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-   -   Meet your new thread, same as the old thread. (http://www.lawtalkers.com/forums/showthread.php?t=781)

sgtclub 07-12-2007 03:36 PM

Question
 
Quote:

Originally posted by Greedy,Greedy,Greedy
Now, clubby, should the guy be more interested because it's no longer just a financial transaction or less interested because once it's not a financial transaction he expects less? Or should Gwink lose interest because she's not gotten her dinner paid for?
He should be suspicious. Why is this hot chick, who can have her meals paid for by any dude out there, buying my dinner. She's either crazy or it's a set up and he's going to awake in the morning wihthout his wallet or kidneys.

Secret_Agent_Man 07-12-2007 03:41 PM

When it rains.
 
Quote:

Originally posted by Greedy,Greedy,Greedy
From the above discussion, it is now clear. He was just looking to buy dinner.
He has apparently made a public denial.

I can only imagine his defense:

"Your Honor, there were debris lying on the floor near the officer.

"It seemed untidy, and not fitting for a public facility in this great State, you see.

"So, I walked over, bent down and told him I wanted to _chuck_ the _sticks_. Chuck the sticks. That's right.

"He must have heard wrong. Simple misunderstanding. Really."

S_A_M

SlaveNoMore 07-12-2007 04:01 PM

When it rains.
 
Quote:

Greedy,Greedy,Greedy
But for that bit of HypocRisy, who cares?
Does this mean I'm now allowed to use the word SurrenDer whenever taking about Democrat foreign policy?

Diane_Keaton 07-12-2007 04:01 PM

Question
 
Quote:

Originally posted by Replaced_Texan
It was pretty evenly split down the middle with my ex-boyfriend.
It has always seemed the guy wants to pay when its dinner. Though he's treating the gal monetarily, I think there's other ways to "treat" him too (um...besides blowjobs) related to the dinner. I always comment on the great choice he made for the restaurant - he may have put a lot of thought into it. Or it may be his old stand by and he'll be thrilled you like it too. Seeing as there is usually at least one outstanding thing at the meal (even if it's just the joint's coffee) I mention a few times that such and such is really good. Guys seem to really love that. E.g.: I commented on how yummy my spice rub was during and then after dinner, and my date seemed so happy he acted liked he'd MADE the darned thing. Being on time for the dinner, showing you are having a nice time, etc. etc. Seems to me the guy appreciates it more than splitting the bill.

Trickier is if the guy is dirt poor (e.g., my type) There are ways to deal with it. Mixing dinners with home cooked meals, romantic picnics. Stuff.

You could also take him out for dessert afterwards at another place (like ice cream) and foot the bill. Another good dessert is to let him pick out anything he wants at the pooty store. But then we're back to that quasi-prostitution argument.

Greedy,Greedy,Greedy 07-12-2007 04:47 PM

And You Should Ask Paigow if its Derivative
 
Quote:

Originally posted by SlaveNoMore
Does this mean I'm now allowed to use the word SurrenDer whenever taking about Democrat foreign policy?
You can, but you'd be a LiaR like Bush if you did.

Not Bob 07-12-2007 04:50 PM

But mommy's neither one of those, I've known her all these years.
 
Quote:

Originally posted by SlaveNoMore
Does this mean I'm now allowed to use the word SurrenDer whenever taking about Democrat foreign policy?
Surrender? Surrender? Sure. But don't give yourself away.

fair and balanced 07-12-2007 04:53 PM

When it rains.
 
Quote:

Originally posted by SlaveNoMore
Does this mean I'm now allowed to use the word SurrenDer whenever taking about Democrat foreign policy?
"D" is for Democrat and is for Defeatist, coincidence?

Mmmm, Burger (C.J.) 07-12-2007 05:00 PM

They are waiting for you.
 
Quote:

Originally posted by fair and balanced
"D" is for Democrat and is for Defeatist, coincidence?
And for the Dream Police.

fair and balanced 07-12-2007 05:08 PM

Typical, Demorat behavior...
 
