American Politics

[Spidy]

Oil and gas extraction income is not subject to GILTI, no matter what the level of tangible assets is. QBAI is irrelevant for oil and gas. I don't believe oil and gas E&P is subject to Subpart F either, unless it's a royalty. It shouldn't be anyway. I don't remember why I thought the headlines were ridiculous.

Okay...it seems I need to revisit my understanding of GILTI, but one last question for you.

So is it your assertion, that O&G companies have no intangible assets? Because if they do (which I think they do) have intangible assets (no matter how small or seemingly inconsequential), wouldn't they need GILTI to be calculated?

And that calc use some variation of the following, when I do a search?: GILTI = Net CFC Tested Income (10% x QBAI - Interest Expense)

That's it, I'm done! It seems YOU and GILTI, have done me in....well at least for now!


PS: My apologies to all the other ISGers, for taking up the forum bandwidth these last few days! I'll try to keep things to a minimum for the next little while.

Thx for your patience and understanding!

[Spidy]

If the playing field were leveled among all industries, the total tax burden on oil and gas relative to other businesses would be less than it is now. On the other hand, a lot of green energy projects wouldn't be viable. The combination of tax benefits and outright government subsidies exceeds their profit. Here's a list of some, kindly provided by ChatGPT.

Well that figures! Chat freakin' GPT!

Well...it looks like I've brought, a "Google Search knife" to an "AI ChatGPT gunfight!" Woe is me? (...kkkk!)

Well, despite the very nice long, MarquisdeSade1 (MDS1) style "Cut-n-paste" subsidies list from ChatGPT, allow me to tell ChatGPT, the same thing I'd be telling you, as I did in the last post.

At least my subsides and tax cuts, come without emitting CO2 emissions and greenhouse gases! or plumes of "clean burning methane gas" from outta space!


PS: And while your at it, ask ChatGPT, if natural gas is a "clean burning gas", I'd love to hear the answer.

[EihTooms]

Former President of Poland Lech Walesa wrote the following letter to Trump.

Your Excellency, Mr. President,

We watched the report of your conversation with the President of Ukraine, Volodymyr Zelensky, with fear and distaste. We find it insulting that you expect Ukraine to show respect and gratitude for the material assistance provided by the United States in its fight against russia. Gratitude is owed to the heroic Ukrainian soldiers who shed their blood in defense of the values of the free world. They have been dying on the front lines for more than 11 years in the name of these values and the independence of their homeland, which was attacked by Putin's russia.

We do not understand how the leader of a country that symbolizes the free world cannot recognize this.

Our alarm was also heightened by the atmosphere in the Oval Office during this conversation, which reminded us of the interrogations we endured at the hands of the Security Services and the debates in Communist courts. Prosecutors and judges, acting on behalf of the all-powerful communist political police, would explain to us that they held all the power while we held none. They demanded that we cease our activities, arguing that thousands of innocent people suffered because of us. They stripped us of our freedoms and civil rights because we refused to cooperate with the government or express gratitude for our oppression. We are shocked that President Volodymyr Zelensky was treated in the same manner.

The history of the 20th century shows that whenever the United States sought to distance itself from democratic values and its European allies, it ultimately became a threat to itself. President Woodrow Wilson understood this when he decided in 1917 that the United States must join World War I. President Franklin Delano Roosevelt understood this when, after the attack on Pearl Harbor in December 1941, he resolved that the war to defend America must be fought not only in the Pacific but also in Europe, in alliance with the nations under attack by the Third Reich.

We remember that without President Ronald Reagan and America's financial commitment, the collapse of the Soviet empire would not have been possible. President Reagan recognized that millions of enslaved people suffered in Soviet russia and the countries it had subjugated, including thousands of political prisoners who paid for their defense of democratic values with their freedom. His greatness lay, among other things, in his unwavering decision to call the USSR an "Empire of Evil" and to fight it decisively. We won, and today, the statue of President Ronald Reagan stands in Warsaw, facing the USA Embassy.

