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Invisiblememes
Blessed


Folding@home Statistics
Registered: 01/11/05
Posts: 27,785
Loc: In a Tree
Re: Obama's Auto Industry Success [Re: imachavel]
    #14603823 - 06/13/11 12:23 AM (12 years, 11 months ago)

Quote:

imachavel said:
Quote:

meams said:
Wow you're dumb.  You realize typically one parent dies first, right?  So mom dies, dad assumes full value of the family wealth.  Dad dies, any assets over $1,000,000 get taxed at 55%.


you think you're so smart, 'eh?  Sucks when you actually start THINKING about things.




don't some people leave the country to avoid this tax? i guess that's criminal or some shit, and you can never return to the country you flee from. I don't know I'll stop here while I'm ahead but god damn that is some serious tax.

obama hasn't done shit to stop that huh?



to STOP that?  Lol, liberals by and large wish the estate tax was as big as possible.  republicans by and large want to eliminate the estate tax.  it is extremely hard on family businesses & farms.  small businesses make up more than 50% of jobs in this nation, by the way.

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: memes]
    #14603892 - 06/13/11 12:42 AM (12 years, 11 months ago)

Quote:

meams said:
Quote:

ShroomyJohn said:
But only someone with no knowledge of estate planning would leave all the wealth to your father.

We're still not getting to the real problem, you keep thinking you're any sort of wealthy, and keep buying into the hype that you keep getting spoon fed by whoever is feeding you, and continue your ignorant ways until your grandkids are broke as shit and our country is ruled by the aristocrats.



why do you think i think i'm wealthY?  why do you care so much whether or not i think i'm wealthy?  Why are you so far up my ass?





I'm not the one saying you're wealthy.  In fact, I've said quite the contrary But you're getting defensive, which means I'm touching something sensitive.

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: memes]
    #14603903 - 06/13/11 12:44 AM (12 years, 11 months ago)

Quote:

meams said:
Quote:

imachavel said:
Quote:

meams said:
Wow you're dumb.  You realize typically one parent dies first, right?  So mom dies, dad assumes full value of the family wealth.  Dad dies, any assets over $1,000,000 get taxed at 55%.


you think you're so smart, 'eh?  Sucks when you actually start THINKING about things.




don't some people leave the country to avoid this tax? i guess that's criminal or some shit, and you can never return to the country you flee from. I don't know I'll stop here while I'm ahead but god damn that is some serious tax.

obama hasn't done shit to stop that huh?



to STOP that?  Lol, liberals by and large wish the estate tax was as big as possible.  republicans by and large want to eliminate the estate tax.  it is extremely hard on family businesses & farms.  small businesses make up more than 50% of jobs in this nation, by the way.






B.U.L.L.S.H.I.T.

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Offlineimachavel
I loved and lost but I loved-ftw
Male User Gallery


Registered: 06/06/07
Posts: 31,564
Loc: You get banned for saying that Flag
Last seen: 21 minutes, 3 seconds
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14603931 - 06/13/11 12:52 AM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
Quote:

meams said:
Quote:

ShroomyJohn said:
But only someone with no knowledge of estate planning would leave all the wealth to your father.

We're still not getting to the real problem, you keep thinking you're any sort of wealthy, and keep buying into the hype that you keep getting spoon fed by whoever is feeding you, and continue your ignorant ways until your grandkids are broke as shit and our country is ruled by the aristocrats.



why do you think i think i'm wealthY?  why do you care so much whether or not i think i'm wealthy?  Why are you so far up my ass?





I'm not the one saying you're wealthy.  In fact, I've said quite the contrary But you're getting defensive, which means I'm touching something sensitive.





you are touching his feelings :heart::blush::crazy:


--------------------
:kingcrankey: I did not say to edit my signature soulidarity! Now forever I will never remember what I said about understanding the secrets of the universe by paying attention to subtleties!

:facepalm: I'm never giving you the password again. Jerk

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Offlineimachavel
I loved and lost but I loved-ftw
Male User Gallery


Registered: 06/06/07
Posts: 31,564
Loc: You get banned for saying that Flag
Last seen: 21 minutes, 3 seconds
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14603942 - 06/13/11 12:55 AM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
Quote:

meams said:
Quote:

imachavel said:
Quote:

meams said:
Wow you're dumb.  You realize typically one parent dies first, right?  So mom dies, dad assumes full value of the family wealth.  Dad dies, any assets over $1,000,000 get taxed at 55%.


you think you're so smart, 'eh?  Sucks when you actually start THINKING about things.




don't some people leave the country to avoid this tax? i guess that's criminal or some shit, and you can never return to the country you flee from. I don't know I'll stop here while I'm ahead but god damn that is some serious tax.

obama hasn't done shit to stop that huh?



to STOP that?  Lol, liberals by and large wish the estate tax was as big as possible.  republicans by and large want to eliminate the estate tax.  it is extremely hard on family businesses & farms.  small businesses make up more than 50% of jobs in this nation, by the way.






B.U.L.L.S.H.I.T.





Bogus Unreal yet Literate Lies Shoveled in Heaps to Initiate Truthslander

:shrug:


--------------------
:kingcrankey: I did not say to edit my signature soulidarity! Now forever I will never remember what I said about understanding the secrets of the universe by paying attention to subtleties!

:facepalm: I'm never giving you the password again. Jerk

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InvisiblePrisoner#1
Even Dumber ThanAdvertized!
 User Gallery

Registered: 01/22/03
Posts: 193,665
Loc: Pvt. Pubfag NutSuck
Re: Obama's Auto Industry Success [Re: Falcon91Wolvrn03]
    #14603979 - 06/13/11 01:03 AM (12 years, 11 months ago)

Quote:

Falcon91Wolvrn03 said:
Quote:

Prisoner#1 said:
Quote:

The White House says the data to back this claim concerning the Big Three automakers is not public information. The official Bureau of Labor Statistics data refers to the entire auto industry — including foreign auto manufacturers, auto parts manufacturers, auto parts dealers and auto dealers. If you look at the data, the 113,200 jobs added between June 2009 and May 2011 amounts to about a 5 percent increase — from a rather low base.




so as we can see, the bulk of the hiring is outside of the country, and this means obama created how many jobs? how many american jobs were created?



The Bureau of Labor Statistics only tracks American jobs.  The 113,200 jobs created were American workers, regardless of parent company.





and just what companies hired these 100,000 people especially when sales
are down and announcements of plant closures, some how these numbers just
dont add up
http://biggovernment.com/capitolconfidential/2011/06/03/white-house-auto-industry-jobs-up-time-for-a-change/
http://www.versustwin.com/automotive-news/auto-plant-closures.html

Quote:

Quote:

Prisoner#1 said:
so the tax payer should be forced to foot the bill for products they have no faith in



If you followed the discussion, you'd realize that the American taxpayer got their money back.  That beats paying unemployment for $1.4 million people in my mind.  :shrug:





http://www.csmonitor.com/USA/Politics/2011/0604/Obama-touts-auto-industry-recovery-while-GOP-asks-What-jobs

let's ask ourselves, how employers continue to add so many jobs yet unemployment rises

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: Prisoner#1]
    #14604008 - 06/13/11 01:14 AM (12 years, 11 months ago)

We could ask the GOP the same question? Where are the jobs they promised?  The first thing they did was talk about jobs to win the 2010 election?  Try to repeal health care, try to ban abortion, try to ban gay marriage... etc etc.  What have they done for jobs? 

