Is always been Facts & Data vs. MAGA Gish Gallop...
[QUOTE=Elvis2008;2986426]Thing about Spidy is I grew tired of his constant name calling and saying nothing in his posts. When it has come to the energy discussion, he still brings his usual partisan hip checks but at least this time he is bringing facts and knowledge to his credit. Maybe it is not fair, but I am suspicious as to why. LOL.[/QUOTE][I][b](...kkkk!)[/b][/I] Coming from the king of the [B]D-BAG[/B] and [B]Double D-BAG[/B] word usage. With a horrendous ISG reputation for instigating name calling and having more deleted posts by Admin, then you can shake a stick at, I think you need to check yourself in the mirror.
Dude, I bring the [I]"facts and knowledge"[/I] to my credit, ALL THE TIME! Which I can't honestly say about YOU and the constant [I][b]gish gallop[/b][/I] you bring to the debate table.
I seem to remember, it wasn't too long ago, our esteemed colleague, Eihtooms, was excoriating you, for your woeful lack of sources, facts, links and evidence to back up all your MAGA gish gallop [I][b](...kkkk!)[/b][/I].
Although, as of late, I will say, that the recent debates (with me at any rate), you have tried to provided more factual information. Kudos!
When it comes to being the Crypto President Trump is all talk!
So far has produced nothing of substance for the CRYPTO industry. Next election Democrats need to fight to the crypto vote!
You just don't get it, do you?
[QUOTE=Tiny12;2986898]I wish you were right, that DOGE will take an axe to the defense budget. We spend more on defense than the next 9 highest-spending countries combined. But you're not right.
The USA is now spending 850 billion annually on defense. In the budget resolution just approved by the Senate, this will go up even more, to $1 trillion! Any cost savings for the military from DOGE will be insignificant.
We spend 8 X more on defense than Russia. We're armed to the teeth. I don't understand why you're so worried about the threat from Moscow.[/QUOTE]Of course, they won't save their money to taxpayers, that's not why they're there. Instead, they're removing career personal from Pentagon and security agencies including top military and intelligence leaders [B]for no reason at all[/B]! Man, you're not brainless MAGA cultist, how can you possibly NOT see this?
Because THAT is their job.
[QUOTE=ShooBree;2986663]Let us be honest, trump is not looking for peace, he wants Ukraine to surrender unconditionally while he is praising putin and begging a war torned Ukraine for money. What the fuck is going on? Your president is begging for money like a crackhead.
I remember a time when usa was a Great country, nowadays USA have to do any and everything to appease russia and harass small third world countries for money. There's absolutely zero dignity in the White House today. It is tragic to see how Marco Rubio betrays what ha used to believe in, the same goes for Ted Cruz and Lindsey Graham in the senate.
The White House is like a clown car, but instead of clowns it's full of pro-Putin, right-wing weirdos.
I understand that the current administration isn't interested in contributing a single dollar to support the defense of democracy; but why do they have give in to every command coming from Kremlin? Trump and jd Vance are actively working to strengthen putin.[/QUOTE]The answer is on the surface even if it sounds as a conspiracy theory. Unfortunately, all other logical explanations fail.
Speaking of deadbeat crypto presidents...
[QUOTE=SubCmdr;2986570]Bro, I don't agree with your opinions that much. But I had a visceral negative reaction to the Oval Office Performance by POTUS.
He is in my opinion a: [B]punk ass ***** sitting up in the White House with his thumb on the nuclear button acting more like a gangster than a US President[/B]. He appears to be on his knees in front of Putin. It is a crying shame. I am embarrassed for me and [I]my fellow Americans[/I].
[B]We need Obama, Clinton, Bush Sr. hell even Regan back![/B]
We are on the path to dictatorship if the courts and congress do not put a check on dis mother fucker![/QUOTE]
Well said...but none of this, comes as a surprise to me!
Project 2025, as was foretold by us Dems, over and over again, to the American people (and to ISGers), is alive and well!
Next stop...for the American Fuhrer and MAGA, ..."The Hunger Games"??
[QUOTE=SubCmdr;2986782]So far has produced nothing of substance for the CRYPTO industry. Next election Democrats need to fight to the crypto vote![/QUOTE]
• Speaking of deadbeat presidents and crypto, I was very surprised nobody had reported on the other one in Argentina, who's embroiled in the $LIBRA scandal. I mean that story came out like about two weeks ago...and crickets here at ISG?
Since I know very little about the subject of crypto, I was leaving it up to experts like yourself to report on the story and weigh in, on what it all, could possibly mean?
My limited understanding like 2-weeks ago: Like 5 people held 75% of the value and [b]cashed out[/b] as soon as the value spiked from nothing to $5. Now president is accused of [b]"rug pulling"[/b] and corruption.
