Executive Order on Cannabis and 280E Proves Empty
It took a while, but I co-authored an article about the recent nothingburger of an executive order about Cannabis and 280E. Read here: https://t.co/CStb3Qwkgu
Pass‑through Entities Often Beat QSBS for Tax Savings
In Episode 52 of @HowTaxWorks, I discuss why QSBS/1202 isn't some magical panacea, and it would lower taxes for many businesses to remain as pass-through entities. Listen here:
AI-Generated Content Is Too Sloppy to Handwrite
"You can't possibly handwrite the type of shit AI slop we have been seeing." https://t.co/bIaWgmeX6L
Harassment Training Reveals Lingering Anti‑Jewish Slurs at Deloitte
Whenever I take a workplace harassment training, I think about the partner at Deloitte who said to the about-to-retire partner at Deloitte, "Look at us, just a bunch of Micks," and the about-to-retire partner looked at the first partner and...
Confused by “Sexual Emojis” In Harassment Training
I'm doing an anti-harassment training for work and one made a comment about "sexual emojis" and... like do those exist? Are they talking about gifs?
0.2% Tax Generates $115M, Yet Home Tax Minimal
Let's assume there are 3500 worth $5MM, 2000 worth $10MM, and 1000 worth $20MM. 0.2% tax and you raise $115MM. The $5MM second home pays $10k, which is less than their annual real estate taxes (roughly $50-70k for...
Propose a Flexible Covenant for Immediate Competition
I want someone to propose a covenant to compete. Just modify it in ways that you can compete immediately and then sign it.
Dissent Misreads 7701(o) and Key Precedent in Soy Case
Finished my second reading of the Liberty Global (Project Soy) economic substance case and it's going to end up being a podcast episode. The dissent fundamentally misunderstands 7701(o) and its preceding caselaw, whiffing on its analysis of Gregory and...
Discovering My Unexpected Top‑1% Expertise in IRC 45F
There's a real argument that I'm in the top 1% of expertise on IRC 45F, which is not something that I thought I would ever know existed, let alone have written dozens, fucking dozens, of memoranda on various issues.
Gas Prices Set to Dominate Economic Conversation
Yesterday, I got a haircut. After basic pleasantries, the barber (who knows I'm a lawyer but doesn't know much else) asked me how high I thought gas prices will go and whether it would hurt the economy. Friends,...
Set PTETs at 110% to Boost Revenue
For what it's worth, PTETs should be set at like 110%. Still a net benefit for taxpayers, would actually pay for the extra processing that PTETs allow and raise revenue.
OPEC Nations Routinely Exceed Production Limits, Critics Overlook
People are out here acting like every single OPEC member didn't constantly exceed production/export limits every single day.
Choosing Entity Structure for QSBS Benefits
One of my favorite things is when a client's accountant asks me to put together a model to compare being a partnership/SCorp v C Corp to see if they should reorganize to go after QSBS. What would you say...
Regulation Gaps Leave Exchanges without Proper Accounting Systems
If only there were some sort of regulations that would require the exchanges to create accounting systems, but unfortunately those were rescinded and apparently the blockchain is not actually a functional ledger. #FAFO
Explaining Dual Consolidated Losses in Cross‑Border Tax
Today, I wrote an email explaining dual consolidated losses in the cross-border context. I feel like @adonnelly50 is the only person who would appreciate this tweet.