News
Supreme Court Upholds Trump-Era Foreign Earnings TAX
On Thursday, the US Supreme Court upheld an obscure tax established as part of Trump’s big 2017 reform package that targets U.S. taxpayers who own shares in certain foreign firms.
The Supreme Court concluded 7-2 that the so-called mandatory repatriation tax, or MRT, is constitutional under Article I and the 16th Amendment, rejecting a lawsuit by a Washington couple, Charles and Kathleen Moore, who claimed the provision violated the Constitution. Justice Brett Kavanaugh authored the majority opinion. Justices Clarence Thomas and Neil Gorsuch dissented.
The Supreme Court’s decision was narrow, but by declining to overturn the tax, the justices avoided closing the door on Democrats’ proposals to levy taxes on the nation’s richest earnings. Kavanaugh emphasized that the court’s analysis ignores the difficulties created by holdings, wealth, or net worth taxes, as well as appreciation taxes.
“Those are potential issues for another day, and we do not address or resolve any of those issues here,” the Supreme Court judge’s counsel wrote. “In the Moores’ instance, Congress has long taxed an entity’s shareholders on its undistributed revenue, as it did with the MRT. This Court has long sustained such taxes, and we continue to do so with the MRT.
The high court opinion is also expected to allay fears about the impact of a sweeping decision rejecting the required repatriation tax on other elements of the tax legislation. Kavanaugh acknowledged the potential repercussions of such a finding, stating that if the Moores’ argument is adopted, “vast swaths” of the Internal Revenue Code may be declared unconstitutional.
“And those tax provisions, if suddenly eliminated, would deprive the U. S. government and the American people of trillions in lost tax revenue,” he wrote on behalf of the coalition. “The logical ramifications of the Moores’ thesis would thus oblige Congress to either dramatically slash important national programs or significantly increase taxes on the remaining sources available to it—including, of course, ordinary Americans. The Constitution does not need such a fiscal disaster.”
Dan Greenberg, general counsel of the Competitive Enterprise Institute, which represented the Moores, expressed disappointment with the verdict, which allows the government to collect income taxes on overseas stockholders who have never earned income.
“We think that is unfair, because the Constitution authorizes Congress to tax people on their income, not the income of foreign businesses that they do not control,” according to a press release.
Supreme Court Moore v. U.S.
The tax at the center of the case, known as Moore v. U.S., is imposed one time on U.S. taxpayers who hold shares of certain foreign corporations. The Moores challenged the measure after they were hit with a nearly $15,000 tax bill for 2017 as a result of the law, which required them to pay levies on their share of reinvested lifetime earnings from an India-based company called KisanKraft Tools.
The Moores had invested $40,000 in the company in 2006 in exchange for a 13% stake, and did not receive any distributions, dividends or other payments from it.
But the mandatory repatriation tax, enacted through the Tax Cut and Jobs Act that was signed into law by former President Donald Trump, taxed U.S. taxpayers who owned at least 10% of a foreign company on their proportionate share of that company’s earnings after 1986. The tax was projected to generate roughly $340 billion in revenue over 10 years.
Though KisanKraft reinvested its earnings in the years after its founding, rather than distributing dividends to shareholders, the tax still applied to the Moores.
The Moores paid, but filed a lawsuit against the federal government to obtain a refund and challenge the constitutionality of the mandatory repatriation tax.
A federal district court ruled for the government and dismissed the case, finding that the mandatory repatriation tax is permitted under the 16th Amendment, which grants Congress the authority to tax “incomes, from whatever source derived.”
The U.S. Court of Appeals for the 9th Circuit upheld the lower court’s decision, ruling that nothing in the Constitution prohibits Congress from “attributing a corporation’s income pro-rata to its shareholders.” The 9th Circuit noted that courts have consistently upheld other similar taxes, and warned that finding the measure unconstitutional would call into question many other long-standing tax provisions.
The Supreme Court affirmed the 9th Circuit’s ruling and found that by 1938, its precedents had established a rule that contradicted the Moores’ argument in their case. That line of prior decisions, Kavanaugh wrote for the court, “remains good law to this day.”
