
2lookingforthegoodwar
1albion
1transcendentalist
lifeinmiddlemarch2
2jesusandjohnwayne
2falsewitness
3confidencegames
Anthony McCann2 360x1000
3paradise
Edmund Burke 360x1000
Susie King Taylor2 360x1000
Margaret Fuller3 360x1000
11632
Stormy Daniels 360x1000
2transadentilist
Brendan Beehan 360x1000
storyparadox2
13albion
When Penalties Are Punitive They Are Not Tax Deductible

When Penalties Are Punitive They Are Not Tax Deductible

BI is a US corporation with a foreign subsidiary that is treated as a disregarded entity (DE).  DE’s executives and employees falsified books and records to cover up things of value given to government officials.  There were not adequate internal accounting and financial controls to detect and prevent corruption-related violations under the Foreign Corrupt Practices Act.  There are about two paragraphs worth of details redacted.  I’m sure they would make this post much more entertaining.

BI entered into a consent decree with the SEC to pay a disgorgement of profits from its FCPA violations.  Part of the deal was that they could not consent to the penalty while denying the allegations.  Then there was an agreement by DE with DOJ consenting to the filing of a Criminal Information and the paying of a monetary penalty for which no tax deduction could be taken.  The fine on DE that was paid by BI caused a dollar for dollar reduction in the disgorgement penalty on BI.

read more
Third Circuit Rules Grocery Store Chain Can Deduct Perks Sooner Rather Than Later

Third Circuit Rules Grocery Store Chain Can Deduct Perks Sooner Rather Than Later

By disallowing deductions claimed on the basis of established recurring expenses, the Tax Court effectively obliterated the distinction between two accounting methods expressly authorized by the Tax Code.The extent to which cash and accrual methods of accounting sometimes yield different deductions is a byproduct of the Tax Code’s design. So long as a taxpayer consistently adheres to one accounting method, the Code is agnostic as to the benefit or hardship wrought by his selection

read more

Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.