Yet another right-wing president who hasn't quite figured out how "greed" works and how NOT to incentivize "greedy" ponzi schemes in right-wing political regime?
[b]Argentina's $4.6 Billion Crypto Scandal; Largest-Ever Crypto Theft[/b]
[url]https://www.forbes.com/sites/digital-assets/2025/02/24/argentinas-46-billion-crypto-scandal-largest-ever-crypto-theft/[/url]
What say you, crypto experts?
[b]PS:[/b] And to all you wingers, [u]where's the love now[/u], for Argentine President Javier Milei? Not to worry though, doesn't President Musk, have enough crypto, to bailout his Argentinian bro-president like, 4x over? [i][b](...kkkk!)[/b][/i]
If you put money into a toilet, what exactly do you think will happen when you flush?
[U][b]ADA[/b][/U]
Huge move after POTUS announced that it will be included in a [B]strategic crypto reserve[/B].
[URL]https://www.cnbc.com/2025/03/02/trump-announces-strategic-crypto-reserve-including-bitcoin-solana-xrp-and-more.html[/URL]
[QUOTE=Spidy;2986926] Speaking of deadbeat presidents and crypto, I was very surprised nobody had reported on the other one in Argentina, who's embroiled in the $LIBRA scandal. I mean that story came out like about two weeks ago...and crickets here at ISG?
Since I know very little about the subject of crypto, I was leaving it up to experts like yourself to report on the story and weigh in, on what it all, could possibly mean?
My limited understanding like 2-weeks ago: Like 5 people held 75% of the value and [b]cashed out[/b] as soon as the value spiked from nothing to $5. Now president is accused of [b]"rug pulling"[/b] and corruption.
Yet another right-wing president who hasn't quite figured out how "greed" works and how NOT to incentivize "greedy" ponzi schemes in right-wing political regime?
[b]Argentina's $4.6 Billion Crypto Scandal; Largest-Ever Crypto Theft[/b]
[url]https://www.forbes.com/sites/digital-assets/2025/02/24/argentinas-46-billion-crypto-scandal-largest-ever-crypto-theft/[/url]
What say you, crypto experts?
[b]PS:[/b] And to all you wingers, [u]where's the love now[/u], for Argentine President Javier Milei? Not to worry though, doesn't President Musk, have enough crypto, to bailout his Argentinian bro-president like, 4x over? [i][b](...kkkk!)[/b][/i][/QUOTE]I comment about what I know. I don't know jack about $LIBRA. [B]Why[/B]? Because I don't participate in the meme coin casino. ADA has been around since 2017 when it was released to the public. I don't see anyone complaining about Casino profits in Las Vegas. They are produced because the people in the casinos lose money.
I do not believe anyone should be mandated to buy an EV. I was won over by a ride in a EV. I was never impressed by Tesla due to its prices. It was liberal luxury they could feel good about. I own a Private Jet but I drive a Tesla. [B]GET THE FUCK UP OUTTA HERE![/B]!
MLPs and GILTI tax loopholes (aka. Subisides) for Oil and Gas...demystified!
[QUOTE=Tiny 12;2986330]Those headlines are bull shit. Reagan's changes in the tax law mostly removed the motivation for oil and gas producers to set up Master Limited Partnerships. They're common for pipelines and other midstream companies though, and for companies that own real estate like apartment and office buildings. Do they really provide substantial tax benefits now that the federal corporate tax rate was cut from 35% to 21%? [/QUOTE] When it comes to MLP's tax structure and tax advantages, its all too apparent that it was mostly created specially, for energy oil and gas (O&G) companies.
[u]MLPs Tax Advantages:[/u]
Only a small fraction of companies (ie. niche industries like, minerals, forestry and timber) use MLP for real estate, as REITs are simpler, more efficient, and a more popular tax structures for mainstream real estate.
If you take a look at MLP investment sector with MLP indexes, ETFs and mutual/hedge funds (like Alerian MLP Index and others), will have 90-95% weighted O&G energy stocks, in their portfolios. Meaning MLPs are most definitely primarily created as tax shelters, with preferential tax treatment, to benefit O&G energy companies.
[QUOTE=Tiny 12;2986330]In the long term, not a lot. In the short term, if they keep expanding, MLP investors benefit from the depreciation write offs. IMO, in order to treat all industries fairly and equally, it would be a good idea to either (a) open up the MLP structure to other industries or (b) eliminate the MLP structure for companies that start up in the future. [/QUOTE] O&G companies, are making billions, you'd think their time at the gov't trough should have ended long ago.