Citing those earlier rulings and the similarities between the mandatory repatriation tax and other tax provisions, the court concluded that the measure “falls squarely within Congress’s constitutional authority to tax.”
Justice Amy Coney Barrett issued a concurring opinion, joined by Justice Samuel Alito, in which she agreed with the outcome of the case, but split with the majority’s reasoning. Addressing the question that was before the court, Barrett said that the 16th Amendment does not authorize Congress to tax unrealized sums without apportionment to the states.
In a dissenting opinion joined by Gorsuch, Thomas said the Moores were correct in challenging the mandatory repatriation tax as unconstitutional. Because the couple never actually received gains from their investment, those unrealized gains couldn’t be taxed as income under the 16th Amendment, he wrote.
“The fact that the MRT has novel features does not mean that it is unconstitutional. But, the MRT is undeniably novel when compared to older income taxes, and many of those differences are constitutionally relevant,” he wrote. “Because the MRT is imposed merely based on ownership of shares in a corporation, it does not operate as a tax on income.”
Thomas criticized the majority over its concerns about the impact a broad decision would have on other longstanding taxes, writing that “if Congress invites calamity by building the tax base on constitutional quicksand, ‘the judicial power’ afforded to this court does not include the power to fashion an emergency escape.”
He also rebuffed the majority’s contention that its ruling does not speak to the constitutionality of other taxes that may be passed by Congress, such as a wealth tax.
“Sensing that upholding the MRT cedes additional ground to Congress, the majority arms itself with dicta to tell Congress ‘no’ in the future,” Thomas wrote. “But, if the court is not willing to uphold limitations on the taxing power in expensive cases, cheap dicta will make no difference.”
During oral arguments in December, the justices seemed sympathetic to concerns about how a sweeping ruling would reverberate across the U.S. tax system and threaten existing tax laws.
But some of the justices sought clarity on the limits of Congress’ taxing power. Lawyers for the Moores had warned the court that allowing a tax on income that has not yet been realized, or received, would pave the way for lawmakers to levy taxes on all manner of things, such as retirement accounts or gains in the value of real estate.
Justice Samuel Alito had faced pressure from some congressional Democrats to recuse himself from the case because of interviews he participated in with an editor at the Wall Street Journal and David Rivkin, a lawyer who represented the Moores.
The justice declined to step aside from the case, arguing there was “no valid reason” for him to do so.
Source: CBS News
An aggressive President Joe Biden downplayed his bad performance in last week’s debate in what had become a high-stakes appearance on ABC, as speculation about his candidacy’s future circulated.
During his discussion with anchor George Stephanopoulos, Biden dismissed the idea of resigning from the ticket while simultaneously presenting changing justifications for his bad performance.
The conversation was Biden’s first public interview since his debate performance, and it came at a critical time for his political future. A growing number of Democrats—lawmakers, contributors, and voters—expressed doubts about his candidacy’s viability.
Here are six key points from Biden’s interview with ABC News.
Biden claims the debate was a ‘poor night,’ not a larger issue.
The president admitted in the interview that he was “sick” and “feeling terrible” prior to the debate. When asked if it was a bad incident or a symptom of a more serious ailment, Biden downplayed the concerns.
“This was a poor episode. There is no evidence of a major condition. “I didn’t listen to my instincts in terms of preparation, and I had a bad night,” he admitted.
6 Takeaways From President Joe Biden’s High-Stakes ABC Interview
In the interview, Biden elaborated on how he was feeling during the debate, stating that he was exhausted from illness and had even tested for Covid-19. The White House did not immediately reply to CNN’s questions on whether the president took the test before or after the debate.
He stated, “I was feeling dreadful. In fact, when I asked the doctors if they had done a Covid test, they said they were attempting to figure out what was wrong. They ran a test to discover if I was infected with a virus. I did not. I simply got a very severe cold.”