NEWARK, N.J. - A federal grand jury Thursday indicted former Newark Mayor Sharpe James on corruption charges involving land sales and allegations that he spent extravagantly on himself and several women using city-issued credit cards.

The 33-count indictment charges James with fraud for allegedly facilitating and approving the cut-rate sales of city-owned land to a female companion.

James is, no surprise, a DEMOCRAT!~

flare up 07-12-2007 05:21 PM

BREAKING
 
ABCs Brian Ross is reporting

Senior U.S. intelligence officials tell ABC News new intelligence suggests a small al Qaeda cell is on its way to the United States, or may already be here.

Officials have released photos of what may be some of the members of this terrorist cell and cautioned all Americans to be on the look out. The potential cell members are pictured here below......

http://static.flickr.com/110/294841050_9925088ed5_o.jpg

fair and balanced 07-12-2007 05:38 PM

BREAKING
 
Quote:

Originally posted by flare up
ABCs Brian Ross is reporting

Senior U.S. intelligence officials tell ABC News new intelligence suggests a small al Qaeda cell is on its way to the United States, or may already be here.

Officials have released photos of what may be some of the members of this terrorist cell and cautioned all Americans to be on the look out. The potential cell members are pictured here below......

http://static.flickr.com/110/294841050_9925088ed5_o.jpg
thanks for the heads up my felloe patriot, but note, late breaking news is reporting there may be a 7th member of the cell.....



http://760kfmb.com/rick_blog/imglib/preacher_reid.jpg

Gattigap 07-12-2007 05:52 PM

Now that the socks are talking with the socks, it sounds like the echo chamber is set up and ready to go. Whee!

SlaveNoMore 07-12-2007 05:58 PM

Quote:

Gattigap
Now that the socks are talking with the socks, it sounds like the echo chamber is set up and ready to go. Whee!
GGG and Ty are socks?

sebastian_dangerfield 07-13-2007 09:49 AM

They are waiting for you.
 
Quote:

Originally posted by Mmmm, Burger (C.J.)
And for the Dream Police.
Mommy's alright, daddy's alright...

That band will never get its fair due.

sebastian_dangerfield 07-13-2007 09:54 AM

Question
 
Quote:

Originally posted by Diane_Keaton
It has always seemed the guy wants to pay when its dinner. Though he's treating the gal monetarily, I think there's other ways to "treat" him too (um...besides blowjobs) related to the dinner. I always comment on the great choice he made for the restaurant - he may have put a lot of thought into it. Or it may be his old stand by and he'll be thrilled you like it too. Seeing as there is usually at least one outstanding thing at the meal (even if it's just the joint's coffee) I mention a few times that such and such is really good. Guys seem to really love that. E.g.: I commented on how yummy my spice rub was during and then after dinner, and my date seemed so happy he acted liked he'd MADE the darned thing. Being on time for the dinner, showing you are having a nice time, etc. etc. Seems to me the guy appreciates it more than splitting the bill.

Trickier is if the guy is dirt poor (e.g., my type) There are ways to deal with it. Mixing dinners with home cooked meals, romantic picnics. Stuff.

You could also take him out for dessert afterwards at another place (like ice cream) and foot the bill. Another good dessert is to let him pick out anything he wants at the pooty store. But then we're back to that quasi-prostitution argument.
No man is dirt poor if he's into you. He'll find a way to pay.

Unless you're an idiot, every man learns by 25 that he'll never have any real money. You get some crap like a nice car and clothes and some watches and shit like that. nd vacations. But the Cash. That's not yours. Which is fine. WTF would I do with it but waste it on cds and alcohol and piles of clothes I don't need?

I'm going Buddhist. Throwing all material out the window. Except for the expensive food. I can't give up good food.