Mr. President, material aidmilitary and financialcan never be equated with the blood shed in the name of Ukraine's independence and the freedom of Europe and the entire free world. Human life is priceless; its value cannot be measured in money. Gratitude is due to those who sacrifice their blood and their freedom. This is self-evident to us, the people of Solidarity, former political prisoners of the communist regime under Soviet russia.

We call on the United States to uphold the guarantees made alongside Great Britain in the 1994 Budapest Memorandum, which established a direct obligation to defend Ukraine's territorial integrity in exchange for its relinquishment of nuclear weapons. These guarantees are unconditionalthere is no mention of treating such assistance as an economic transaction.

Signed,

Lech Wał281;sa, former political prisoner, President of Poland.

[Tiny 12]

(...kkkk!)

But if you are going to argue, that natural gas is 10X or 100X cleaner, I would love to see your facts, data and sources w/r to such false and dubious claims..

I said I could argue. The primary contributors to dirty air, and deaths therefrom, are particulate matter, sulfur dioxide, and nitrogen oxides. Particulate matter is the worst by far. See table about 40% of the way through the web page below. Hard coal and brown coal produce about 10,000 X to 30,000 X more particulate matter than gas. About 1000 X more sulfur dioxide. And two to three times more NOx compounds. Those numbers are actually variable though, depending on the chemical composition of the specific coal and gas.

https://en.wikipedia.org/wiki/Fossil_fuel_power_station

Spend some time in China and Hong Kong and you'll see a huge difference in air quality between there and the USA. One of the big reasons for the difference is we burn more natural gas than coal, and they do the reverse.

[Tiny 12]

Okay...Got it! I thought they'd be more O&G companies, judging from recent results, I was reading in the headlines. 2025 MLP Yields Up To 11.3%: https://www.suredividend.com/mlp-list/

Judging from many of the MLP investment funds, I thought the number of MLPs is probably more like, about 5-10% of O&G companies.

The articles (and I) were using FOGEI/FORI (Subpar F carveout of IRC Section 907--is what I meant instead of GILTI) for O&G extraction income.

But that's not the point of those articles, because the the tax loophole that's being uncovered, is really only interested in and uses the QBAI calc of the total tangible assets, in order to determine the GILTI for the intangible assets (which are vast the article's and IMH opinion).

Fair enough, that your in favor having them removed, but why then, were you calling the articles "Ridiculous"? As far as I can make out, their reporting of the O&G tax loophole is accurate.

You also have to ask yourself, and to your point (if it makes sense to remove them), why are O&G companies fighting so hard to hang on to GILTI?

I'm not necessarily buying that agreement and I'm not so sure that's a bad thing. O&G have had a pretty good run, some 100+ years (and this is where we probably disagree mostly), perhaps it's time to move on.

Well according to your last statement O&G wouldn't be viable without the all the "subsidies, tax advantages and loopholes". At least my subsides come without emitting CO2 emissions and greenhouse gases!

At the moment (and perhaps I'll circle-back), I can't speak the green energy case, you cite in Texas, but on the surface, isn't this a case for the use of batteries (BESS)? And does shutting down the windmills really give you that much more profit, over and above, the savings from reduced wear-and-tear? Maybe the difference is negligible and not enough to get worked up about?

Oil and gas extraction income is not subject to GILTI, no matter what the level of tangible assets is. QBAI is irrelevant for oil and gas. I don't believe oil and gas E&P is subject to Subpart F either, unless it's a royalty. It shouldn't be anyway. I don't remember why I thought the headlines were ridiculous. If I recall correctly (this is from attending a presentation by an engineer at ERCOT, which manages the electric grid in Texas, years ago), the wind generators were paying around $. 02 per kilowatt hour to sell into the grid. I'd guess the wholesale price of electricity at the time averaged around $. 05 per kilowatt hour. It's the principle of the thing. The tax laws shouldn't be set up so that people are actually paying money to produce electricity, which was wasted because there was no demand for it, solely so they could collect a tax credit. You apparently misinterpreted what I wrote, or I screwed up in what I said, as oil and gas E&P would be just about as viable without the industry specific tax advantages as it is now. You wouldn't see a significant fall off in domestic production if you axed them all tomorrow. Like I said, if I were in charge, they'd all be axed except expensing of IDC's.