Besides threaten to filibuster legislation to prevent outsourcing of course...

Are you really asking how unemployment can rise, because some people are being hired doesn't mean more aren't losing their jobs...

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InvisiblePrisoner#1
Even Dumber ThanAdvertized!
 User Gallery

Registered: 01/22/03
Posts: 193,665
Loc: Pvt. Pubfag NutSuck
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14604398 - 06/13/11 02:51 AM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
We could ask the GOP the same question? Where are the jobs they promised?  The first thing they did was talk about jobs to win the 2010 election?  Try to repeal health care, try to ban abortion, try to ban gay marriage... etc etc.  What have they done for jobs? 




contrary to the claims of obama, outside of government, politicians cant
create jobs, they can only provide a favorable climate. how has the obama
administration or the democrat controlled congress provided that favorable
climate in the first 2 years? I guess to you the republicans should have
shat jobs for the last 6 months

Quote:

Besides threaten to filibuster legislation to prevent outsourcing of course...




so you believe that we should be outsourcing the jobs



Quote:

Are you really asking how unemployment can rise, because some people are being hired doesn't mean more aren't losing their jobs...




how very astute, so while the auto industry has put 113,000 people to work
it's hemorrhaged 130,000 jobs... sure sounds like that obama math has
payed off with job creation

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OfflinePileusSonofGalt
PhungiPharmer
Male

Registered: 05/19/11
Posts: 240
Last seen: 12 years, 2 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14604502 - 06/13/11 03:22 AM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
But only someone with no knowledge of estate planning would leave all the wealth to your father.

We're still not getting to the real problem, you keep thinking you're any sort of wealthy, and keep buying into the hype that you keep getting spoon fed by whoever is feeding you, and continue your ignorant ways until your grandkids are broke as shit and our country is ruled by the aristocrats.




So how is he being spoon fed hype? I realize the more I read your posts you will not hold firm to a belief and when questioned you resolve to name calling and arguing semantics. Way to bring intelligent discussion to the table.

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: PileusSonofGalt]
    #14606674 - 06/13/11 02:37 PM (12 years, 11 months ago)

Quote:

Prisoner#1 said:

Quote:

Besides threaten to filibuster legislation to prevent outsourcing of course...




so you believe that we should be outsourcing the jobs






I know you're better than that.

Quote:

PileusSonofGalt said:
Quote:

ShroomyJohn said:
But only someone with no knowledge of estate planning would leave all the wealth to your father.

We're still not getting to the real problem, you keep thinking you're any sort of wealthy, and keep buying into the hype that you keep getting spoon fed by whoever is feeding you, and continue your ignorant ways until your grandkids are broke as shit and our country is ruled by the aristocrats.




So how is he being spoon fed hype? I realize the more I read your posts you will not hold firm to a belief and when questioned you resolve to name calling and arguing semantics. Way to bring intelligent discussion to the table.




Just trying to get on your level.    :tard:

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Offlinezappaisgod
horrid asshole


Registered: 02/11/04
Posts: 81,741
Loc: Fractallife's gym
Last seen: 7 years, 11 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14606762 - 06/13/11 02:52 PM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
Quote:

Prisoner#1 said:

Quote:

Besides threaten to filibuster legislation to prevent outsourcing of course...




so you believe that we should be outsourcing the jobs






I know you're better than that.





I gotta see this one.  ShroomyJohn, just how would you go about writing a piece of legislation that would prevent outsourcing jobs?  You don't have to get specific but what do you suppose the rough outline would be?


--------------------

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: zappaisgod]
    #14606824 - 06/13/11 03:03 PM (12 years, 11 months ago)