[QUOTE=Tiny 12;2986330]I've already covered intangible drilling costs and percentage depletion, the main bogeymen in the Reuters article. While yes, IDC results in less revenue to the Treasury in the short term, in the long term the company pays the same amount of tax. There's no difference between it and the way R&D or Section 179 depreciation are handled for other industries. And again, the percentage depletion allowance, which is only available to small oil and gas producers, should be done away with.
As to the tax advantages / disadvantages for foreign oil and gas income described in your NPR article, that cuts both way. Yes, oil and gas are exempt from the GILTI tax imposed in the Republican's 2017 Tax Cuts and Jobs Act. However, under IRC section 907, oil and gas companies cannot utilize tax credits for foreign taxes paid to the extent that other companies have. The GILTI tax was designed to force tech and pharmaceutical companies from parking patents and the like in tax haven countries. The amount raised by GILTI from a capital intensive business like oil and gas wouldn't be that significant anyway.
The headlines lie. Again, take into account severance taxes and the gasoline tax, and oil and gas companies pay more than their fair share.[/QUOTE]
[u]The GILTI Tax O&G Loophole:[/u]
Allow me to explain, why I think your assessment of GILTI, and that it applies more to tech and software companies, and not so much to oil and gas (O&G), is not entirely correct.
Although, Ken Moy (lobbyist/lawyer for American Petroleum Institute from my NPR article: [url]https://www.npr.org/2021/12/14/1064011237/fossil-fuel-subsidies-are-proving-harder-to-
end-than-first-thought[/url]), is correct, that O&G companies have to go where the reserves are found, and can't necessarily choose to solely operate, just in low-income tax jurisdiction/countries, like tech and software companies can, he left out one key important fact ...[b]intangible assets.[/b]
To calculate the foreign taxes on oil and gas (O&G) [b]tangible assets,[/b] under GILTI, the tax guidelines says to use FOGEI/FORI, in the Subpar F carveout of GILTI, found in IRC section 907. All other non-energy O&G companies use the standard GILTI calculation, unless specified.
The O&G foreign tax calcs, using FOGEI/FORI must use the standard U.S. corporate tax rate (currently 21%), so no real tax benefits there on O&G tangible assets.
However...[i][b]where the tax loophole comes into play,[/b][/i] is from having a large base of oversees tangible assets (or QBAI: ie. rigs, platforms, well, refineries, storage facilities, buildings, offices...etc), that allows O&G companies to reduce their foreign income tax/GILTI tax, on their holdings of [b]intangible assets.[/b]
The strategy of allocating or increasing their oversees tangible asset base, to reduce the GILTI tax, on their intangible assets, is widely practiced and seen as very beneficial, many O&G companies, w/r to paying lower taxes.
After doing some digging on the GILTI tax, it appears that the O&G companies (to my surprise, anyways), have more in common with the tech and software industries, than you'd think.
Yes indeed, they do have a [b]vast, expanding and growing portfolio of intangible assets,[/b] commonly know as patents, licensing, copyrights, technical know-how, proprietary technologies...etc, that are strangely enough, as we all know, are often more commonly associated with, the tech and software industry. Ergo the why O&G companies want to keep the GILTI loophole!
[LIST][b]QBAI Calculation and Its Impact on Tax Planning Strategies:[/b][i]"QBAI plays a critical role in the Global Intangible Low-Taxed Income (GILTI) calculation by influencing the deemed tangible income return. This return, equal to 10% of the QBAI of each controlled foreign corporation, reduces the amount of GILTI subject to U.S. tax.
[u]Businesses can manage effective tax rates by increasing investment in tangible assets,[/u] raising the deemed tangible income return, and potentially decreasing GILTI inclusion. This strategy is particularly relevant for industries with substantial capital expenditures, like manufacturing and technology."[/i] [url]https://accountinginsights.org/qbai-calculation-and-its-impact-on-tax-planning-strategies/[/url][/LIST][LIST][b]Intangibles and performance in oil and gas industry --[/b][i]"Findings: Results show that [u]intangibles had a significant impact on firm performance in multiple financial measures.[/u] Firms intangibles also influence their market capitalization, indicating that the financial markets discount such information in their pricing." --Brief Synopsis by Emerald Insight. [/i] (Bedtime Reading) [URL]https://www.researchgate.net/publication/327768585_Intangibles_and_performance_in_oil_and_gas_industry[/URL] OR [url]https://www.emerald.com/insight/content/doi/10.1108/md-11-2017-1139/full/html[/url][/LIST]Finally, while the O&G lobbyist/lawyers and other O&G apologists, would have you believe that the GILTI tax, is more for the tech and software industry, when the truth is, the [i][b]intangible assets[/b][/i] for O&G companies, using the [b]GILTI tax loophole, is a windfall![/b]
The headlines in those articles, told the TRUTH and were indeed correct, calling for the oil and gas subsides, tax advantages and loopholes to end!