And yes, if you can create cost effective battery storage, renewables look a lot better when the suns not shining and the wind's not blowing. Or, in your example, when the wind is blowing but there's no demand for electricity. The question is when will that happen, especially when Biden, Trump and others are punishing the lowest cost producers (in China) with sky high tariffs.

[Spidy]

As Elvis and I have already told you, oil and gas producers in general aren't MLP's. A number of the pipeline and other midstream companies are. I can think of a few exceptions, like royalty trusts that don't actually produce hydrocarbons, and at least one producer, Vanguard. But my wild guess is that less than 1% of USA oil and gas is produced by MLP's.

Okay...Got it! I thought they'd be more O&G companies, judging from recent results, I was reading in the headlines. 2025 MLP Yields Up To 11.3%: https://www.suredividend.com/mlp-list/

Judging from many of the MLP investment funds, I thought the number of MLPs is probably more like, about 5-10% of O&G companies.

You've gone off on a tangent on GILTI. Income from oil and gas extraction isn't subject to the GILTI tax. My comments earlier about tangible and intangible assets were just to indicate that the GILTI tax, if imposed on foreign income realized by oil and gas companies, wouldn't raise that much revenue. If you're going to have the GILTI tax on foreign income, oil companies should be subject to it. However, at the same time, you should remove the provisions of IRC Section 907, targeted towards oil companies, that limit their ability to take advantage of foreign tax credits. You level the playing field on GILTI and Section 907 and I bet the oil and gas producers would end up paying more tax.

The articles (and I) were using FOGEI/FORI (Subpar F carveout of IRC Section 907--is what I meant instead of GILTI) for O&G extraction income.

But that's not the point of those articles, because the the tax loophole that's being uncovered, is really only interested in and uses the QBAI calc of the total tangible assets, in order to determine the GILTI for the intangible assets (which are vast the article's and IMH opinion).

In fact, if you've been paying attention, I've favored removing all oil and gas "subsidies, tax advantages and loopholes" mentioned by you and in your links, except expensing of Intangible Drilling Costs. And if you want to eliminate Section 179 Depreciation and other accelerated depreciation, for all companies, along with IDC expensing, that would make sense.

Fair enough, that your in favor having them removed, but why then, were you calling the articles "Ridiculous"? As far as I can make out, their reporting of the O&G tax loophole is accurate.

You also have to ask yourself, and to your point (if it makes sense to remove them), why are O&G companies fighting so hard to hang on to GILTI?

The fact is, again, because of severance tax, gasoline taxes, and Section 907, oil and gas is taxed at higher rates than the average for USA. If you removed all the "subsidies, tax advantages and loopholes" available exclusively to oil and gas producers, USA oil and gas output wouldn't fall significantly and revenues to the USA Treasury wouldn't increase significantly.

I'm not necessarily buying that agreement and I'm not so sure that's a bad thing. O&G have had a pretty good run, some 100+ years (and this is where we probably disagree mostly), perhaps it's time to move on.

Contrast with green energy, which in many instances wouldn't be viable without government support. When it's windy in Texas and so there's a surplus of electricity, companies that generate electricity from wind have to pay $.01 or $.02 per kilowatt hour "sell" energy into the grid. And instead of shutting down the windmills to reduce wear and tear, they do it! Why? Because the tax credits are worth $.02+ per kilowatt hour. In the words of Elvis, how fucked up is that?

Well according to your last statement O&G wouldn't be viable either, without the all the "subsidies, tax advantages and loopholes". At least my subsides come without emitting CO2 emissions and greenhouse gases!

At the moment (and perhaps I'll circle-back), I can't speak the green energy case, you cite in Texas, but on the surface, isn't this a case for the use of batteries (BESS)? And does shutting down the windmills really give you that much more profit, over and above, the savings from reduced wear-and-tear? Maybe the difference is negligible and not enough to get worked up about?