It would probably go something like this


Calendar No. 578
111th CONGRESS
2d Session
S. 3816
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
IN THE SENATE OF THE UNITED STATES
SEPTEMBER 21, 2010
Mr. DURBIN (for himself, Mr. REID, Mr. SCHUMER, Mr. DORGAN, Mrs. BOXER, Mr. BROWN of Ohio, and Mr. LEAHY) introduced the following bill; which was read the first time
SEPTEMBER 22, 2010
Read the second time and placed on the calendar
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘Creating American Jobs and Ending Offshoring Act’.
TITLE I--INCENTIVES TO CREATE AMERICAN JOBS
SEC. 101. PAYROLL TAX HOLIDAY FOR EMPLOYERS MOVING JOBS TO THE UNITED STATES FROM OVERSEAS.
(a) In General- Section 3111 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(e) Special Exemption for Certain Individuals Hired to Replace Employees Whose Jobs Were Overseas-
‘(1) IN GENERAL- Subsection (a) shall not apply to wages paid by a qualified employer with respect to employment during the applicable 24-month period with respect to any qualified replacement individual for services performed--
‘(A) in a trade or business of such qualified employer, or
‘(B) in the case of a qualified employer exempt from tax under section 501(a), in furtherance of the activities related to the purpose or function constituting the basis of the employer’s exemption under section 501.
‘(2) QUALIFIED EMPLOYER- For purposes of this subsection, the term ‘qualified employer’ has the meaning given such term by subsection (d)(2).
‘(3) QUALIFIED REPLACEMENT INDIVIDUAL- For purposes of this subsection--
‘(A) IN GENERAL- The term ‘qualified replacement individual’ means any individual--
‘(i) who begins employment with a qualified employer after September 21, 2010, and before September 22, 2013,
‘(ii) with respect to whom the qualified employer certifies that such individual has been employed by the qualified employer to replace another employee--
‘(I) who was not a citizen or lawfully present resident of the United States, and
‘(II) substantially all of whose services for the employer were performed outside of the United States,
‘(iii) with respect to whom the qualified employer certifies that substantially all of the services the individual will perform for the employer will be performed within the United States, and
‘(iv) who is not an individual described in section 51(i)(1) (applied by substituting qualified employer for taxpayer each place it appears).
For purposes of this paragraph, only 1 individual may be treated as a qualified replacement individual with respect to any employee described in clause (ii) being replaced by the qualified employer. Any certification under clause (ii) or (iii) shall be made by signed affidavit, under penalties of perjury.
‘(B) EMPLOYER- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single employer for purposes of subparagraph (A)(ii), except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of such section.
‘(4) APPLICABLE 24-MONTH PERIOD- For purposes of this subsection, the term ‘applicable 24-month period’ means, with respect to any qualified replacement individual of a qualified employer, the 24-month period beginning on the hiring date of such individual by the employer.
‘(5) ELECTION- A qualified employer may elect to have this subsection not apply. Such election shall be made in such manner as the Secretary may require.
‘(6) SPECIAL RULE FOR THIRD CALENDAR QUARTER OF 2010-
‘(A) NONAPPLICATION OF EXEMPTION DURING THIRD QUARTER- Paragraph (1) shall not apply with respect to wages paid during the third calendar quarter of 2010.
‘(B) CREDITING OF FIRST QUARTER EXEMPTION DURING FOURTH QUARTER- The amount by which the tax imposed under subsection (a) would (but for subparagraph (A)) have been reduced with respect to wages paid by a qualified employer during the third calendar quarter of 2010 shall be treated as a payment against the tax imposed under subsection (a) with respect to the qualified employer for the fourth calendar quarter of 2010 which is made on the date that such tax is due.
1
‘(7) REGULATIONS- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this subsection, including regulations necessary to prevent the avoidance of such purposes through the transfer and retransfer of employees within and without the United States or otherwise.’.
(b) Coordination With Work Opportunity Credit- Section 51(c) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph:
‘(6) COORDINATION WITH PAYROLL TAX FORGIVENESS OF QUALIFIED REPLACEMENT INDIVIDUALS- The term ‘wages’ shall not include any amount paid or incurred to a qualified replacement individual (as defined in section 3111(e)(3)) during the 2-year period beginning on the hiring date of such individual by an employer unless such employer makes an election not to have section 3111(e) apply.’.
(c) Transfers to Federal Old-Age and Survivors Insurance Trust Fund- There are hereby appropriated to the Federal Old-Age and Survivors Trust Fund and the Federal Disability Insurance Trust Fund established under section 201 of the Social Security Act (42 U.S.C. 401) amounts equal to the reduction in revenues to the Treasury by reason of the amendments made by subsection (a). Amounts appropriated by the preceding sentence shall be transferred from the general fund at such times and in such manner as to replicate to the extent possible the transfers which would have occurred to such Trust Fund had such amendments not been enacted.
(d) Effective Date- The amendments made by this section shall apply to wages paid after September 21, 2010.
TITLE II--DISINCENTIVES TO MOVING AMERICAN JOBS OVERSEAS
SEC. 201. DISALLOWANCE OF DEDUCTION, LOSS, OR CREDIT FOR CERTAIN ITEMS INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
(a) In General- Part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:
‘SEC. 280I. EXPENDITURES INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
‘(a) Disallowance- No deduction, loss, or credit shall be allowed under this title for any taxable year for any disallowed amount.
‘(b) Disallowed Amount- For purposes of this section--
‘(1) IN GENERAL- The term ‘disallowed amount’ means any amount which is paid or incurred during the taxable year which is properly allocable to an American jobs offshoring transaction.
‘(2) LOSSES- Such term shall include any loss from any sale, exchange, abandonment, or other disposition of property in connection with an American jobs offshoring transaction.
‘(3) EXCEPTION FOR COSTS RELATED TO DISPLACED WORKERS- Such term shall not include any amount paid or incurred for assistance to employees within the United States whose jobs are being lost as part of an American jobs offshoring transaction, including any severance pay, outplacement services, or employee retraining.
‘(c) American Jobs Offshoring Transaction- For purposes of this section--
2
‘(1) IN GENERAL- The term ‘American jobs offshoring transaction’ means any transaction (or series of transactions) in which the taxpayer reduces or eliminates the operation of a trade or business (or line of business) within the United States in connection with the start up or expansion of such trade or business (or such line of business) by the taxpayer outside of the United States.
‘(2) EXCEPTION- A transaction (or series of transactions) shall not be treated as an American jobs offshoring transaction if the taxpayer establishes to the satisfaction of the Secretary that such transaction (or series of transactions) will not result in the loss of employment for employees of the taxpayer within the United States.
‘(d) Aggregation Rule- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single taxpayer for purposes of this section, except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of section 52.
‘(e) Regulations- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations necessary to prevent the avoidance of such purposes and the application of this section in the case of mergers, acquisitions, and dispositions and in the case of contract employees.’.
(b) Conforming Amendment- The table of sections for part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:
‘Sec. 280I. Expenditures incurred in moving American jobs offshore.’.
(c) Effective Dates-
(1) IN GENERAL- The amendments made by this section shall apply to transactions occurring after the date of the enactment of this Act.
(2) EXCEPTION FOR EXISTING TRANSACTIONS- The amendments made by this section shall not apply to transactions occurring after the date of the enactment of this Act if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or the Secretary’s delegate that on or before such date the taxpayer publicly identified the transaction in sufficient detail that the nature and scope of the transaction could be identified.
SEC. 202. TAXATION OF INCOME OF CONTROLLED FOREIGN CORPORATIONS ATTRIBUTABLE TO IMPORTED PROPERTY PRODUCED BY EMPLOYEES IN AMERICAN JOBS MOVED OFFSHORE.
(a) General Rule- Subsection (a) of section 954 of the Internal Revenue Code of 1986 (defining foreign base company income) is amended by striking the period at the end of paragraph (5) and inserting ‘, and’, by redesignating paragraph (5) as paragraph (4), and by adding at the end the following new paragraph:
‘(5) imported property offshored income for the taxable year (determined under subsection (j) and reduced as provided in subsection (b)(5)).’.
(b) Definition of Imported Property Offshored Income- Section 954 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(j) Imported Property Offshored Income-
‘(1) IN GENERAL- For purposes of subsection (a)(5), the term ‘imported property offshored income’ means offshored income (whether in the form of profits, commissions, fees, or otherwise) received from a controlled foreign corporation and derived in connection with--
‘(A) manufacturing, producing, growing, or extracting imported property;
‘(B) the sale, exchange, or other disposition of imported property; or
‘(C) the lease, rental, or licensing of imported property.
Such term shall not include any foreign oil and gas extraction income (within the meaning of section 907(c)) or any foreign oil related income (within the meaning of section 907(c)).
‘(2) IMPORTED PROPERTY- For purposes of this subsection--
‘(A) IN GENERAL- Except as otherwise provided in this paragraph, the term ‘imported property’ means property which is imported into the United States by the offshored controlled foreign corporation or a related person.
‘(B) IMPORTED PROPERTY INCLUDES CERTAIN PROPERTY IMPORTED BY UNRELATED PERSONS- The term ‘imported property’ includes any property imported into the United States by an unrelated person if, when such property was sold to the unrelated person by the controlled foreign corporation (or a related person), it was reasonable to expect that--
‘(i) such property would be imported into the United States; or
‘(ii) such property would be used as a component in other property which would be imported into the United States.
‘(C) EXCEPTION FOR PROPERTY SUBSEQUENTLY EXPORTED- The term ‘imported property’ does not include any property which is imported into the United States and which--
‘(i) before substantial use in the United States, is sold, leased, or rented by the controlled foreign corporation or a related person for direct use, consumption, or disposition outside the United States; or
‘(ii) is used by the offshored controlled foreign corporation or a related person as a component in other property which is so sold, leased, or rented.
‘(D) EXCEPTION FOR CERTAIN AGRICULTURAL COMMODITIES- The term ‘imported property’ does not include any agricultural commodity which is not grown in the United States in commercially marketable quantities.
‘(3) OFFSHORED INCOME- For purposes of this section, the term ‘offshored income’ means income described in paragraph (1) that is directly or indirectly derived from the operation of a trade or business (or line of business) which was started or expanded outside the United States as part of an American jobs offshoring transaction (as defined in section 280I(c)) to which the provisions of section 280I apply.
‘(4) DEFINITIONS AND SPECIAL RULES-
‘(A) IMPORT- For purposes of this subsection, the term ‘import’ means entering, or withdrawal from warehouse, for consumption or use. Such term includes any grant of the right to use intangible property (as defined in section 936(h)(3)(B)) in the United States.
‘(B) UNITED STATES- For purposes of this subsection, the term ‘United States’ includes the Commonwealth of Puerto Rico, the Virgin Islands of the United States, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
‘(C) UNRELATED PERSON- For purposes of this subsection, the term ‘unrelated person’ means any person who is not a related person with respect to the controlled foreign corporation.
‘(D) COORDINATION WITH FOREIGN BASE COMPANY SALES INCOME- For purposes of this section, the term ‘foreign base company sales income’ shall not include any imported property income.’.
(c) Separate Application of Limitations on Foreign Tax Credit for Imported Property Offshored Income-
(1) IN GENERAL- Paragraph (1) of section 904(d) of the Internal Revenue Code of 1986 (relating to separate application of section with respect to certain categories of income) is amended by striking ‘and’ at the end of subparagraph (A), by redesignating subparagraph (B) as subparagraph (C), and by inserting after subparagraph (A) the following new subparagraph:
‘(B) imported property offshored income, and’.
(2) IMPORTED PROPERTY OFFSHORED INCOME DEFINED- Paragraph (2) of section 904(d) of such Code is amended by redesignating subparagraphs (I), (J), and (K) as subparagraphs (J), (K), and (L), respectively, and by inserting after subparagraph (H) the following new subparagraph:
‘(I) IMPORTED PROPERTY OFFSHORED INCOME- The term ‘imported property offshored income’ means any income received or accrued by any person which is of a kind which would be imported property offshored income (as defined in section 954(j)).’.
(3) CONFORMING AMENDMENT- Clause (ii) of section 904(d)(2)(A) of such Code is amended by inserting ‘or imported property offshored income’ after ‘passive category income’.
(d) Technical Amendments-
(1) Clause (iii) of section 952(c)(1)(B) of the Internal Revenue Code of 1986 (relating to certain prior year deficits may be taken into account) is amended--
(A) by redesignating subclauses (II), (III), (IV), and (V) as subclauses (III), (IV), (V), and (VI), and
(B) by inserting after subclause (I) the following new subclause:
‘(II) imported property offshored income,’.
(2) The last sentence of paragraph (4) of section 954(b) of such Code (relating to exception for certain income subject to high foreign taxes) is amended by striking ‘subsection (a)(5)’ and inserting ‘subsection (a)(4)’.
(3) Paragraph (5) of section 954(b) of such Code (relating to deductions to be taken into account) is amended by striking ‘and the foreign base company oil related income’ and inserting ‘the foreign base company oil related income, and the imported property offshored income’.
(e) Effective Date- The amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of the enactment of this Act, and to taxable years of United States shareholders within which or with which such taxable years of such foreign corporations end.
Calendar No. 578
111th CONGRESS
2d Session
Comments
Permalink
S. 3816
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
SEPTEMBER 22, 2010

