kimmy

Waiting for the facts, or inventing their own, *cough*cough*orbitalfracture*cough* -k

It has been interesting to see how the argument on this issue has split almost completely along political lines. Democrat: "bad cops". Republican: "bad urban youths". -k

Suuure, that's probably exactly what the blogger assumed people would think. That's probably why he erased "University of Iowa" from the image. He didn't think a detail like that was necessary, since it was so readily apparent that it was just an example X-ray. -k

In an ideal world, that's how accounting would work. But it's not an ideal world. One good thing that came from Mitt Romney's run for the presidency is that we got to look into his financial past. On his personal finances, we learned about things like the "charitable remainder unitrust" (which Mitt uses to claim very large charitable donations without actually donating much money), as well as what an awesome advantage it is if you can get paid in capital gains instead of wages. On the corporate side, we learned about the "Son of B.O.S.S." scam, which Romney oversaw at Marriott when he sat on the Board of Directors as head of the Audit Committee. The IRS was able to put an end to Son of BOSS, but not before billions of tax dollars were lost to companies like Marriott. Only CPAs can really understand it, but it apparently involves shorting yourself on bonds, creating a partnership with a subsidiary of yourself, using the money from your short sale buy into the partnership, ending the partnership, and when you have to make up the short sale, it's a "loss" that you can claim on your taxes. Or could claim, up until the IRS put an end to it after about 10 years of such shenanigans. Son of BOSS was invented by the friendly folks at KPMG, one of the "Big Four" of the management accounting world. Another of the "Big Four", Ernst & Young, is involved in another tax controversy going on in the UK over tax evasion. They invented a scheme called "Project Sussex" for one of their clients, Greene King (a chain of breweries and pubs and restaurants that's a big deal in the UK apparently) to perform, in the words of the government lawyer prosecuting the case: "transactions ... structured in the curious way ... in order to attempt to take advantage of a perceived loophole in the loan relationships legislation so as to achieve a tax mismatch within the Greene King group." And at this point you're probably saying "yeah but the regulators caught up to Son of BOSS and Project Sussex!" Well, yeah. That's why I can write about them: they've already been found and challenged. What else is out there that the tax investigators don't even know about yet? What else is out there that they know about but can't do anything about? One that falls into the latter category is the "Double Irish Dutch Sandwich" that Google and others are using. This one involves exploiting loopholes in the tax codes of Ireland and Holland, plus using a tax haven like Bermuda. Money is shuffled around between the three countries in a circuit of transactions that exploits peculiarities in the laws of each country, with the result that Google's global tax rate is under 5%. If your yardstick is "could there be a legitimate reason for structuring their business this way?" then the answer depends on your definition of "reasonable". There's only one reason to structure their business this way: to avoid paying tax. Whether that's a "legitimate" reason is kind of irrelevant. If there were no tax loopholes to exploit, it is obvious that no company would bother with this ridiculous series of accounting shenanigans, but it turns out that many very successful companies are doing exactly that. Well, it turns out that Reuters has done some investigation on the subject. Starbucks continually moans that doing business in England is hard and they can't turn a profit... but in conference calls with investors, they're delighted with the success of their English operations. Here's why the English operation can't turn a profit: -paying higher-than-industry-average royalties for use of the Starbucks and name and trademarks to the rights-holder. The rights-holder being Starbucks of Seattle? No, silly, the rights-holder being Starbucks of Amsterdam, obviously. 6% of gross sales goes straight to Holland in the form of royalties payments. -intercompany loans, as you suspected. Starbucks' UK operations are financed by borrowing from the International Bank of Starbucks, at an intercompany loan rate of LIBOR + 4%. Do you pay LIBOR + 4% to borrow money? I don't pay LIBOR +4% on my mortgage or line of credit. Unemployed hobos don't even pay LIBOR + 4% on their subprime mortgages. -buying coffee from their Swiss subsidiary, as I suspected. No word on whether it costs $140/lb, though. 84% of Starbucks' revenue goes to Switzerland, where it's taxed at 5%, to pay for coffee beans and other raw materials. Add that to the 6% royalties payments, and fully 90% of Starbucks' UK revenue is leaving the country. Why can't Starbucks UK turn a profit? Because they've found ways to shift so much money to Starbucks operations in Switzerland and Holland that they can report a loss every year. Interestingly, Starbucks has opted to voluntarily decline some of their tax deductions and pay a total of $20 million pounds in tax for 2013 and 2014. Why? Did they discover a conscience? Well, it turns out that this issue turned into a public relations nightmare for Starbucks and resulted in a popular boycott of Starbucks. Britons opted to take their business across the street to Costas, a domestic coffee chain that pays taxes and doesn't have international tax shelters. If would be cool if that caught on. Unfortunately, we can't really stage a popular boycott of our tax dodging uranium mine. And yet a guy like our old friend Mitt, who let us see his tax records a couple of years ago, pays far less than he would if he were payed in income, largely because he can collect it in the form of capital gains that are taxed at a much lower rate. Mitt had to leave tax deductions on the table so that he could bring his tax bill up to the 13% effective rate that he claimed he paid most years. What is "not reasonable" is expecting the IRS to overlook billions of dollars of tax evasion because some sad old lady in Toronto doesn't want to hire an accountant. I believe that the large majority of Americans living outside the United States are doing so because they're employed in well-paying occupations that should allow them to easily hire an accountant if they wish to. You know, circumstances change, and sometimes people have to change with them. I know old-people who can't spend winters in Arizona anymore because the cost of medical insurance has gotten too high. Maybe if living abroad is becoming too expensive for Ms Sheila, she should head on home. Life's rough. There's lots of housing available a short drive away in Detroit, super-cheap. Good value! -k

