In 2012, Puerto Rico had passed two laws intended to make the island a “global investment destination.” Act 20 allows corporations that export services from the island to pay only 4 percent tax. Act 22 goes much further: It makes Puerto Rico the only place on U.S. soil where personal income from capital gains, interest, and dividends are untaxed.
The last big tweak to U.S. taxation was in 2018. Plainly, the rates were low enough that most rich Americans refrained from making the move to the Ritz-Carlton Dorado. But what if Kamala Harris and fellow Democrats are able to deliver on their promise to soak the rich? Wouldn’t there be a lot more rich people who would make the move for 183 days per year in order to avoid losing a big percentage of their wealth? If so, the only way to stop the erosion of expected tax base would be to eliminate Puerto Rico’s ability to offer Act 22 treatment and the only way that I know to strip Puerto Rico of its tax sovereignty is to make Puerto Rico a state.
What’s stopping her from doing this now? Is Joe Biden such an intelligent muscular leader that he is preventing Kamala Harris from taking on corporate landlords? I had imagined that Democrats were all on the same team and that Biden and Harris were working especially closely, like Allen Gamble and Terry Hoitz. In reality, Biden is to Harris as P.K. Highsmith and Christopher Danson are to Terry Hoitz? (for those of you unfamiliar with The Other Guys, see below).
A little more background on the kinds of things that a leader such as Joe Biden can do…
Today, another American apparently took Joe Biden and Kamala Harris at their respective words and tried to save our democracy with a rifle. Kamala Harris says “I am glad [the danger to our democracy] is safe”:
I have been briefed on reports of gunshots fired near former President Trump and his property in Florida, and I am glad he is safe. Violence has no place in America.
The Democrats’ latest tax schemes, recently highlighted by Kamala Harris, include collecting tax on unrealized capital gains. To me, one of the strangest things about the US tax system is that losses are taxed as capital gains so long as there is even the slightest amount of inflation. For example, if you bought a stock in January 2021 for $100 and sold it today for $110 more you’d have about $10 in today’s dollars terms under official CPI and closer to $80 if adjusted for house purchasing power (Zillow). Despite the loss on what turned out to be an unsuccessful investment, you’d owe federal and, perhaps, state tax on the sale. The current not-adjusted-for-inflation capital gains tax regime is, thus, rather cruel when combined with Bidenflation but at least you can choose when to pay the tax on your fictitious profit/real loss.
We walked to a friend from Maskachusetts shortly after the noble Gazans made the news for amputating a young American citizen’s arm, holding him hostage for 11 months, and then executing him shortly before he would have been rescued by the IDF. Hersh Goldberg-Polin was 23 years old, was not serving in the Israeli military, and “was reportedly working with an initiative that was using soccer to bring Israeli and Palestinian children together” (Wikipedia).
As with other Democrats, the murder of Hersh Goldberg-Polin did not dampen her enthusiasm for voting for Kamala Harris, who has pledged to continue funding Hamas (via UNRWA, a funding path that Donald Trump cut off and Joe Biden restored in 2021; unless the October 7 attacks cost more than $1 billion it is fair to say that the Biden-Harris administration funded 100 percent of it with our tax dollars). She did volunteer her belief that there was an urgent need to “solve the Israel-Palestine Problem”. I asked her why the Maskachusetts Righteous sympathies were there rather than with Black Lives Matter or American Women, two victimhood classes that had previously generated large rallies. She said that Democrats were still passionate about these causes, but couldn’t remember any BLM events post-October 7, 2023. I asked why the failure of the Palestinians to achieve their 1948 military goals made them more sympathy-worthy than any of the 1.5 billion residents of Africa, about whom she had never expressed any concern. She said, “I guess I hear more about the Palestinians in the news.”