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Offlinezappaisgod
horrid asshole


Registered: 02/11/04
Posts: 81,741
Loc: Fractallife's gym
Last seen: 7 years, 11 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14606883 - 06/13/11 03:13 PM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
It would probably go something like this


Calendar No. 578
111th CONGRESS
2d Session
S. 3816
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
IN THE SENATE OF THE UNITED STATES
SEPTEMBER 21, 2010
Mr. DURBIN (for himself, Mr. REID, Mr. SCHUMER, Mr. DORGAN, Mrs. BOXER, Mr. BROWN of Ohio, and Mr. LEAHY) introduced the following bill; which was read the first time
SEPTEMBER 22, 2010
Read the second time and placed on the calendar
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘Creating American Jobs and Ending Offshoring Act’.
TITLE I--INCENTIVES TO CREATE AMERICAN JOBS
SEC. 101. PAYROLL TAX HOLIDAY FOR EMPLOYERS MOVING JOBS TO THE UNITED STATES FROM OVERSEAS.
(a) In General- Section 3111 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(e) Special Exemption for Certain Individuals Hired to Replace Employees Whose Jobs Were Overseas-
‘(1) IN GENERAL- Subsection (a) shall not apply to wages paid by a qualified employer with respect to employment during the applicable 24-month period with respect to any qualified replacement individual for services performed--
‘(A) in a trade or business of such qualified employer, or
‘(B) in the case of a qualified employer exempt from tax under section 501(a), in furtherance of the activities related to the purpose or function constituting the basis of the employer’s exemption under section 501.
‘(2) QUALIFIED EMPLOYER- For purposes of this subsection, the term ‘qualified employer’ has the meaning given such term by subsection (d)(2).
‘(3) QUALIFIED REPLACEMENT INDIVIDUAL- For purposes of this subsection--
‘(A) IN GENERAL- The term ‘qualified replacement individual’ means any individual--
‘(i) who begins employment with a qualified employer after September 21, 2010, and before September 22, 2013,
‘(ii) with respect to whom the qualified employer certifies that such individual has been employed by the qualified employer to replace another employee--
‘(I) who was not a citizen or lawfully present resident of the United States, and
‘(II) substantially all of whose services for the employer were performed outside of the United States,
‘(iii) with respect to whom the qualified employer certifies that substantially all of the services the individual will perform for the employer will be performed within the United States, and
‘(iv) who is not an individual described in section 51(i)(1) (applied by substituting qualified employer for taxpayer each place it appears).
For purposes of this paragraph, only 1 individual may be treated as a qualified replacement individual with respect to any employee described in clause (ii) being replaced by the qualified employer. Any certification under clause (ii) or (iii) shall be made by signed affidavit, under penalties of perjury.
‘(B) EMPLOYER- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single employer for purposes of subparagraph (A)(ii), except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of such section.
‘(4) APPLICABLE 24-MONTH PERIOD- For purposes of this subsection, the term ‘applicable 24-month period’ means, with respect to any qualified replacement individual of a qualified employer, the 24-month period beginning on the hiring date of such individual by the employer.
‘(5) ELECTION- A qualified employer may elect to have this subsection not apply. Such election shall be made in such manner as the Secretary may require.
‘(6) SPECIAL RULE FOR THIRD CALENDAR QUARTER OF 2010-
‘(A) NONAPPLICATION OF EXEMPTION DURING THIRD QUARTER- Paragraph (1) shall not apply with respect to wages paid during the third calendar quarter of 2010.
‘(B) CREDITING OF FIRST QUARTER EXEMPTION DURING FOURTH QUARTER- The amount by which the tax imposed under subsection (a) would (but for subparagraph (A)) have been reduced with respect to wages paid by a qualified employer during the third calendar quarter of 2010 shall be treated as a payment against the tax imposed under subsection (a) with respect to the qualified employer for the fourth calendar quarter of 2010 which is made on the date that such tax is due.
1
‘(7) REGULATIONS- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this subsection, including regulations necessary to prevent the avoidance of such purposes through the transfer and retransfer of employees within and without the United States or otherwise.’.
(b) Coordination With Work Opportunity Credit- Section 51(c) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph:
‘(6) COORDINATION WITH PAYROLL TAX FORGIVENESS OF QUALIFIED REPLACEMENT INDIVIDUALS- The term ‘wages’ shall not include any amount paid or incurred to a qualified replacement individual (as defined in section 3111(e)(3)) during the 2-year period beginning on the hiring date of such individual by an employer unless such employer makes an election not to have section 3111(e) apply.’.
(c) Transfers to Federal Old-Age and Survivors Insurance Trust Fund- There are hereby appropriated to the Federal Old-Age and Survivors Trust Fund and the Federal Disability Insurance Trust Fund established under section 201 of the Social Security Act (42 U.S.C. 401) amounts equal to the reduction in revenues to the Treasury by reason of the amendments made by subsection (a). Amounts appropriated by the preceding sentence shall be transferred from the general fund at such times and in such manner as to replicate to the extent possible the transfers which would have occurred to such Trust Fund had such amendments not been enacted.
(d) Effective Date- The amendments made by this section shall apply to wages paid after September 21, 2010.
TITLE II--DISINCENTIVES TO MOVING AMERICAN JOBS OVERSEAS
SEC. 201. DISALLOWANCE OF DEDUCTION, LOSS, OR CREDIT FOR CERTAIN ITEMS INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
(a) In General- Part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:
‘SEC. 280I. EXPENDITURES INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
‘(a) Disallowance- No deduction, loss, or credit shall be allowed under this title for any taxable year for any disallowed amount.
‘(b) Disallowed Amount- For purposes of this section--
‘(1) IN GENERAL- The term ‘disallowed amount’ means any amount which is paid or incurred during the taxable year which is properly allocable to an American jobs offshoring transaction.
‘(2) LOSSES- Such term shall include any loss from any sale, exchange, abandonment, or other disposition of property in connection with an American jobs offshoring transaction.
‘(3) EXCEPTION FOR COSTS RELATED TO DISPLACED WORKERS- Such term shall not include any amount paid or incurred for assistance to employees within the United States whose jobs are being lost as part of an American jobs offshoring transaction, including any severance pay, outplacement services, or employee retraining.
‘(c) American Jobs Offshoring Transaction- For purposes of this section--
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‘(1) IN GENERAL- The term ‘American jobs offshoring transaction’ means any transaction (or series of transactions) in which the taxpayer reduces or eliminates the operation of a trade or business (or line of business) within the United States in connection with the start up or expansion of such trade or business (or such line of business) by the taxpayer outside of the United States.
‘(2) EXCEPTION- A transaction (or series of transactions) shall not be treated as an American jobs offshoring transaction if the taxpayer establishes to the satisfaction of the Secretary that such transaction (or series of transactions) will not result in the loss of employment for employees of the taxpayer within the United States.
‘(d) Aggregation Rule- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single taxpayer for purposes of this section, except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of section 52.
‘(e) Regulations- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations necessary to prevent the avoidance of such purposes and the application of this section in the case of mergers, acquisitions, and dispositions and in the case of contract employees.’.
(b) Conforming Amendment- The table of sections for part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:
‘Sec. 280I. Expenditures incurred in moving American jobs offshore.’.
(c) Effective Dates-
(1) IN GENERAL- The amendments made by this section shall apply to transactions occurring after the date of the enactment of this Act.
(2) EXCEPTION FOR EXISTING TRANSACTIONS- The amendments made by this section shall not apply to transactions occurring after the date of the enactment of this Act if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or the Secretary’s delegate that on or before such date the taxpayer publicly identified the transaction in sufficient detail that the nature and scope of the transaction could be identified.
SEC. 202. TAXATION OF INCOME OF CONTROLLED FOREIGN CORPORATIONS ATTRIBUTABLE TO IMPORTED PROPERTY PRODUCED BY EMPLOYEES IN AMERICAN JOBS MOVED OFFSHORE.
(a) General Rule- Subsection (a) of section 954 of the Internal Revenue Code of 1986 (defining foreign base company income) is amended by striking the period at the end of paragraph (5) and inserting ‘, and’, by redesignating paragraph (5) as paragraph (4), and by adding at the end the following new paragraph:
‘(5) imported property offshored income for the taxable year (determined under subsection (j) and reduced as provided in subsection (b)(5)).’.
(b) Definition of Imported Property Offshored Income- Section 954 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(j) Imported Property Offshored Income-
‘(1) IN GENERAL- For purposes of subsection (a)(5), the term ‘imported property offshored income’ means offshored income (whether in the form of profits, commissions, fees, or otherwise) received from a controlled foreign corporation and derived in connection with--
‘(A) manufacturing, producing, growing, or extracting imported property;
‘(B) the sale, exchange, or other disposition of imported property; or
‘(C) the lease, rental, or licensing of imported property.
Such term shall not include any foreign oil and gas extraction income (within the meaning of section 907(c)) or any foreign oil related income (within the meaning of section 907(c)).
‘(2) IMPORTED PROPERTY- For purposes of this subsection--
‘(A) IN GENERAL- Except as otherwise provided in this paragraph, the term ‘imported property’ means property which is imported into the United States by the offshored controlled foreign corporation or a related person.
‘(B) IMPORTED PROPERTY INCLUDES CERTAIN PROPERTY IMPORTED BY UNRELATED PERSONS- The term ‘imported property’ includes any property imported into the United States by an unrelated person if, when such property was sold to the unrelated person by the controlled foreign corporation (or a related person), it was reasonable to expect that--
‘(i) such property would be imported into the United States; or
‘(ii) such property would be used as a component in other property which would be imported into the United States.
‘(C) EXCEPTION FOR PROPERTY SUBSEQUENTLY EXPORTED- The term ‘imported property’ does not include any property which is imported into the United States and which--
‘(i) before substantial use in the United States, is sold, leased, or rented by the controlled foreign corporation or a related person for direct use, consumption, or disposition outside the United States; or
‘(ii) is used by the offshored controlled foreign corporation or a related person as a component in other property which is so sold, leased, or rented.
‘(D) EXCEPTION FOR CERTAIN AGRICULTURAL COMMODITIES- The term ‘imported property’ does not include any agricultural commodity which is not grown in the United States in commercially marketable quantities.
‘(3) OFFSHORED INCOME- For purposes of this section, the term ‘offshored income’ means income described in paragraph (1) that is directly or indirectly derived from the operation of a trade or business (or line of business) which was started or expanded outside the United States as part of an American jobs offshoring transaction (as defined in section 280I(c)) to which the provisions of section 280I apply.
‘(4) DEFINITIONS AND SPECIAL RULES-
‘(A) IMPORT- For purposes of this subsection, the term ‘import’ means entering, or withdrawal from warehouse, for consumption or use. Such term includes any grant of the right to use intangible property (as defined in section 936(h)(3)(B)) in the United States.
‘(B) UNITED STATES- For purposes of this subsection, the term ‘United States’ includes the Commonwealth of Puerto Rico, the Virgin Islands of the United States, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
‘(C) UNRELATED PERSON- For purposes of this subsection, the term ‘unrelated person’ means any person who is not a related person with respect to the controlled foreign corporation.
‘(D) COORDINATION WITH FOREIGN BASE COMPANY SALES INCOME- For purposes of this section, the term ‘foreign base company sales income’ shall not include any imported property income.’.
(c) Separate Application of Limitations on Foreign Tax Credit for Imported Property Offshored Income-
(1) IN GENERAL- Paragraph (1) of section 904(d) of the Internal Revenue Code of 1986 (relating to separate application of section with respect to certain categories of income) is amended by striking ‘and’ at the end of subparagraph (A), by redesignating subparagraph (B) as subparagraph (C), and by inserting after subparagraph (A) the following new subparagraph:
‘(B) imported property offshored income, and’.
(2) IMPORTED PROPERTY OFFSHORED INCOME DEFINED- Paragraph (2) of section 904(d) of such Code is amended by redesignating subparagraphs (I), (J), and (K) as subparagraphs (J), (K), and (L), respectively, and by inserting after subparagraph (H) the following new subparagraph:
‘(I) IMPORTED PROPERTY OFFSHORED INCOME- The term ‘imported property offshored income’ means any income received or accrued by any person which is of a kind which would be imported property offshored income (as defined in section 954(j)).’.
(3) CONFORMING AMENDMENT- Clause (ii) of section 904(d)(2)(A) of such Code is amended by inserting ‘or imported property offshored income’ after ‘passive category income’.
(d) Technical Amendments-
(1) Clause (iii) of section 952(c)(1)(B) of the Internal Revenue Code of 1986 (relating to certain prior year deficits may be taken into account) is amended--
(A) by redesignating subclauses (II), (III), (IV), and (V) as subclauses (III), (IV), (V), and (VI), and
(B) by inserting after subclause (I) the following new subclause:
‘(II) imported property offshored income,’.
(2) The last sentence of paragraph (4) of section 954(b) of such Code (relating to exception for certain income subject to high foreign taxes) is amended by striking ‘subsection (a)(5)’ and inserting ‘subsection (a)(4)’.
(3) Paragraph (5) of section 954(b) of such Code (relating to deductions to be taken into account) is amended by striking ‘and the foreign base company oil related income’ and inserting ‘the foreign base company oil related income, and the imported property offshored income’.
(e) Effective Date- The amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of the enactment of this Act, and to taxable years of United States shareholders within which or with which such taxable years of such foreign corporations end.
Calendar No. 578
111th CONGRESS
2d Session
Comments
Permalink
S. 3816
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
SEPTEMBER 22, 2010