Greedy,Greedy,Greedy 07-13-2007 10:09 AM

Question
 
Quote:

Originally posted by sebastian_dangerfield
No man is dirt poor if he's into you. He'll find a way to pay.

Unless you're an idiot, every man learns by 25 that he'll never have any real money. You get some crap like a nice car and clothes and some watches and shit like that. nd vacations. But the Cash. That's not yours. Which is fine. WTF would I do with it but waste it on cds and alcohol and piles of clothes I don't need?

I'm going Buddhist. Throwing all material out the window. Except for the expensive food. I can't give up good food.
I am with you completely.

Except that I also don't want to give up the wheels, even if they're somewhat humble. I may go Buddhist, but I'm not going to take the damn train everywhere.

sebastian_dangerfield 07-13-2007 10:23 AM

Question
 
Quote:

Originally posted by Greedy,Greedy,Greedy
I am with you completely.

Except that I also don't want to give up the wheels, even if they're somewhat humble. I may go Buddhist, but I'm not going to take the damn train everywhere.
Buy a good one and take care of it. I'd lease if I could, but I drive too much. I'm going to try to keep the two I have for 200,000 miles. I used to flip them at 60 to 80k, but when you do the math, with all the transfer costs and annoyance built into that cycle, you're better off just keeping a good one for the really long haul. A Japanese or German car will do 200k highway miles easily if you take care of it.

The beaten in thing is nice. The badge just fell off the hood of one of them, and it's a good a pile of dinks on it. Gives it a nice worn in look, and nobody will want to steal it.

SlaveNoMore 07-13-2007 10:55 AM

Question
 
Quote:

sebastian_dangerfield
I'm going Buddhist. Throwing all material out the window. Except for the expensive food. I can't give up good food.
Becoming a Popov vodka guy, eh?

Tyrone Slothrop 07-13-2007 12:34 PM

In 10 years, remember to thank Bush for AQiM.
 
NYT:
  • Al Qaeda in Mesopotamia did not exist before the Sept. 11 attacks. The Sunni group thrived as a magnet for recruiting and a force for violence largely because of the American invasion of Iraq in 2003, which brought an American occupying force of more than 100,000 troops to the heart of the Middle East, and led to a Shiite-dominated government in Baghdad.[...]

    But while American intelligence agencies have pointed to links between leaders of Al Qaeda in Mesopotamia and the top leadership of the broader Qaeda group, the militant group is in many respects an Iraqi phenomenon. They believe the membership of the group is overwhelmingly Iraqi. Its financing is derived largely indigenously from kidnappings and other criminal activities. And many of its most ardent foes are close at home, namely the Shiite militias and the Iranians who are deemed to support them.

    “The president wants to play on Al Qaeda because he thinks Americans understand the threat Al Qaeda poses,” said Bruce Riedel, an expert at the Saban Center for Middle East Policy and a former C.I.A. official. “But I don’t think he demonstrates that fighting Al Qaeda in Iraq precludes Al Qaeda from attacking America here tomorrow. Al Qaeda, both in Iraq and globally, thrives on the American occupation.”

Ezra Klein:
  • AQiM is entirely a creation of our invasion. We have triggered the activation of a new branch of al Qaeda, a branch that has amassed extensive experience in adapting terrorist tactics to urban warfare, has proven our vulnerability, and will endure long after we've left. If we weren't fighting them over there, not only would they not be coming here, but they wouldn't exist in the first place.

linkini

sebastian_dangerfield 07-13-2007 01:03 PM

Question
 
Quote:

Originally posted by SlaveNoMore
Becoming a Popov vodka guy, eh?
No. No. Booze is still a major expenditure.

Which reminds me... It's past noon EST.

ETA: Dug into Knob Creek for the first time in a while two weeks ago. Those 20 units of proof make such a difference. Red Bull and bourbon is just a stupid drink. I can't smash the furniture in my own home.