The revelation regarding his illness was the latest shift in the White House’s portrayal of the president’s physical condition during the debate. During the discussion, White House officials stated that the president had a cold, and on Wednesday, press secretary Karine Jean-Pierre denied that Biden had visited his doctor, repeatedly stating that the president had not had a medical exam since his physical in February.
“It is a cold, gentlemen. “It’s a cold,” she explained at the time. “I understand that it impacts everyone differently. We’ve all had colds; therefore, the doctor didn’t check him out.”
A day later, the White House verified that the president had indeed seen a doctor about his condition, and on Friday, Jean-Pierre told reporters aboard Air Force One that Biden had a “verbal check-in” with his doctor following the debate.
She described Biden’s check-in as “a conversation” with his physician, Kevin O’Connor after reporters reported that the president informed a gathering of Democratic governors that he had seen a doctor.
The president admits to bad performance but provides a fresh reason.
The president stated that he had not watched a repeat of his performance. When questioned if he knew how awful things were going, he replied, “Nobody’s fault but mine.”
Biden’s response to the question was confused about New York Times polls.
“I prepared what I always do sitting down when I return as foreign leaders or the National Security Council – for explicit detail. And I noticed, about halfway through, that all I get mentioned is that The New York Times had me down 10 points prior to the debate, nine now, or whatever. The truth is that, from what I saw, he lied 28 times,” he stated.
When pressed on his performance, he replied, “Well, I was just having a bad night.”
But later in the conversation, Biden provided a different answer. He said he was distracted by Trump speaking out of turn even though Trump’s microphone was muted.
“I understood I was having a difficult night when I noticed that even while I was answering a question and they switched off his microphone, he was still shouting. I let it distract me. I’m not blaming anything on it, but I recognized I simply wasn’t in control,” Biden told Stephanopoulos.
Biden, Trump, and their teams agreed on the rules before the debate.
Biden stated that “no one said I had to” undergo cognitive and neurological testing, telling Stephanopoulos that “I get a full neurological test every day” – referring to his job responsibilities.
“I have medical doctors who travel everywhere. You are aware that every president does this. I am accompanied by world-class medical doctors wherever I go. I am always evaluating my work. “They don’t hesitate to tell me if they suspect anything else is wrong,” he said.
When asked if he had any cognitive testing or a neurology checkup, Biden responded no.
“No one told me I had to… “They said I was fine.”
In a Friday analysis, CNN Chief Medical Correspondent Dr. Sanjay Gupta, a practicing neurosurgeon, asked Biden to undergo extensive cognitive and neurological testing and report his findings.
Gupta expressed concern about Biden’s performance during the debate. According to him, comprehensive examinations “can help determine whether there is a simpler explanation for the symptoms displayed or if there is something more concerning.”
Biden rejects polls that show him losing to Trump.
When Stephanopoulos asked Biden if he was honest with himself about his capacity to overcome Trump, he responded, “Yes.” “Yes, yes, yes.”
He cited prior surveys that suggested he couldn’t win in 2020 and subsequent down-ballot elections while dismissing comprehensive polling that shows he is lagging in the race.
When asked if his low approval rating would make it more difficult to win four years later, Biden replied, “Not when you’re running against a pathological liar. Not when he hasn’t been challenged in the same way that he is about to be.”
The president stated that all his pollsters regard the race as a “toss up” as he cited particular polls before trailing off.
Biden dismisses worried Democrats: Only the ‘Lord Almighty’ could persuade him to withdraw from the race.
When asked if he would step aside if he became persuaded he couldn’t win Trump, Biden responded he would only do so “if the Lord Almighty comes down” and tells him so.
“If the Lord Almighty came down and said, ‘Joe, get out of the race,’ I’d get out of the race,” stated Vice President Biden.
“The Lord Almighty’s not coming down,” said Biden, a devoted Catholic.
Stephanopoulos replied, “I agree that the Lord Almighty will not come down.” But what will you do if you are reliably informed by your allies, friends, and supporters in the Democratic Party, the House, and the Senate that they are frightened you will lose the House and the Senate if you remain?