:rofl2:You can't read a mortgage agreement but you post this disjointed bit of bullshit that doesn't do what you say it does (prevent the outsourcing of jobs).  It just disallows some tax deductions and adds some others.  It doesn't prevent dick.

  Did you even read it?  Show of hands among the audience:
Does anybioody think ShroomyJohn read this bill?
You may choose only one


Votes accepted from (06/13/11 03:12 PM) to (No end specified)
View the results of this poll



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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: zappaisgod]
    #14606899 - 06/13/11 03:15 PM (12 years, 11 months ago)

You realize that this bill offered tax breaks for companies, the same tax breaks they were lobbying for before, just to bring some outsourced jobs back to America?  You might call it "just disallowing some tax deductions and add some others" but that only means YOU didn't read it, whereas I have.

Of course I don't understand every little thing that is being said, but I understand most of it to know that it was a good idea, but it got shot down without even thought of changing it at all.  It's all or nothing for republicans.

Edited by ShroomyJohn (06/13/11 03:17 PM)

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14606938 - 06/13/11 03:21 PM (12 years, 11 months ago)

And I've never had to read a mortgage agreements.  A few rental agreements and you'd be damn sure I went through line by line and marked everything I needed to ask.

I don't see how what you think I would be unable to do has any effect on my beliefs about the topic.

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Offlinezappaisgod
horrid asshole


Registered: 02/11/04
Posts: 81,741
Loc: Fractallife's gym
Last seen: 7 years, 11 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14607027 - 06/13/11 03:37 PM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
You realize that this bill offered tax breaks for companies, the same tax breaks they were lobbying for before, just to bring some outsourced jobs back to America?  You might call it "just disallowing some tax deductions and add some others" but that only means YOU didn't read it, whereas I have.




No, I actually did read it.  It was absurd and came nowhere near preventing outsourcing.
Quote:



Of course I don't understand every little thing that is being said, but I understand most of it to know that it was a good idea, but it got shot down without even thought of changing it at all.  It's all or nothing for republicans.




Of course you don't understand it and it was an idiot idea.  Protectionism always is.


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OfflinePileusSonofGalt
PhungiPharmer
Male

Registered: 05/19/11
Posts: 240
Last seen: 12 years, 2 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14607460 - 06/13/11 05:01 PM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
It would probably go something like this