Even in the basement.

ltl/fb 07-13-2007 01:04 PM

Question
 
Quote:

Originally posted by sebastian_dangerfield
No. No. That's still a major expenditure.

Which reminds me... It's past noon EST.
Are you giving up the house?

sebastian_dangerfield 07-13-2007 01:12 PM

Question
 
Quote:

Originally posted by ltl/fb
Are you giving up the house?
Honestly, I couldn't care less about the house. That makes her happy. I like the performance aspects of things most. It's all a quest to find that sweet spot of perfect irresponsibility and promise you had at 22 and the world works real hard to take away from you for the rest of your life.

I'm working my way back. Slowly.

ltl/fb 07-13-2007 01:13 PM

Question
 
Quote:

Originally posted by sebastian_dangerfield
Honestly, I couldn't care less about the house. That makes her happy. I like the performance aspects of things most. It's all a quest to find that sweet spot of perfect irresponsibility and promise you had at 22 and the world works real hard to take away from you for the rest of your life.

I'm working my way back. Slowly.
Having a kid and a wife who likes her huge, expensive house are really good, solid steps back to that age-22-ness. I can tell you are making real progress. Kudos!

sebastian_dangerfield 07-13-2007 01:14 PM

Question
 
Quote:

Originally posted by ltl/fb
Having a kid and a wife who likes her huge, expensive house are really good, solid steps back to that age-22-ness. I can tell you are making real progress. Kudos!
Like I said, it's slow. I'm a have my cake and eat it kind of guy.

ltl/fb 07-13-2007 01:21 PM

Question
 
Quote:

Originally posted by sebastian_dangerfield
Like I said, it's slow. I'm a have my cake and eat it kind of guy.
OK, so if you aren't giving anything up w/r/t food, drink, housing,* or car, what are you giving up? Did you give away your wardrobe, and are you now wearing the same stuff every day?


*including furniture, apparently.

Greedy,Greedy,Greedy 07-13-2007 01:23 PM

And what about the kid?
 
Quote:

Originally posted by ltl/fb
OK, so if you aren't giving anything up w/r/t food, drink, housing,* or car, what are you giving up? Did you give away your wardrobe, and are you now wearing the same stuff every day?


*including furniture, apparently.
You know, it's possible to have it all and just ignore it.

sebastian_dangerfield 07-13-2007 01:44 PM

Question
 
Quote:

Originally posted by ltl/fb
OK, so if you aren't giving anything up w/r/t food, drink, housing,* or car, what are you giving up? Did you give away your wardrobe, and are you now wearing the same stuff every day?


*including furniture, apparently.
Actually, yes. You really wouldn't want to smell these old swim/surf shorts.

sebastian_dangerfield 07-13-2007 01:44 PM

You Can Always Get What You Want
 
Quote:

Originally posted by Greedy,Greedy,Greedy
You know, it's possible to have it all and just ignore it.
I think they call that not knowing what the fuck you want.

Tyrone Slothrop 07-13-2007 01:55 PM

Paul Krugman:
  • During the 2000 presidential campaign, Ralph Nader mocked politicians of both parties as “Republicrats,” equally subservient to corporations and the wealthy. It was nonsense, of course: the modern G.O.P. is so devoted to the cause of making the rich richer that it makes even the most business-friendly Democrats look like F.D.R.

    But right now, as I watch Senate Democrats waffle over what should be a clear issue of justice and sound tax policy — namely, whether managers of private equity funds and hedge funds should be subject to the same taxes as ordinary working Americans — I’m starting to feel that Mr. Nader wasn’t all wrong.

    What’s at stake here is a proposal by House Democrats to tax “carried interest” as regular income. This would close a tax loophole that is complicated in detail, but basically lets fund managers take a large part of the fees they earn for handling other peoples’ money and redefine those fees, for tax purposes, as capital gains.