[MarquisdeSade1]

Allahu Akbar.

https://www.nytimes.com/2025/03/03/o...-business.html

[Spidy]

Uh, no. Nobody here said that, or believes it.

(...kkkk!) No but your American Fuhrer did, and MAGA (and MAGA adjacent alike) ate that shit-up! MAGA greenwashing at it's best!

Thanks to clean burning natural gas, USA CO2 emissions are down by 20% since 2007. China's are up by 70%. They were up in China by 5% from 2022 to 2023.

But don't try to backpedal, outta your equally idiotic statement of "Thanks to clean clean burning natural gas..." , you said it, you thanked it...now own it!

Yes, if you go to sleep in a room that contains 100% methane and no oxygen, you will die. Otherwise methane is not toxic.

Maybe, not toxic in the traditional sense, but methane is way more potent (80x??), due to its dangerous asphyxiation and explosion risks and an even worse greenhouse gas.

I'm reading that "flaring rates", as you put it, in Wyoming and North Dakota are in single digits. If I step onto a section of land in North Dakota or wherever with one producing well, and that well is flaring gas, then the "flare rate" is 100%. That doesn't change the fact the total for the USA is a measly 0. 5%. Methane is coming down. Yes, regulators should clamp down on that, and they are.

Let me be clear! You can dibble, dabble and haggle in futility, over a few meaningless flare capturing percentage points here and there, all you want....have at it! Your haggling matters not in the larger scheme of things, when S+W+B emit zero 0% CO2 emissions.

But, your main take-away from this debate, should be that the fossil fuel industry, has been polluting for over 100+ years, and could have another 100+ years and still wouldn't get to zero 0% flaring or zero 0% CO2 emissions from using fossil fuels. Meaning, the very definition of insanity, is...

Again, perfect is the enemy of good. The world can spend many trillions and go to net zero carbon in a hurry. But if instead we approach this rationally, and just spend a fraction of the money we would have spent otherwise on things like malaria, micronutrients, vaccinations (sorry Elvis), education and the like, the world will be a much better place.

Disregarding the preceding, global warming actually has saved lives.

https://unherd.com/newsroom/bjorn-lo...ll-save-lives/

Yeah, I often hear that nonsensical statement (IMHO), from those that would love to keep the status quo. Especially when the status quo, benefits them!

Ridiculous. I could argue that natural gas is 10X or 100X cleaner burning than coal, and would be closer to the truth than you are.

You're mistaken perhaps for the same reason you underestimate the level of air pollution in China. Particulate matter is the biggest contributor to mortality from air pollution. Coal produces around 100 X more particulates per kilowatt hour than natural gas. Coal plants also produce 90 X more sulfur dioxide and 5 X more NOx compounds. Yes, coal does produce about 2 X more carbon dioxide. Carbon dioxide however is a colorless, odorless, nontoxic gas that doesn't contribute to dirty air. Admittedly, like methane, if you fall asleep in a room with only CO2 and no oxygen, you will die.

Hey, I won't stop you, beating yourself up and defending natural gas vs. coal, if that's what you wish to do, over and over again, while convincing yourself with the fossil fuel propaganda that natural gas is "clean burning."

Again, I refer you to my 100+ years response above. But just keep in mind, other alternatives for producing electricity, like S+W+B, that don't emit CO2 and greenhouse gases and didn't take 100+ years to get to 0.5% flaring capture.

But if you are going to argue, that natural gas is 10X or 100X cleaner, I would love to see your facts, data and sources w/r to such false and dubious claims.

The USA, Canada, Australia (probably including your beloved South Australia) and Russia all emit more CO2 per capita than other developed countries. That's because they occupy large areas and people are more spread out. Furthermore people in developed countries, like the USA, consume more energy and thus emit more CO2 per capita than people in developing countries.