Calendar No. 578
111th CONGRESS
2d Session
S. 3816
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
IN THE SENATE OF THE UNITED STATES
SEPTEMBER 21, 2010
Mr. DURBIN (for himself, Mr. REID, Mr. SCHUMER, Mr. DORGAN, Mrs. BOXER, Mr. BROWN of Ohio, and Mr. LEAHY) introduced the following bill; which was read the first time
SEPTEMBER 22, 2010
Read the second time and placed on the calendar
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘Creating American Jobs and Ending Offshoring Act’.
TITLE I--INCENTIVES TO CREATE AMERICAN JOBS
SEC. 101. PAYROLL TAX HOLIDAY FOR EMPLOYERS MOVING JOBS TO THE UNITED STATES FROM OVERSEAS.
(a) In General- Section 3111 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(e) Special Exemption for Certain Individuals Hired to Replace Employees Whose Jobs Were Overseas-
‘(1) IN GENERAL- Subsection (a) shall not apply to wages paid by a qualified employer with respect to employment during the applicable 24-month period with respect to any qualified replacement individual for services performed--
‘(A) in a trade or business of such qualified employer, or
‘(B) in the case of a qualified employer exempt from tax under section 501(a), in furtherance of the activities related to the purpose or function constituting the basis of the employer’s exemption under section 501.
‘(2) QUALIFIED EMPLOYER- For purposes of this subsection, the term ‘qualified employer’ has the meaning given such term by subsection (d)(2).
‘(3) QUALIFIED REPLACEMENT INDIVIDUAL- For purposes of this subsection--
‘(A) IN GENERAL- The term ‘qualified replacement individual’ means any individual--
‘(i) who begins employment with a qualified employer after September 21, 2010, and before September 22, 2013,
‘(ii) with respect to whom the qualified employer certifies that such individual has been employed by the qualified employer to replace another employee--
‘(I) who was not a citizen or lawfully present resident of the United States, and
‘(II) substantially all of whose services for the employer were performed outside of the United States,
‘(iii) with respect to whom the qualified employer certifies that substantially all of the services the individual will perform for the employer will be performed within the United States, and
‘(iv) who is not an individual described in section 51(i)(1) (applied by substituting qualified employer for taxpayer each place it appears).
For purposes of this paragraph, only 1 individual may be treated as a qualified replacement individual with respect to any employee described in clause (ii) being replaced by the qualified employer. Any certification under clause (ii) or (iii) shall be made by signed affidavit, under penalties of perjury.
‘(B) EMPLOYER- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single employer for purposes of subparagraph (A)(ii), except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of such section.
‘(4) APPLICABLE 24-MONTH PERIOD- For purposes of this subsection, the term ‘applicable 24-month period’ means, with respect to any qualified replacement individual of a qualified employer, the 24-month period beginning on the hiring date of such individual by the employer.
‘(5) ELECTION- A qualified employer may elect to have this subsection not apply. Such election shall be made in such manner as the Secretary may require.
‘(6) SPECIAL RULE FOR THIRD CALENDAR QUARTER OF 2010-
‘(A) NONAPPLICATION OF EXEMPTION DURING THIRD QUARTER- Paragraph (1) shall not apply with respect to wages paid during the third calendar quarter of 2010.
‘(B) CREDITING OF FIRST QUARTER EXEMPTION DURING FOURTH QUARTER- The amount by which the tax imposed under subsection (a) would (but for subparagraph (A)) have been reduced with respect to wages paid by a qualified employer during the third calendar quarter of 2010 shall be treated as a payment against the tax imposed under subsection (a) with respect to the qualified employer for the fourth calendar quarter of 2010 which is made on the date that such tax is due.
1
‘(7) REGULATIONS- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this subsection, including regulations necessary to prevent the avoidance of such purposes through the transfer and retransfer of employees within and without the United States or otherwise.’.
(b) Coordination With Work Opportunity Credit- Section 51(c) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph:
‘(6) COORDINATION WITH PAYROLL TAX FORGIVENESS OF QUALIFIED REPLACEMENT INDIVIDUALS- The term ‘wages’ shall not include any amount paid or incurred to a qualified replacement individual (as defined in section 3111(e)(3)) during the 2-year period beginning on the hiring date of such individual by an employer unless such employer makes an election not to have section 3111(e) apply.’.
(c) Transfers to Federal Old-Age and Survivors Insurance Trust Fund- There are hereby appropriated to the Federal Old-Age and Survivors Trust Fund and the Federal Disability Insurance Trust Fund established under section 201 of the Social Security Act (42 U.S.C. 401) amounts equal to the reduction in revenues to the Treasury by reason of the amendments made by subsection (a). Amounts appropriated by the preceding sentence shall be transferred from the general fund at such times and in such manner as to replicate to the extent possible the transfers which would have occurred to such Trust Fund had such amendments not been enacted.
(d) Effective Date- The amendments made by this section shall apply to wages paid after September 21, 2010.
TITLE II--DISINCENTIVES TO MOVING AMERICAN JOBS OVERSEAS
SEC. 201. DISALLOWANCE OF DEDUCTION, LOSS, OR CREDIT FOR CERTAIN ITEMS INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
(a) In General- Part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:
‘SEC. 280I. EXPENDITURES INCURRED IN MOVING AMERICAN JOBS OFFSHORE.
‘(a) Disallowance- No deduction, loss, or credit shall be allowed under this title for any taxable year for any disallowed amount.
‘(b) Disallowed Amount- For purposes of this section--
‘(1) IN GENERAL- The term ‘disallowed amount’ means any amount which is paid or incurred during the taxable year which is properly allocable to an American jobs offshoring transaction.
‘(2) LOSSES- Such term shall include any loss from any sale, exchange, abandonment, or other disposition of property in connection with an American jobs offshoring transaction.
‘(3) EXCEPTION FOR COSTS RELATED TO DISPLACED WORKERS- Such term shall not include any amount paid or incurred for assistance to employees within the United States whose jobs are being lost as part of an American jobs offshoring transaction, including any severance pay, outplacement services, or employee retraining.
‘(c) American Jobs Offshoring Transaction- For purposes of this section--
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‘(1) IN GENERAL- The term ‘American jobs offshoring transaction’ means any transaction (or series of transactions) in which the taxpayer reduces or eliminates the operation of a trade or business (or line of business) within the United States in connection with the start up or expansion of such trade or business (or such line of business) by the taxpayer outside of the United States.
‘(2) EXCEPTION- A transaction (or series of transactions) shall not be treated as an American jobs offshoring transaction if the taxpayer establishes to the satisfaction of the Secretary that such transaction (or series of transactions) will not result in the loss of employment for employees of the taxpayer within the United States.
‘(d) Aggregation Rule- All employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single taxpayer for purposes of this section, except that section 1563(b)(2)(C) shall be disregarded in applying section 1563 for purposes of section 52.