What was her plan for resolving the conflict? She believed that Palestinian children were being indoctrinated by a message of Jew-/Israel-hatred in their schools (funded by US and EU taxpayers, of course) and that the solution was to bring them to the U.S. so that they could instead be indoctrinated by American schools (also funded by US taxpayers so perhaps this isn’t a huge change from a financial point of view). I didn’t point out that Queers for Palestine and similar rallies all around the U.S. show that there is plenty of “destroy Israel” energy among those who go through American K-12, but I did ask “Why would the typical Palestinian go to the trouble of having 5 kids and then just give them up voluntarily to American do-gooders running a reeducation scheme in which Christianity and Judaism have equal status to Islam?” Our Massachusetts Kamala voter said, “the parents can come too if they want.” I pointed out that, given Gaza’s world-leading population growth rate, almost every adult there has at least one minor child and, therefore, she was proposing that the entire population of Gaza be admitted to the United States to become American citizens. She said that it was indeed her expectation that the majority of Gazans would come to the U.S. I then pointed out that 50,000 babies had been born in Gaza during the recent battles (not to say “war” since that started in 1948 and the Palestinians have never accepted any kind of peace; there has been a continuous officially declared war going for 76 years now). Wouldn’t a new crop of Hamas warriors, therefore, be born soon enough and be able to carry on the fight even if most of their older brothers, sisters, and binary-resisters were peacefully voting for Democrats in Michigan? She didn’t seem to have considered the possibility that Gazans left behind, still getting unlimited food, education, health care, etc. free from UNRWA, would continue the Palestinian tradition of off-the-charts fertility. (See “Reproductive decisions in the lives of West Bank Palestinian women: Dimensions and contradictions” (2017, Global Public Health):
Palestinian women have one of the highest fertility rates in the world, averaging 4.38 births per woman. However, Palestinian fertility patterns are distinct from those of other developing nations, in that high fertility rates coexist alongside high levels of education and low levels of infant mortality – both of which have been established elsewhere as predictors of low total fertility rates.
).
I share this conversation because I thought it was an interesting window into the mind of a Kamala Harris voter. The best way to heal the world is a further expansion of low-skill immigration to the U.S.
Separately, given the success that Hamas has enjoyed after taking and killing American hostages what happens to U.S. citizens in other parts of the world going forward? Since taking American hostages Hamas has secured from the Biden-Harris administration (a) promises of continued funding, (b) a $230 million pier (admittedly washed away quickly), (c) support for the Hamas-sought “permanent ceasefire” that leaves Hamas leaders alive and well and permanently in charge of Gaza, (d) pressure on Israel for a long delay in the IDF operation in Rafah, which turns out to be where at least one American hostage was held and killed (see “Harris warns it would be a ‘mistake’ for Israel to invade Rafah” (CNN, March 25, 2024)) and “Kamala Harris says Israel assault on Rafah ‘would be a huge mistake’” (Guardian)), and (e) diplomatic recognition by a variety of purported U.S. allies and military client states as leaders of their own sovereign nation (“Spain, Norway and Ireland formally recognize a Palestinian state as EU rift with Israel widens” (AP)). What’s the downside to taking American hostages in the Biden-Harris era?
IRC 877A imposes a mark-to-market regime, which generally means that all property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date. Any gain arising from the deemed sale is taken into account for the tax year of the deemed sale notwithstanding any other provisions of the Code. Any loss from the deemed sale is taken into account for the tax year of the deemed sale to the extent otherwise provided in the Code, except that the wash sale rules of IRC 1091 do not apply.
Section 877A(a) generally imposes a mark-to-market regime on expatriates who are covered by section 877A, providing that all property of a covered expatriate is treated as sold on the day before the expatriation date for its fair market value.
For purposes of the mark-to-market regime, the covered expatriate is deemed to have sold any interest in property that he or she is considered to own under the rules of this paragraph other than property described in section 877A(c). For purposes of computing the tax liability under the mark-to-market regime, a covered expatriate is considered to own any interest in property that would be taxable as part of his or her gross estate for Federal estate tax purposes under Chapter 11 of Subtitle B of the Code as if he or she had died on the day before the expatriation date as a citizen or resident of the United States.
In computing the tax liability under the mark-to-market regime, a covered expatriate must use the fair market value of each interest in property as of the day before the expatriation date in accordance with the valuation principles applicable for purposes of the Federal estate tax, except as otherwise provided in this paragraph.