    The effect of this redefinition is that income that should be considered by normal standards to be ordinary income taxed at a 35 percent rate is treated as capital gains, taxed at only 15 percent instead. So fund managers get to pay a low tax rate that is supposed to provide incentives to risk-taking investors, even though they aren’t investors and they aren’t taking risks.

I haven't paid attention to this issue at all. Can someone explain to me why this -- particulary, his last sentence -- is wrong?

Shape Shifter 07-13-2007 01:58 PM

Like Rats from a Sinking Ship
 
Crazy liberal Peggy Noonan on W:
  • Americans have always been somewhat romantic about the meaning of our country, and the beacon it can be for the world, and what the Founders did. But they like the president to be the cool-eyed realist, the tough customer who understands harsh realities.

    With Mr. Bush it is the people who are forced to be cool-eyed and realistic. He's the one who goes off on the toots. This is extremely irritating, and also unnatural. Actually it's weird.

http://opinionjournal.com/columnists.../?id=110010326

fair and balanced 07-13-2007 02:00 PM

In 10 years, remember to thank Bush for AQiM.
 
Quote:

Originally posted by Tyrone Slothrop
NYT:
  • Al Qaeda in Mesopotamia did not exist before the Sept. 11 attacks. The Sunni group thrived as a magnet for recruiting and a force for violence largely because of the American invasion of Iraq in 2003, which brought an American occupying force of more than 100,000 troops to the heart of the Middle East, and led to a Shiite-dominated government in Baghdad.[...]

    But while American intelligence agencies have pointed to links between leaders of Al Qaeda in Mesopotamia and the top leadership of the broader Qaeda group, the militant group is in many respects an Iraqi phenomenon. They believe the membership of the group is overwhelmingly Iraqi. Its financing is derived largely indigenously from kidnappings and other criminal activities. And many of its most ardent foes are close at home, namely the Shiite militias and the Iranians who are deemed to support them.

    “The president wants to play on Al Qaeda because he thinks Americans understand the threat Al Qaeda poses,” said Bruce Riedel, an expert at the Saban Center for Middle East Policy and a former C.I.A. official. “But I don’t think he demonstrates that fighting Al Qaeda in Iraq precludes Al Qaeda from attacking America here tomorrow. Al Qaeda, both in Iraq and globally, thrives on the American occupation.”

Ezra Klein:
  • AQiM is entirely a creation of our invasion. We have triggered the activation of a new branch of al Qaeda, a branch that has amassed extensive experience in adapting terrorist tactics to urban warfare, has proven our vulnerability, and will endure long after we've left. If we weren't fighting them over there, not only would they not be coming here, but they wouldn't exist in the first place.

linkini
Translation: I hate America and its freedoms.

Mmmm, Burger (C.J.) 07-13-2007 02:10 PM

Quote:

Originally posted by Tyrone Slothrop
  • So fund managers get to pay a low tax rate that is supposed to provide incentives to risk-taking investors, even though they aren’t investors and they aren’t taking risks.

I haven't paid attention to this issue at all. Can someone explain to me why this -- particulary, his last sentence -- is wrong?
1) Most private equity fund managers are taking risks. To be sure, primarily with investors' money, but also their own. Indeed, the investors who get the 80% of the gains (that is all gains less the 20% carried interest), are taxed at the k-gains rate.

2) There are reasons for a lower k-gain rate other than providing incentives for risk taking.

sgtclub 07-13-2007 02:18 PM

Quote:

Originally posted by Mmmm, Burger (C.J.)
1) Most private equity fund managers are taking risks. To be sure, primarily with investors' money, but also their own. Indeed, the investors who get the 80% of the gains (that is all gains less the 20% carried interest), are taxed at the k-gains rate.

2) There are reasons for a lower k-gain rate other than providing incentives for risk taking.
Right. And depending on how the deal is structured, there is no guaranty that carried interest will be paid or paid in full.

If they change this, then to be intellectually fair they also should change the tax treatment of ISOs.