‘(e) Regulations- The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations necessary to prevent the avoidance of such purposes and the application of this section in the case of mergers, acquisitions, and dispositions and in the case of contract employees.’.
(b) Conforming Amendment- The table of sections for part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:
‘Sec. 280I. Expenditures incurred in moving American jobs offshore.’.
(c) Effective Dates-
(1) IN GENERAL- The amendments made by this section shall apply to transactions occurring after the date of the enactment of this Act.
(2) EXCEPTION FOR EXISTING TRANSACTIONS- The amendments made by this section shall not apply to transactions occurring after the date of the enactment of this Act if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or the Secretary’s delegate that on or before such date the taxpayer publicly identified the transaction in sufficient detail that the nature and scope of the transaction could be identified.
SEC. 202. TAXATION OF INCOME OF CONTROLLED FOREIGN CORPORATIONS ATTRIBUTABLE TO IMPORTED PROPERTY PRODUCED BY EMPLOYEES IN AMERICAN JOBS MOVED OFFSHORE.
(a) General Rule- Subsection (a) of section 954 of the Internal Revenue Code of 1986 (defining foreign base company income) is amended by striking the period at the end of paragraph (5) and inserting ‘, and’, by redesignating paragraph (5) as paragraph (4), and by adding at the end the following new paragraph:
‘(5) imported property offshored income for the taxable year (determined under subsection (j) and reduced as provided in subsection (b)(5)).’.
(b) Definition of Imported Property Offshored Income- Section 954 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
‘(j) Imported Property Offshored Income-
‘(1) IN GENERAL- For purposes of subsection (a)(5), the term ‘imported property offshored income’ means offshored income (whether in the form of profits, commissions, fees, or otherwise) received from a controlled foreign corporation and derived in connection with--
‘(A) manufacturing, producing, growing, or extracting imported property;
‘(B) the sale, exchange, or other disposition of imported property; or
‘(C) the lease, rental, or licensing of imported property.
Such term shall not include any foreign oil and gas extraction income (within the meaning of section 907(c)) or any foreign oil related income (within the meaning of section 907(c)).
‘(2) IMPORTED PROPERTY- For purposes of this subsection--
‘(A) IN GENERAL- Except as otherwise provided in this paragraph, the term ‘imported property’ means property which is imported into the United States by the offshored controlled foreign corporation or a related person.
‘(B) IMPORTED PROPERTY INCLUDES CERTAIN PROPERTY IMPORTED BY UNRELATED PERSONS- The term ‘imported property’ includes any property imported into the United States by an unrelated person if, when such property was sold to the unrelated person by the controlled foreign corporation (or a related person), it was reasonable to expect that--
‘(i) such property would be imported into the United States; or
‘(ii) such property would be used as a component in other property which would be imported into the United States.
‘(C) EXCEPTION FOR PROPERTY SUBSEQUENTLY EXPORTED- The term ‘imported property’ does not include any property which is imported into the United States and which--
‘(i) before substantial use in the United States, is sold, leased, or rented by the controlled foreign corporation or a related person for direct use, consumption, or disposition outside the United States; or
‘(ii) is used by the offshored controlled foreign corporation or a related person as a component in other property which is so sold, leased, or rented.
‘(D) EXCEPTION FOR CERTAIN AGRICULTURAL COMMODITIES- The term ‘imported property’ does not include any agricultural commodity which is not grown in the United States in commercially marketable quantities.
‘(3) OFFSHORED INCOME- For purposes of this section, the term ‘offshored income’ means income described in paragraph (1) that is directly or indirectly derived from the operation of a trade or business (or line of business) which was started or expanded outside the United States as part of an American jobs offshoring transaction (as defined in section 280I(c)) to which the provisions of section 280I apply.
‘(4) DEFINITIONS AND SPECIAL RULES-
‘(A) IMPORT- For purposes of this subsection, the term ‘import’ means entering, or withdrawal from warehouse, for consumption or use. Such term includes any grant of the right to use intangible property (as defined in section 936(h)(3)(B)) in the United States.
‘(B) UNITED STATES- For purposes of this subsection, the term ‘United States’ includes the Commonwealth of Puerto Rico, the Virgin Islands of the United States, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
‘(C) UNRELATED PERSON- For purposes of this subsection, the term ‘unrelated person’ means any person who is not a related person with respect to the controlled foreign corporation.
‘(D) COORDINATION WITH FOREIGN BASE COMPANY SALES INCOME- For purposes of this section, the term ‘foreign base company sales income’ shall not include any imported property income.’.
(c) Separate Application of Limitations on Foreign Tax Credit for Imported Property Offshored Income-
(1) IN GENERAL- Paragraph (1) of section 904(d) of the Internal Revenue Code of 1986 (relating to separate application of section with respect to certain categories of income) is amended by striking ‘and’ at the end of subparagraph (A), by redesignating subparagraph (B) as subparagraph (C), and by inserting after subparagraph (A) the following new subparagraph:
‘(B) imported property offshored income, and’.
(2) IMPORTED PROPERTY OFFSHORED INCOME DEFINED- Paragraph (2) of section 904(d) of such Code is amended by redesignating subparagraphs (I), (J), and (K) as subparagraphs (J), (K), and (L), respectively, and by inserting after subparagraph (H) the following new subparagraph:
‘(I) IMPORTED PROPERTY OFFSHORED INCOME- The term ‘imported property offshored income’ means any income received or accrued by any person which is of a kind which would be imported property offshored income (as defined in section 954(j)).’.
(3) CONFORMING AMENDMENT- Clause (ii) of section 904(d)(2)(A) of such Code is amended by inserting ‘or imported property offshored income’ after ‘passive category income’.
(d) Technical Amendments-
(1) Clause (iii) of section 952(c)(1)(B) of the Internal Revenue Code of 1986 (relating to certain prior year deficits may be taken into account) is amended--
(A) by redesignating subclauses (II), (III), (IV), and (V) as subclauses (III), (IV), (V), and (VI), and
(B) by inserting after subclause (I) the following new subclause:
‘(II) imported property offshored income,’.
(2) The last sentence of paragraph (4) of section 954(b) of such Code (relating to exception for certain income subject to high foreign taxes) is amended by striking ‘subsection (a)(5)’ and inserting ‘subsection (a)(4)’.
(3) Paragraph (5) of section 954(b) of such Code (relating to deductions to be taken into account) is amended by striking ‘and the foreign base company oil related income’ and inserting ‘the foreign base company oil related income, and the imported property offshored income’.
(e) Effective Date- The amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of the enactment of this Act, and to taxable years of United States shareholders within which or with which such taxable years of such foreign corporations end.
Calendar No. 578
111th CONGRESS
2d Session
Comments
Permalink
S. 3816
A BILL
To amend the Internal Revenue Code of 1986 to create American jobs and to prevent the offshoring of such jobs overseas.
SEPTEMBER 22, 2010