The number of individuals who renounce their U.S. citizenship or terminate their green card status has increased significantly since the enactment of the current expatriation tax regime in 2008. Lists of these individuals published quarterly by the IRS in the Federal Register show that the number of individuals expatriating has increased from 312 in 2008 to 3,260 in 2023, with a peak of 6,705 in 2020.
My big question is how President Kamala Harris will collect long-term money from the targets of her extended (not exactly new, as noted above) unrealized capital gains tax. A person targeted by the tax has two choices:
pay President Harris for unrealized capital gains in 2026 (let’s assume it takes a while for this to be implemented), 2027, 2028, and every subsequent year until death
pay President Harris for unrealized capital gains at long-term rates in 2025 and then never pay income taxes to President Harris, the U.S. government, or any other government again (expatriation)
Why wouldn’t a rational target of the new tax choose Option 2? He/she/ze/they renounces U.S. citizenship, moves his/her/zir/their assets into an offshore Dutch trust (as U2 did) and moves to any country that doesn’t dig into offshore assets/income for computing income tax. Or establish a residence in Italy and pay a flat tax rate of €200,000 a year (recently bumped up from the €100,000/year rate established in 2017, which means it has kept roughly even after adjusting for inflation in the costs of things that rich people buy, but the bump doesn’t affect people who signed up for this prior to August 2024). Or simply move to a country that doesn’t impose any income tax (KMPG on relocation to Monaco). If the expat is nostalgic, he/she/ze/they can return to the US for 30-60 days per year, depending on the employment situation, without becoming subject to U.S. taxation.
There is a lot to like about living in the U.S. (especially here in Florida!), but is it worth paying 100X as much in taxes compared to living in some other part of the world? If there are friends you want to see buy them a first class ticket to Heathrow and push your way through the pro-Hamas rallies to a night of theater. Or, if you’re truly one of those who has taken more than he/she/ze/they needs, send the Gulfstream or Airbus Corporate Jet to pick up the friends.
Here’s a place in northern Italy that costs less than a tract house in Palm Beach County ($2.7 million for a modern house on 22 acres):
Given the tax savings, maybe there isn’t any need for maintenance. Just buy a new house every few years with a fraction of what would have been paid in unrealized capital gains tax and give the old house to a charity.
Separately, why didn’t the Democrats impose their new tax regime during the first two years of the Biden-Harris administration when they had control of both houses of Congress and the White House? How can Kamala Harris simultaneously say that she agrees with everything that Joe Biden did (or read from a teleprompter) and also that she will do completely different stuff starting January 2025?
Wikipedia page on Eduardo Saverin: “a Brazilian billionaire entrepreneur and angel investor based in Singapore. … With an estimated net worth of US$26.3 billion as of early August 2024, he is the 69th richest person in the world, and the richest Brazilian. Saverin renounced his U.S. citizenship in September 2011, thereby avoiding an estimated US$700 million in capital gains taxes.”
We are informed that Joe Biden is too senile to run for reelection, but also more than capable of serving as Commander in Chief of the $1 trillion/year U.S. military (so he’ll do that job for another half year). We’ll soon be reminded, no doubt, by government-sponsored media (NPR) and government-affiliated media (most of the rest) of Joe Biden’s tremendous achievements between 2021 and 2024. Perhaps we could also fit in a brief moment of thanks to the person who made Joe Biden’s magnificent largesse, such as student loan forgiveness, possible: the taxpayer. This humble soul, attired in threadbare garments, is featured in an 1877 oil painting, The Tax Payer, by Hugo Oehmichen. Note the comparatively rich outfit worn by the government employee:
Hugo Oehmichen (1843-1932) studied under Julius Hubner and Adolf Ehrhardt at the Academy in Dresden, from 1858 to 1864. In 1866 and 1867 he visited Italy, and in 1869 he visited Düsseldorf, the banks of the Rhine and Moselle, Westphalia, Hesse and Swabia, returning with numerous studies. These travels in small-town Germany, and home life with his children, inspired many of the genre scenes for which he is best known. From 1862 he exhibited at the Academy in Dresden, and he also exhibited in Berlin, London and Antwerp.