Biden declined to address the question. “It’s not going to happen,” he explained.
The president later questioned whether any other Democratic leader would possess his foreign policy expertise.
“Who will be able to hold NATO together as I can? Who will be able to put me in a position to keep the Pacific basin in check now that we are in China? Who’s going to do it? “Who has that reach?” Biden asked.
Four Democratic members of Congress have urged Biden to step aside. Massachusetts Gov. Maura Healey published a statement Friday, urging Biden to “carefully evaluate” whether he is the party’s best candidate to oppose Donald Trump. According to CNN, Virginia Sen. Mark Warner is trying to get Senate Democrats on the same page regarding Biden’s reelection attempt, placing additional pressure on the White House.
Warner, who is leading the effort, has reached the point where he believes Biden’s reelection campaign should be suspended, according to a source familiar with the situation.
When asked about Warner’s efforts, Biden said, “Mark is a good man.” He also attempted to secure the nomination. Warner was considered a vice presidential candidate in 2008, a position Biden subsequently won but withdrew from consideration.
“Mark’s not—Mark and I have a different perspective,” Biden told Stephanopoulos.
Biden | Rolling stoneg
6 Takeaways From President Joe Biden’s High-Stakes ABC Interview
When asked if he would alter his stance if additional high-ranking Democrats, such as Senate Majority Leader Chuck Schumer, former House Speaker Nancy Pelosi, or House Minority Leader Hakeem Jeffries, persuaded him to drop out, Biden replied, “They’re not going to do that.”
Just before the ABC interview, Biden addressed voter concerns at a campaign rally in Wisconsin. A rallygoer displayed a banner that read, “Pass the torch, Joe.” The placard was visible briefly before someone attempted to conceal it with a Biden-Harris sign.
Biden’s remarks at that rally was enthusiastic and vibrant, but he appeared to be aware that every word he said would be dissected and carefully scrutinized during this strategically critical era. He vowed to “beat Trump again in 2020” before swiftly recognizing his error and amending himself: “By the way, we’re gonna do it again in 2024.” Biden criticized Trump’s economic policies, saying his opponent “wants another 5 billion – trillion, trillion, not billion – $5 trillion tax cut.”
He answered criticism regarding his age, stating, “I wasn’t too old to create over 50 million new jobs, ensure 21 million Americans are insured under the Affordable Care Act, and beat Big Pharma.” Was I too old to help over 5 million Americans with college debt? Too elderly to appoint the first Black woman to the Supreme Court of the United States? To sign the Respect for Marriage Act?
Biden claimed unspecified forces are “trying to push him out of the race.”
“Well, let me say this as quick as I can,” he joked. “I’m staying in the race.”
That theme was highlighted by the song that played at the end of Biden’s speech: Tom Petty’s “I Won’t Back Down.”
SOURCE – CNN
LONDON — British Prime Minister Keir Starmer announced on Saturday that he is abandoning a contentious Conservative policy of deporting asylum-seekers to Rwanda, promising to fulfill the voters’ mandate for reform, though he warned that it would take time.
“The Rwanda scheme was dead and buried before it started,” Starmer stated at his first press conference. “It has never functioned as a deterrent. “Almost the opposite.”
Starmer told reporters in a wood-paneled chamber at 10 Downing St. that he was “restless for change,” but refused to say when Britons would see changes in their standard of life or public services. His Labour Party inflicted the most devastating blow to the Conservatives in their two-century history on Friday, winning by a landslide on a program of change.
Starmer | AP news Image
New UK Prime Minister Starmer Says Controversial Rwanda Deportation Plan Is ‘Dead And Buried’
The 30-minute question-and-answer session came after his first Cabinet meeting. His new government faces the daunting task of addressing a slew of internal issues while also winning over a population weary of years of austerity, political upheaval, and a wounded economy.
“We have a huge amount of work to do, so let’s get started,” Starmer said as he welcomed the new ministers to the table at 10 Downing Street. He stated it had been the greatest honor of his life to be asked by King Charles III to form a government in a ceremony that officially promoted him to prime minister.