Awesome, he thinks that a bank should have to produce a document that anyone would be able to understand because they are so confusing as of now that you require outside help to understand, yet he quotes a Congressional bill that would takes a person with above average intelligence several hours if not a day or two to fully comprehend every word and implication. Way to go Shroomy, I like how you say you are trying to get on my level. Read every post I have made and I you will see I have responded to almost every question pointed my way, by anyone, yet you have answered less than 50% of the questions just I have asked you. Typical moocher style. I am going to start calling you James Taggert.

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OfflineShroomyJohn
Stranger
Registered: 09/13/10
Posts: 1,085
Last seen: 11 years, 7 months
Re: Obama's Auto Industry Success [Re: zappaisgod]
    #14608739 - 06/13/11 08:46 PM (12 years, 11 months ago)

Quote:

zappaisgod said:
Quote:

ShroomyJohn said:
You realize that this bill offered tax breaks for companies, the same tax breaks they were lobbying for before, just to bring some outsourced jobs back to America?  You might call it "just disallowing some tax deductions and add some others" but that only means YOU didn't read it, whereas I have.




No, I actually did read it.  It was absurd and came nowhere near preventing outsourcing.
Quote:



Of course I don't understand every little thing that is being said, but I understand most of it to know that it was a good idea, but it got shot down without even thought of changing it at all.  It's all or nothing for republicans.




Of course you don't understand it and it was an idiot idea.  Protectionism always is.



-
And you do understand it? :rofl:

Of course it doesn't PREVENT anything but it was a solid idea that instead of being worked with, got completely shut down without any discussion, just as you seem to be doing.

Quote:


Awesome, he thinksthata bankshould have toproduce a document thatanyone wouldbe able to understandbecause theyare soconfusingas ofnowthatyourequire outside help to understand, yet he quotes a Congressional bill thatwouldtakes a person with aboveaverage intelligence several hours ifnota day or twotofully comprehendevery word and implication. Way to go Shroomy, I like how you say you are trying to get on my level. Read every post I have made and I you will see I have responded to almost every questionpointedmyway,by anyone, yet you have answeredless than50% ofthe questions justI have askedyou. Typical moocher style. I am going to start calling you James Taggert.





I don't need to understand every single line, there are plenty of detailed breakdowns of the bill that I have to reference to.

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OfflinePileusSonofGalt
PhungiPharmer
Male

Registered: 05/19/11
Posts: 240
Last seen: 12 years, 2 months
Re: Obama's Auto Industry Success [Re: ShroomyJohn]
    #14608777 - 06/13/11 08:52 PM (12 years, 11 months ago)

Quote:

ShroomyJohn said:
Quote:

zappaisgod said:
Quote:

ShroomyJohn said:
You realize that this bill offered tax breaks for companies, the same tax breaks they were lobbying for before, just to bring some outsourced jobs back to America?  You might call it "just disallowing some tax deductions and add some others" but that only means YOU didn't read it, whereas I have.




No, I actually did read it.  It was absurd and came nowhere near preventing outsourcing.
Quote:



Of course I don't understand every little thing that is being said, but I understand most of it to know that it was a good idea, but it got shot down without even thought of changing it at all.  It's all or nothing for republicans.




Of course you don't understand it and it was an idiot idea.  Protectionism always is.



-
And you do understand it? :rofl:

Of course it doesn't PREVENT anything but it was a solid idea that instead of being worked with, got completely shut down without any discussion, just as you seem to be doing.

Quote:


Awesome, he thinksthata bankshould have toproduce a document thatanyone wouldbe able to understandbecause theyare soconfusingas ofnowthatyourequire outside help to understand, yet he quotes a Congressional bill thatwouldtakes a person with aboveaverage intelligence several hours ifnota day or twotofully comprehendevery word and implication. Way to go Shroomy, I like how you say you are trying to get on my level. Read every post I have made and I you will see I have responded to almost every questionpointedmyway,by anyone, yet you have answeredless than50% ofthe questions justI have askedyou. Typical moocher style. I am going to start calling you James Taggert.





I don't need to understand every single line, there are plenty of detailed breakdowns of the bill that I have to reference to.




You dont need to understand every line huh? You expect a bank to give you a loan and make sure that you understand every line, yet you do not hold your government to the same standard. I wonder why? Congress published this and your average everday citizen would have little to no clue what the full implications are, but a mortgage, that has far less the number of implications, is too hard for people to read and understand? Maybe they should educate themselves.

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OfflineFalcon91Wolvrn03
Stranger
Male User Gallery

Folding@home Statistics
Registered: 03/16/05
Posts: 32,557
Loc: California, US Flag
Last seen: 8 months, 8 days
Re: Obama's Auto Industry Success [Re: PileusSonofGalt]
    #14608982 - 06/13/11 09:26 PM (12 years, 11 months ago)

Quote:

PileusSonofGalt said:
You expect a bank to give you a loan and make sure that you understand every line, yet you do not hold your government to the same standard.




The Government wouldn't be asking ordinary Americans not to outsource jobs - they would be asking businesses.  That's the difference.


--------------------
I am in a minority on the shroomery, as I frequently defend the opposing side when they have a point about something or when my side make believes something about them.  I also attack my side if I think they're wrong.  People here get very confused by that and think it means I prefer the other side.

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