Readers: Which progressive hero (or heroine) will Democrat elites select next to stave off the end of our democracy? How long will it take peasants to respond to the updated propaganda and transfer their enthusiasm to the new candidate for whom none of them previously voted (at least not for this role)?
Personally, I would like to see a Kamala Harris and Hunter Biden combo. Speaking of Hunter, the museum holds one of his works:
We’ve been getting some details about the face-off between the arch criminal below and the $3 billion/year Secret Service.
Wikipedia says that the building from which Thomas Matthew Crooks shot at Mr. Trump was identified as an ideal location for an assassin, that police snipers were sitting inside the building eating donuts and drinking coffee rather than risk falling off a mostly-flat roof, that law enforcement ignored the crowd’s attempts to warn them of Mr. Crooks’s activities, and that Crooks’s use of a rangefinder wasn’t considered sufficiently suspicious for anyone to take action. The state of knowledge as of July 16, 2024:
According to WPXI, Crooks was photographed twice by security officers prior to the shooting. Prior to 5:45 p.m. EDT, a police officer saw Crooks on the ground and reported him, with a photograph, as a suspicious person. An officer searched for Crooks but did not find him. Multiple local law enforcement officers identified Crooks and believed that he might have been acting suspiciously near the event’s magnetometers; they expressed their suspicions over the radio, and their radio communications were available to the Secret Service.[38] At 5:45 p.m., a member of the Beaver County Emergency Services Unit (ESU) tactical team saw Crooks on a roof, notified other security services, and photographed Crooks.[47] According to Forbes, in one of the two cases of Crooks being photographed, the police officer who photographed Crooks saw him “‘scoping out’ the roof and carrying a range finder”.[43] Reports indicated that several bystanders also witnessed a man carrying a rifle on the rooftop and alerted the police about him nearly a minute and a half before shots were fired at Trump.[48][49] A Butler Township police officer attempted to climb to the roof of the building in search of Crooks, hoisted by another officer. Crooks spotted the officer while the officer’s hands were clinging to the edge of the roof and aimed his rifle at the officer, at which point the officer let go, falling 8 feet (2.4 m) to the ground and severely injuring his ankle. Crooks undertook the assassination attempt immediately following the confrontation with the officer.
My question for today is “Suppose that the Secret Service and local law enforcement actually wanted a random kid to be able to shoot and kill Donald Trump. What would they have done differently?” Short of actually handing out rifles, scopes, and ammo, how would it have been possible for the Secret Service and police to facilitate what young Mr. Crooks was trying to do?
U.S. intelligence agencies were tracking what they considered a potential Iranian assassination plot against former President Donald J. Trump in the weeks before a gunman opened fire last weekend, several officials said on Tuesday, but they added that they did not believe the threat was related to the shooting that wounded Mr. Trump.
The intelligence had prompted the Secret Service to enhance security for the former president before his outdoor campaign rally in Butler, Pa., on Saturday, officials said. Yet whatever additional measures were taken did not stop a 20-year-old local man from clambering on top of a nearby warehouse roof to shoot at Mr. Trump, grazing his right ear and coming close to killing him.
American progressives now agree with Iran on both (a) Palestine, and (b) the importance of getting rid of Donald Trump?
Separately, at least according to Joe Biden and/or his minders, here are some of the threats that Mr. Crooks came close to eliminating:
I’m in a chat group with a few Deplorables, a couple of whom are gun nuts. I’ve been trying to get some of my software expert witness work done before EAA AirVenture (“Oshkosh”) and thus was in the middle of a real-time work session when the Trump shooting occurred. I ]wasn’t paying close attention to the chat group, for which I get alerts, or the news, for which I don’t get alerts. During a short break in the work, during which I scanned the gun nuts’ exchange, I responded with the following:
I haven’t checked the news, but let me guess: all of the people who said that Donald Trump would end our democracy (i.e., destroy the U.S. as we know it), kill Americans who identify as “pregnant people” by denying them abortion care, kill Americans by refusing to order masks, school closures, and lockdowns next time a respiratory virus comes through, etc. are now saying that it is reprehensible that someone would try to preserve American democracy and American lives by killing the one big threat to both.