“Just because Labour won a big landslide doesn’t mean that all of the problems that the Conservative government has faced have gone away,” said Tim Bale, professor of politics at Queen Mary University of London.
In his first words as prime minister Friday after the “kissing of hands” ceremony with Charles at Buckingham Palace, Starmer said he would go to work right once but warned that results would take time.
“Changing a country is not as simple as flipping a switch,” he remarked as ecstatic fans cheered him outside his new official residence at 10 Downing Street. “It’ll take a while. But there is little doubt that the job of change begins immediately.”
Following the six-week campaign, he will have a hectic schedule, traveling to each of the four nations of the United Kingdom—England, Scotland, Wales, and Northern Ireland—that he claims voted for Labour.
He will next go to Washington for a NATO meeting on Tuesday before hosting the European Political Community conference on July 18, the day following Parliament’s official opening and the King’s Speech, which outlines the new government’s agenda.
Starmer singled out several major issues on Friday, including fixing the revered but crippled National Health Service and securing its borders, alluding to a larger global issue of absorbing an influx of migrants fleeing war, poverty, drought, heat waves, and floods caused by climate change.
Conservatives struggled to slow the flood of migrants crossing the English Channel, failing to keep ex-Prime Minister Rishi Sunak’s promise to “stop the boats” that led to the contentious Rwanda plan.
Starmer’s decision on what he dubbed the Rwanda “gimmick” was widely predicted given that he had previously stated that he would not carry out the plan, which cost hundreds of millions of dollars and had never taken flight.
It’s unclear what Starmer would do differently to address the same situation, which saw a record number of refugees arrive on shore in the first six months of the year.
“Labour is going to need to find a solution to the small boats coming across the channel,” Bale told the crowd. “It’s going to have to come up with other solutions to deal with that particular problem.”
Starmer | AP News Image
New UK Prime Minister Starmer Says Controversial Rwanda Deportation Plan Is ‘Dead And Buried’
Suella Braverman, a Conservative hardliner on immigration who could replace Sunak as party leader, slammed Starmer’s decision to dissolve the Rwanda accord.
“Years of hard work, acts of Parliament, millions of pounds been spent on a scheme which had it been delivered properly would have worked,” she tweeted on Saturday. “There are big problems on the horizon which will be I’m afraid caused by Keir Starmer.”
Starmer’s Cabinet is also going to work.
Foreign Secretary David Lammy was to go on his first international trip Saturday, meeting counterparts in Germany, Poland, and Sweden to emphasise the importance of their partnership.
Health Secretary Wes Streeting said he would resume talks with NHS physicians at the start of their careers next week after they launched a series of multi-day strikes. The wage conflict has exacerbated the NHS’s high wait times, which have become a defining feature of its issues.
SOURCE – (AP)
On Thursday, Patrick Bertoletti a 39-yearold Chicago native chocked down 58 hotdogs in 10-minutes to win his men’s title at the annual Nathan’s Famous Fourth of July hot dog eating contest. While reigning champion Miki Sudo set a new world record of 51 hotdogs to win her tenth victory in the women’s tournament.
The current men’s champion, Joey “Jaws” Chestnut, who has won 16 of the last 17 events, opted not to attend this years Nathan’s Famous Fourth of July event due to a disagreement with his sponsor. Instead he competed later in the day against four soldiers at a U.S. Army base in El Paso, Texas, where he wolfed down 57 hot dogs in five minutes, AP reported.
The 39-year-old Chicagoan Bertoletti beat out thirteen international rivals in a close 10-minute race in which the lead changed hands multiple times. He claimed to have trained for the event for three months with “an urgency” and shed pounds in the belief that he could win.
According to Bertoletti, “I knew I had a shot” when Joey was not present. “I found a way to open something, but I have no idea what it was.”
At the annual Independence Day festival on New York’s Coney Island, a beachside attraction featuring amusement parks and summer atmosphere, Bertoletti shattered his previous record of 55 hot dogs in 10 minutes.