Mmmm, Burger (C.J.) 07-13-2007 02:21 PM

Quote:

Originally posted by sgtclub
Right. And depending on how the deal is structured, there is no guaranty that carried interest will be paid or paid in full.

If they change this, then to be intellectually fair they also should change the tax treatment of ISOs.
All that said, a conversion to a consumption tax would eliminate any of these shenanigans. If a VC or PE guy wants to take the money and buy a yacht, he gets taxed at 35%. If he wants to plow it back into more investments, then zero tax.

Cletus Miller 07-13-2007 02:21 PM

Quote:

Originally posted by Mmmm, Burger (C.J.)
1) Most private equity fund managers are taking risks. To be sure, primarily with investors' money, but also their own. Indeed, the investors who get the 80% of the gains (that is all gains less the 20% carried interest), are taxed at the k-gains rate.

2) There are reasons for a lower k-gain rate other than providing incentives for risk taking.
1) That's true, but the manager will get the cap gains rate on any gains on their invested money. The manager is also "risking" that the carried interest will be zero--not that they get nothing, because the manager gets 2% off the top, no matter what else happens. However, isn't "risk" more about the risk of losing your investment, which isn't an issue for carried interest?

2) Such as . . .? I can't think of examples that reasonably apply to carried interests other than the lower rate generates more free cash for campaign contributions.

Greedy,Greedy,Greedy 07-13-2007 02:27 PM

Quote:

Originally posted by Tyrone Slothrop
  • So fund managers get to pay a low tax rate that is supposed to provide incentives to risk-taking investors, even though they aren’t investors and they aren’t taking risks.

I haven't paid attention to this issue at all. Can someone explain to me why this -- particulary, his last sentence -- is wrong?
Several reasons, practical and theoretical:

(1) the risk takers bit is laughable - ask the fund managers who got sued for clawbacks after the nuclear winter hit the tech industry - this is a high-risk, high-reward business, and while the rewards seem to be rolling in at the moment, it wasn't that long ago that we were in the middle of a shake-out that ended a lot of careers;

(2) in reality, capital versus asset has little to do with risk versus non risk - capital is relating to investments, which can run from ultra-conservative bonds to wild-ass plunges into speculative start-ups; in this case, the carried interest is a piece of the underlying investment transaction, and is measured by and relates to the return on an investment;

(3) few fund managers have no investment in their partnership interest, though the investment is quite low compared to the interests held by the limiteds; the best argument for this is that it's really income relating to services provided to the investment vehicle, and there is a service component, but there is also an investment component and in many capital gains transactions some services accompany the investment (e.g., I buy a piece of real estate for investment purposes - over the years, I'm going to spend some time and energy managing it and fixing it up, all of which will enhance its value when sold if done right); and

(4) economically, the venture sector has been a driving force in the economy and capital gains have encouraged it; during the Clinton administration, there was very important tax legislation that was specifically designed to further incentive these guys (letting them roll over investments and giving them a preferred rate of return on investments in early stage companies), and that was part of the reason for Clinton's economic successes.

Some of this seems to be about the greedy New Yorkers at Blackstone getting piggy and effectively looking to sell of the future stream of income from these deals to the public; but this bill undercuts some of the most productive investment sectors around.

Rant over.

sebastian_dangerfield 07-13-2007 02:35 PM

Quote:

Originally posted by Greedy,Greedy,Greedy
Several reasons, practical and theoretical:

(1) the risk takers bit is laughable - ask the fund managers who got sued for clawbacks after the nuclear winter hit the tech industry - this is a high-risk, high-reward business, and while the rewards seem to be rolling in at the moment, it wasn't that long ago that we were in the middle of a shake-out that ended a lot of careers;

(2) in reality, capital versus asset has little to do with risk versus non risk - capital is relating to investments, which can run from ultra-conservative bonds to wild-ass plunges into speculative start-ups; in this case, the carried interest is a piece of the underlying investment transaction, and is measured by and relates to the return on an investment;