As soon as work was done, I checked Twitter. I refreshed my memory by sampling some Democrat thought-leadership… According to “the big guy”, we could “lose everything”, including our democracy, if anyone votes for Donald Trump:
Trump poses many threats to our country: The right to choose, civil rights, voting rights, and America’s standing in the world.
But the greatest threat he poses is to our democracy.
Also, from June 28 (screen shot in case this gets memory-holed):
How does Joe Biden feel about the failure of the rifleman to neutralize the dire/genuine threat to our democracy that he identified and, therefore, the continued realistic possibility that we will soon “lose everything”? Joe Biden is “grateful” and “praying for [Donald Trump]” (i.e., praying that Americans continue to be threatened):
I have been briefed on the shooting at Donald Trump’s rally in Pennsylvania.
I’m grateful to hear that he’s safe and doing well. I’m praying for him and his family and for all those who were at the rally, as we await further information.
Let’s check the New York Times. “Is Donald Trump a Threat to Democracy?” (NYT, December 16, 2016) answers the question in the affirmative. Here’s the worst part:
There are signs that Mr. Trump seeks to diminish the news media’s traditional role by using Twitter, video messages and public rallies to circumvent the White House press corps and communicate directly with voters…
Also, Trump would seek to imprison the political opposition:
An even more basic norm under threat today is the idea of legitimate opposition. … Governments throughout history have used the claim that their opponents are disloyal or criminal or a threat to the nation’s way of life to justify acts of authoritarianism.
The idea of legitimate opposition has been entrenched in the United States since the early 19th century, disrupted only by the Civil War. That may now be changing, however, as right-wing extremists increasingly question the legitimacy of their liberal rivals. …
Such extremism, once confined to the political fringes, has now moved into the mainstream. … Mr. Trump’s campaign centered on the claim that Hillary Clinton was a criminal who should be in jail; and “Lock her up!” was chanted at the Republican National Convention. In other words, leading Republicans — including the president-elect — endorsed the view that the Democratic candidate was not a legitimate rival.
Did the newspaper of record’s opinion change over the intervening 8 years? No. Just two days ago, the NYT said that Trump was “Dangerous in Word, Deed, and Action”:
The clear thinkers at the NYT have been warning us for at least 8 years about the dangers of Donald Trump being anywhere near the levers of power. What do they now say? “The Attack on Donald Trump Is Antithetical to America”:
It is a mercy that Donald Trump was not seriously injured by gunfire at an evening campaign rally … We hope that Mr. Trump recovers quickly and fully.
They want the person whom they said would end American democracy to “recover quickly and fully”? They don’t at least hope he’ll be incapacitated through November 5, 2024?
Given all of the above, I rate my prediction in the chat group exchange as TRUE.
Readers: Have you found any examples of a righteous person admitting that there is at least an apparent logical contradiction between his/her/zir/their previous vilification and expressed fear of Donald Trump and current expressed hope that Donald Trump be preserved from any future harm?
(Personally, I do hope that our fellow Palm Beach County taxpayer Donald Trump recovers completely. And I have to say that I’m impressed by his apparent sangfroid. How many among us can say that our courage has been tested with an actual shooting? But my well-wishing isn’t a logical contradiction because I did not previously express an opinion that Mr. Trump was dangerous, a threat, or likely to end American democracy. (I did say that I preferred both Nikki Haley and Ron DeSantis as candidates, but not that I expected or demanded everyone else in America to agree with me.))
Related:
Mar-a-Lago and the Palm Event (from March 2024; “The most hated man in America appeared midway through the event to welcome the guests, praise the organization, praise the musical and theatrical talent, etc. Donald Trump was gracious and did not mention politics nor did he talk about himself. He had no teleprompter.”)