Miki Sudo – Getty Images
New World Record Set
Earlier, in the women’s division, 38-year-old Florida dental hygiene student Sudo maintained her dominant performance and set a new record, following her successful consumption of 39 1/2 hot dogs in 2023.
“I’m just happy to call this mine for another year,” Sudo remarked after winning the pink belt.
Mayoi Ebihara of Japan, a 28-year-old participant, finished second after devouring 37 hot dogs, but Sudo still managed to overcome 13 of her rivals. She finished in second place in 2023 as well.
In the men’s division, Sudo consumed more hot dogs than her competitor, Nicholas Wehry, a former Florida bodybuilder. Wehry ate 46 hot dogs. This is the first time since 2015 that the prestigious mustard belt has not gone to Chestnut; Bertoletti does it.
Every year, thousands of people gather outside the original Nathan’s on Coney Island for the event, with some donning foam hot dog hats. Even without Chestnut, the event drew a large crowd, according to Rich Shea, CEO of Major League Eating, who organized the gathering.
According to him, the well-known eating champion is “just a great competitor, a great guy, a grown man, and a man who’s made a choice not to be here today” (ESPN). Tens of thousands of people are swarming around Nathan’s Famous, which is quite lucky for us. It’s an annual journey. You won’t find a paid Hollywood crew here.
Contestants from around the world
With hopefuls from Brazil, Japan, the UK, South Korea, Australia, and the Czech Republic among the more than a dozen states and five continents competing for the prestigious title and $10,000 reward money, the event was truly global in scope.
Chewing his way to victory last year, Chestnut of Indiana devoured 62 dogs and buns in under 10 minutes. He set the record in 2021 with 76.
An earlier decision to not invite Chestnut stemmed from his sponsorship arrangement with plant-based meat alternative company Impossible Foods, which ran ads on ESPN during Thursday’s event.
Chestnut chose to celebrate the holiday with the military despite Major League Eating’s subsequent statement that it rescinded the prohibition. If the Coney Island contest did not accept his apologies, Chestnut threatened to withdraw from it.
Joey “Jaws” Chestnut – Getty Images
Joey “Jaws” Chestnut downs 57 hotdogs
An Army base, which is not easily accessible by the public, was the site of the El Paso incident. Despite this, a few hundred Chestnut supporters turned out, with some donning hotdogs costumes and one sporting a “Let Joey eat” T-shirt. Out of the four men from Fort Bliss, who consumed a total of 49, Chestnut managed to consume 57 hotdogs.
Chestnut had voiced his concern before the show that he would struggle to perform without the enthusiastic backing of the Coney Island audience. However, he later claimed to have achieved a “record-setting pace.”
Speaking to the Fort Bliss crowd, Chestnut expressed his admiration for them after paying tribute to his family’s military service: his father, grandfather, and brother. “You all gave me a tremendous push, and I’m really grateful.”
Despite the non-inclusion of Impossible Foods’ vegan products in the competition, the company served as event sponsor. Along with Chestnut and officials from the charity Operation Homefront, who assist military families, company CEO Peter McGuinness made an appearance on stage. He gave the group a check for $106,000, or $1,000 for every hot dog consumed.
Source: The Associated Press
People Also Reading:
Heat Waves are Getting More Dangerous in Europe for Tourists
Heat Waves are Getting More Dangerous in Europe for Tourists
-
News4 weeks agoFIA Warns of Rising WhatsApp Hacks Targeting Women
-
Sports4 weeks ago
Edmonton Oilers Goaltender Stuart Skinner’s Play Is The Biggest Uncertainty In The Stanley Cup Final
-
News4 weeks ago
Police Pepper Spray Antisemitic Protesters at McGill University, 15 Arrested
-
World4 weeks ago
Will North Korea Fly Trash Balloons Into South Korea Again? A Look At Rising Tensions Between Them
-
Celebrity4 weeks ago
Woman Who Says She’s The Real Martha From ‘Baby Reindeer’ Sues Netflix For Defamation
-
Health4 weeks ago
Man Dies After H5N2 Bird Flu Infection