American conservatives are (literally) praying that Michael Sam doesn't make it. -k

So about that alleged "orbital fracture" that Officer Wilson had. I don't know if this has been posted yet, but the blog Little Green Footballs did some research into that rumor. http://littlegreenfootballs.com/article/43751_Jim_Hofts_Unsourced_Claim_That_Officer_Darren_Wilson_Had_an_Orbital_Blowout_Fracture_of_the_Eye_Socket One interesting thing he found is about the CT scan image that accompanied the claim that Wilson had suffered an "orbital blowout fracture." The picture to the left is the original image. The picture to the right is the picture as it appeared in the "Gateway Pundit" Jim Hoft's blog. Notice the difference? It's in the lower right corner of each image. In the picture to the right, the "Univ of Iowa" is erased. The picture is posted immediately below a caption that reads: And an unsuspecting reader would likely draw the conclusion that the image is a CT scan of Officer Wilson, not a CT scan that the "Gateway Pundit" found on the internet. Little Green Footballs notes that a lot of people fell for it: Little Green Footballs' second point concerns the physiological effects of an "orbital blowout fracture". Swelling, nose-bleed, double-vision. But watching the video of Officer Wilson immediately after the shooting... does this look like a guy suffering any of those symptoms? Does the guy in the video act as if he's just suffered a fractured eye socket? He's walking completely upright, with no apparent bleeding and no visible sign of any discomfort. He doesn't touch his face once in this video. In the course of my sparring, I've been popped in the nose and the eye more than a few times, and in my experience, it's hard not to touch it. As soon as my gloves are off, my immediate compulsion is to touch my face where I got hit. Feel for swelling or other damage. Check my nose for blood. Try to massage some sting away. It's reflexive to put your hand to an injury, but this guy doesn't bring his hand to his face the whole video. -k

It might tell us what we need to know about the Michael Brown shooting, but it won't shed any light on animosity between the police and the citizens that clearly goes back farther than this one incident. -k

I doubt it's worse than water-skiing on either the money or the energy front. Waterskiing tow boats are absurdly expensive. Boats in general are absurdly expensive. I went to a boat show this spring and was utterly floored at the price of the boats on display. Like high 5 figures at the low end, all the way up to $350,000. Insane. -k

Sure, now that there are outside parties involved, "let's let the investigators do their job" is a reasonable request. But you'd have to be a king-sized sucker to believe that the Ferguson PD would be getting any of this outside scrutiny if rioting hadn't broken out. It's unfortunate that it takes something this extreme to bring attention to a situation, but that seems to be where things are at. -k

Except the Trudeau family wasn't robbed. Some stuff was moved around and a threatening note was left behind. But nothing was removed. So an attempt to link this incident to his father's views on property rights seems rather labored, to say the least. -k

Wait, you're not retired yet? How do you have time to be on the forum 18 hours a day when you have a job? -k

It is the duty of law enforcement authorities to maintain an environment where "let's calm down and trust the investigators to do their job" is a reasonable request instead of a punchline. Ferguson is a town where the police charged a man with destroying public property because he bled on their uniforms while they were stomping his face in, and received no sanction at all. "Let's trust the investigators" is not a reasonable request for people in Ferguson. -k