Update: Let’s also check out Kamala Harris. Last month, “[Donald Trump] is a threat to our democracy and our fundamental freedoms.”
Donald Trump has vowed that he will be a dictator on “day one.”
This evening, “praying for Donald Trump” and “relieved” that the pathway to dictatorship for the U.S. is still available:
I have been briefed on the shooting at former President Trump’s event in Pennsylvania.
Doug and I are relieved that he is not seriously injured. We are praying for him, his family, and all those who have been injured and impacted by this senseless shooting.
But when people draw parallels between Donald Trump’s 2024 candidacy and Hitler’s progression from fringe figure to Great Dictator, we aren’t joking. Those of us who hope to preserve our democratic institutions need to underscore the resemblance before we enter the twilight of American democracy.
Thankfully, Donald Trump is reported to be “fine” after an apparent attempt on his life
(They’re happy that the person they called Hitler With a Golf Cart Instead of a Volkswagen is hale and hearty.)
The New Republic should get an award for clarity. I’m going to leave this “Trump = Hitler” cover as a placeholder to see if the progressive magazine comes up with a paired “We’re sorry that the latter-day Claus von Stauffenberg did not kill Hitler” story:
We chose the cover image, based on a well-known 1932 Hitler campaign poster, for a precise reason: that anyone transported back to 1932 Germany could very, very easily have explained away Herr Hitler’s excesses and been persuaded that his critics were going overboard. After all, he spent 1932 campaigning, negotiating, doing interviews—being a mostly normal politician. But he and his people vowed all along that they would use the tools of democracy to destroy it, and it was only after he was given power that Germany saw his movement’s full face.
I will have a lot more respect for The New Republic if they say that they’re sad the modern Claus von Stauffenberg wasn’t more successful than the original Claus von Stauffenberg.
After the despicable attempt to kill Trump, a reporter who writes regularly about political violence explains how deeply unprepared we are for the terrible escalation that may now be coming. … At the time of this recording, we know little about the attempt to assassinate Donald Trump. He was hit in the ear, but thankfully doesn’t appear seriously injured.
It’s “despicable” to kill a person whom they said was a defrosted Hitler and they are thankful that Hitler wasn’t seriously injured. I sampled the podcast and the main issue, it seems, is violence perpetrated by Republicans. So just maybe the magazine’s position can be considered consistent with the Hitler cover. They’re thankful that Trump wasn’t more seriously injured because a serious injury would be more likely to result in violence against noble Democrats, not because they they want Trump to be alive and well. And the shooter was “despicable” because his action could have resulted in violence against noble/precious Democrats.
“If you begin with criticism, then you go to protest, then you go to impeachment, now you go to indictment and none of them work. What’s next? Graph it out, man. We’re speeding towards assassination, obviously. … They have decided — permanent Washington, both parties have decided — that there’s something about Trump that’s so threatening to them, they just can’t have him,” Carlson said in the interview, which was posted online Wednesday.
In far-right and conspiratorial circles, Trump has long been presented as the target of a vast plot orchestrated in part by Washington’s “deep state” as well as the Democratic establishment and the news media. The former president has embraced this worldview, referring to himself as a “victim” and the center of a “witch hunt.”
NBC reassured readers that this theory was “presented without evidence” and only someone gullible enough to believe a conspiracy theory would consider the possibility of an attack on literal Hitler.
The New York Post shows us the threat with which the $3 billion/year Secret Service was confronted:
Is it fair to say that the Biden administration’s Secret Service is at least as effective as the Biden administration’s Department of Homeland Security, responsible for securing the border?
Representative Nancy Pelosi, a longtime Biden ally and the former speaker, is the most senior member of his party who has so far suggested he consider dropping out.
Ms. Pelosi, 84, a longtime ally of the 81-year-old Mr. Biden and one of the most seasoned and cutthroat politicians in the House, has been more aggressive in her public comments about the president’s candidacy than other party leaders, who have publicly stated only that they remain behind him.
The 84-year-old is “seasoned” and “aggressive” (like Mindy the Crippler, our golden retriever?) while the 81-year-old is too old to work for the federal government.