(3) few fund managers have no investment in their partnership interest, though the investment is quite low compared to the interests held by the limiteds; the best argument for this is that it's really income relating to services provided to the investment vehicle, and there is a service component, but there is also an investment component and in many capital gains transactions some services accompany the investment (e.g., I buy a piece of real estate for investment purposes - over the years, I'm going to spend some time and energy managing it and fixing it up, all of which will enhance its value when sold if done right); and

(4) economically, the venture sector has been a driving force in the economy and capital gains have encouraged it; during the Clinton administration, there was very important tax legislation that was specifically designed to further incentive these guys (letting them roll over investments and giving them a preferred rate of return on investments in early stage companies), and that was part of the reason for Clinton's economic successes.

Some of this seems to be about the greedy New Yorkers at Blackstone getting piggy and effectively looking to sell of the future stream of income from these deals to the public; but this bill undercuts some of the most productive investment sectors around.

Rant over.
Can you send this to Krugman, because right now, Chuck Rangel is operating without the benefit of any of even this cursory knowledge. And oddly, I don't think he's just playing to the base here. I think this issue is over most of congress' heads and sounds to a layman very unfair and greedy (see the Times' piece of this morning on how Blackstone structured the IPO to create a tax advantage down the road). And, apparantly, Krugman's.

Cletus Miller 07-13-2007 02:41 PM

Quote:

Originally posted by sebastian_dangerfield
And, apparantly, Krugman's.
Nah, he's just advocating a position. He's jealous of the boo-coo dollars his intellectual inferiors are rolling in and wants to see them pay "their fair share".

Mmmm, Burger (C.J.) 07-13-2007 02:44 PM

Quote:

Originally posted by Cletus Miller

2) Such as . . .? I can't think of examples that reasonably apply to carried interests other than the lower rate generates more free cash for campaign contributions.
More free cash for more investment. These guys aren't consuming most of the boo-coo dollars they pull in--they're plowing it back into the market. That's the other major point of low k-gains.

Greedy,Greedy,Greedy 07-13-2007 02:53 PM

Quote:

Originally posted by sebastian_dangerfield
Can you send this to Krugman, because right now, Chuck Rangel is operating without the benefit of any of even this cursory knowledge. And oddly, I don't think he's just playing to the base here. I think this issue is over most of congress' heads and sounds to a layman very unfair and greedy (see the Times' piece of this morning on how Blackstone structured the IPO to create a tax advantage down the road). And, apparantly, Krugman's.
You know, the crazy thing is this may not end up generating any revenue.

Take the basic transaction: A group of people invest $10 million in Company A, hope to realize a 5x return and get $50 million. They're going to split it, with the people who put up $9.9 million will take about 80% of the $40 million gain and the people who managed the fund will take about 20%.

So, pre-bill, there is a $10 million investment and $40 million gain. You tax the $40 million gain at capital gains rates.

Now, you say to the guys managing the investment, wait, we think you're providing services, so we're going to tax your piece (about $8 million) at ordinary rates.

Well, the guys now structure this so they get a fee for $9.6 million. Why $9.6? They gross it up for the difference between about 15% and 35% tax rates. Why do the investors agree? Because they get to deduct the full $9.6 from their ordinary income. So, at the end of the day, there is still $40 million in capital gains, but there is also $9.6 million in ordinary income and a $9.6 million deduction.

There some chance of a gains/income mismatch generating some money, and some chances that the deduction would accrue to exempt orgs that can't use it, but, trust me, there will be ways to make sure the deduction gets used and the gross up occurs so that we end up in pretty close to the same place.

By the way, I think this is just more Pavlov. The R congress enacted a bunch of silly stuff post-Enron because they had to do something; the D congress may just do some of the same. But, if there were a Clinton in the corner office, there would be more thought given to the tax policy issues involved (as there was during his term). And Clinton was very good to the venture boys.


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