I wasn't attempting to point out an exhaustive list of loopholes. I was pointing out that "costs of doing business" is a term that encompasses more than just the basic costs of building your widgets, and subject to abuse. Suncor has an army of accountants looking for ways to make the "costs of doing business" appear as high as possible without actually spending money on anything. If a company is still paying financing costs for opening a few hundred store locations after 12 years and 3 billion British pounds in revenue, it seems likely that there's shenanigans involved. Perhaps they borrowed money at 140% interest from the same hypothetical Swiss holdings company that hypothetically sells them their coffee at $140/lb. There's not enough information to claim that any law is being broken, but there's information enough to concluded that legal or not, it's absurd. The Ontario resident in question is still paying most of his taxes to the federal government, and Quebec is going to get the difference made up in the form of transfer payments anyway. Whichever side of the river he lives on, his taxes are ultimately paying to assure a standard of living in Canada. If he gets hurt in a traffic accident, he's getting cared for in a hospital that his own tax dollars are helping pay for, whichever side of the river he got hurt on. On the other hand we've got these big companies that do business in Canada, take advantage of stable Canadian law and order and infrastructure and education system, but don't pay a fair share of operating those things because they have a phone booth on the Cayman Islands that's supposedly their head office. I don't think the comparison is accurate. If you're right that there's nothing we can do about companies avoiding Canadian taxes, then that's a good argument for increasing taxes on dividends. If dividends are how we're supposed to get the tax money that these corporations aren't paying, then there's no reason for dividends to be taxed at a much lower rate then other forms of income, is there? I gather that the rational for this low tax rate is supposed to be that profits are already supposed to be taxed once, but we apparently can't ensure that actually happens. Well, as you said above, the plural of anecdote is not data. This sad old lady apparently has to pay $350-$500 to do her taxes... but what if she did them herself instead? Doing your taxes is something each of us has to live with, one of the costs of living in our society. Sorry. The amount of money that vanishes out of Canada to offshore tax havens each year is in the billions, and in the United States one expects the cost is proportionately larger. At a time when budgets are under extreme pressure, I don't think it's realistic to expect the IRS to overlook vast sums of money being heisted out of the country just because Sheila in Toronto has to pay an accountant once a year. -k

This is a difficult question. On the one hand, this is essentially a vigilante group. It's a digital lynch mob. They could completely ruin an innocent person's life. There's no accountability, no assurance that any sort of fairness results. On the other hand, I believe that this sort of vigilante action occurs in response to failure by the authorities to maintain the confidence of the public. Consider the participation of Anonymous in the Steubenville rape case. Anonymous had a direct role in embarrassing the authorities into taking action. A female blogger had reported about the incident first, and the New York Times posted about it shortly after that, but it wasn't until Anonymous got involved that the situation became so inflamed that the local authorities were forced to take action. The threat of mob justice is one reason why justice needs to be done but also needs to be visible. In today's society, where we don't have lynch mobs anymore, perhaps the law enforcement community has lost sight of what can happen if the people no longer trust the police to provide justice. That's what happened in Steubenville. But we still have lynch mobs, and they carry laptops instead of torches and pitchforks. Yes, we know. And the starter of this thread stated his reasons for making this thread separate. -k

On the nonsense scale, how does "nonsensical nonsense" compare with "complete nonsense"? If complete nonsense is 100% nonsense, is nonsensical nonsense like an 80% or 90%? -k

Because somebody is still going to get elected. Even if you don't see a "good" option on the ballot, there are still differing degrees of "bad". -k

Good luck to you, jbg. I hope that you'll be able to find a worthwhile way forward. Sometimes experienced professionals who find themselves out of work take their expertise and industry knowledge and use it to start a new business of their own. For others, it's a chance to try something completely new. Whatever you decide, it's a challenging time. -k

What makes you think our teachers are managing badly? If I recall correctly, Canada's education system ranks among the world's best, and the amount of information students learn today is higher than in the past. I'm curious why you've decided our education system is doing "so badly". Compared to what? Compared to Hong Kong and Finland? Compared to "the good old days"? This sounds like the kind of grumbling I overhear from senior citizens, not an analysis based on any sort of facts. "Bah, let me tell you, when we went to school, we learned the 3 Rs. Now kids are learning all this computer stuff but they can't even spell or do math anymore. They need to go back to the basics! That's what's wrong with kids these days!" Just more old-people BS. Do you have any metrics to support this conclusion? Do you have any specific complaints about the curriculum? Do you even know what's in the curriculum? Please elaborate on why you feel our education system is doing such a bad job. As for the proposition that Steve Jobs has succeeded at something the education system has failed at, it's fault. It falls on its face. Rather than explain why in my own words, I'll quote something a guy named August1991 wrote a few days ago: The education system is not tasked with building a user interface so simple that even Islamic militants can use it. The education is tasked with teaching what a square root is and why you might need to calculate it, which is something you already stated that Jobs did not achieve. -k

Jobs wasn't out to develop a "teaching method". Jobs was out to develop a successful personal electronics device. He succeeded. Cell phones and portable computing devices existed long before the iPhone. It was never assumed that they were somehow intended to bring education to third worlders. Computers can be used to perform scientific calculations, or they can used to play silly games. Then again, so can a stick of charcoal. I also question why you've drawn a distinction between a slide-rule and a calculator. Does the guy operating a slide-rule necessarily need to know math better than the guy operating the calculator? Both guys are just following a set of steps to get an answer out of a device. They don't need a fundamental understanding of the underlying mathematics; they just need to know the correct sequence of steps. In the case of the slide-rule, the actual mathematics was done by the guy who marked the lines on the device in the correct spacing. I've got a watch here with a slide-rule on the bezel. It's pretty cool! Say I want to multiply 12 by 17. I just turn the bezel so that the 12 on the outer ring lines up with the 10 on the inner ring. Then I follow the inner ring out to the 17, and the 17 on the inner ring lines up with about halfway between 20 and 21 on the outer ring. And I multiply by 10, and behold! 205! Pretty close to the correct answer. I have no idea how any of this works! The guy who decided where to put the numbers on the inner and outer rings obviously did a whole lot of careful calculations, but I don't need to know he did it. I just need to know the right steps. It might as well be a magic incantation. Poke buttons, spin the bezel to the right location, ask Siri, ask a Magic 8 Ball, what's the difference? -k

The article I quoted put the stats into some context. A couple of key points from my article: -the raw number of arrests doesn't indicate how many of those arrests were in conjunctions with other crimes. The president of the Criminal Lawyers Association indicated that marijuana possession charges are typically not laid alone and are often used as a means for police to investigate other issues. So while the pro-pot people would probably like you to picture a typical marijuana arrest as being a young-person minding their own business when suddenly a big fascist cop jumps out of the bushes and shouts "A-HA!!!" the typical situation is more like the cops have already been called out for some reason-- noise complaint, trespass, neighbor suspicious of domestic violence, or so on, and the cop sees or smells marijuana and uses that as a foot-in-the-door tactic. -there are situations where it might be a good thing that the cops can charge somebody with possession. For example, the article mentioned that the cops often look the other way, but not if the person happens to be driving while they're stoned. Personally, I think that if you're driving down the road puffing on a big fat joint and the cops pull you over, you *should* face criminal charges. I think it's slightly important. I'll pay much more attention to what the parties positions on CPP and OAS are, though. -k

http://www.cbc.ca/news/canada/marijuana-crime-are-police-turning-a-blind-eye-to-pot-charges-1.2733396 ... ... -k

None of that actually addressed what I said. There may have been a large number of marijuana arrests, but how many result in jail time? Despite claims to the contrary, there's still not a mandatory minimum sentence for simple possession. There are mandatory minimums for production (6 or more plants), possession for purposes of trafficking, and possession for purposes of import or export. You guys seem to be insinuating that the Conservatives are filling the prisons with people convicted for simple possession, but I still have not seen any evidence that it's so. -k

How many Canadians actually do jail time for using marijuana, or possessing it in recreational quantities? I have a hunch that the number is actually miniscule, despite what pro-legalization activists might want you to think. Don't get me wrong, I'm all in favor of smarter laws around marijuana, and if the experiments in Washington and Colorado are successful, I'd support legalization too. But I see marijuana laws as an issue of minor importance, they are not something that will decide my vote. -k

If someone deliberately inflected someone else with AIDS, and the victim lived for many years before succumbing to the disease, I think most people would agree that it was murder. Take a really ridiculous hypothetical: a James Bond villain implants a bomb in someone's chest, and it has a 30-year timer on it, I think it most people would agree that it was murder. I don't know the specifics of Mr Bradley's injuries, but it's plausible that he could have lived for many years before dying from the effects of the injuries. For example, suppose fragments from the bullet were in his brain and it was deemed that it was more dangerous to remove the fragments than let them stay. Eventually a fragment shifts and inflicts a new injury that kills him. Or suppose that the gunshot inflicted some sort of medical condition that carries an increased health risk and much later killed him. I think there are situations where it's plausible to say he died from the gunshot but took a long time to die. -k

I have been reading that Robin Williams has long struggled with bipolar disorder, which makes this sad event somewhat understandable. -k