And is the very reason I said, that way I think China is doing much better with their CO2 emission than you realize, given their population size and its only since 2007, they surpass the U.S. as the worse polluter on the plant. The U.S. had been the worst, decades before.

We have air conditioning, cars, etc, that many in developing countries, like China, don't have. Our economies and GDP's are larger -- we produce more.

And YET, developing countries, like China, somehow manage to develop world class AI, EVs and batteries tech at a fraction of the cost. Hmmm...pretty good for a developing country.

That said, the USA accounts for about 13% of global carbon emissions and about 26% of global GDP. Compare to China, which has 31% of worldwide CO2 emissions and accounts for about 18% of global GDP.

Recall, that I said the U.S./Europe has been burning/emitting CO2 emission for a whole lot longer, well I'm betting that if go back perhaps 75 years ago and add up all the U.S. emissions, that would really say something about all the U.S. GDP crap and waster, over 3/4 of a century.

I know you're sensitive about me "changing" your posts, so I'll point out it was me that highlighted "Great President Joe Biden" above. I agree with you 100% about Direct Air Capture. The Great President Joe Biden and democrats shouldn't have made the tax benefits so lucrative for this expensive, unproven technology that oil and gas and other companies want to pursue it.

Carbon capture and storage, from sources like flu gas, however holds more promise.

No, not sensitive, just angry about you, adding inappropriate words, I NEVER wrote. Taking what I wrote out of context. But by all means highlight and underline the words in my post all you want just don't change them!

As for the IRA being lucrative, well that was probably more the doing of those backstabbing turncoats and DINOs, Joe Manchin and Kyrsten Sinema. Other wise lucrative tax acts and subsides for the rich billionaires and robber barons is something your American Fuhrer's transactional administration is world famous for doing. I'm sure their cup will runneth over, this term.

[Spidy]

I comment about what I know. I don't know jack about $LIBRA.

Fair enough!

I do not believe anyone should be mandated to buy an EV.

Me neither!

As you may recall, I don't really care, if the consumer buys EVs or ICE! But FWIW, global EV sales, are trending up positively!

BTW, where exactly are people being mandated to buy EVs? The only mandates I know of, are those given to the auto vehicle industry, required to meet emissions standards.

[Tiny 12]

If the playing field were leveled among all industries, the total tax burden on oil and gas relative to other businesses would be less than it is now. On the other hand, a lot of green energy projects wouldn't be viable. The combination of tax benefits and outright government subsidies exceeds their profit. Here's a list of some, kindly provided by ChatGPT.

As of March 2025, the United States offers a variety of federal subsidies and tax incentives to support manufacturers of green energy and renewable products, as well as their customers. These incentives aim to promote the adoption of clean energy technologies and reduce greenhouse gas emissions. Below is an overview of the key programs:8203;.

1. Investment Tax Credit (ITC):

Overview: The ITC provides a dollar-for-dollar reduction in federal income taxes for investments in renewable energy properties, most commonly solar developments. ​.

Current Rates: The Inflation Reduction Act extended the ITC at a 30% credit for qualified expenditures through 2032. The credit decreases to 26% for systems installed in 2033 and 22% for those installed in 2034. ​.

2. Production Tax Credit (PTC):

Overview: The PTC offers a per kilowatt-hour (kWh) federal tax credit for electricity generated by qualified renewable energy resources, such as wind and geothermal energy. ​.

Eligibility: Facilities must produce and sell electricity from qualified resources to an unrelated person during the taxable year to qualify. ​.

3. Clean Vehicle Tax Credits:

New Clean Vehicles:

Credit Amount: Up to $7,500 for the purchase of a new, qualified plug-in electric vehicle (EV) or fuel cell electric vehicle (FCV).

Eligibility Criteria: The vehicle must undergo final assembly in North America and meet specific battery component and critical mineral sourcing requirements.

Used Clean Vehicles:

Credit Amount: Lesser of $4,000 or 30% of the sales price for eligible used EVs.

Eligibility Criteria: The vehicle must be at least two years old, have a sale price under $25,000, and be purchased from a licensed dealer.

4. Alternative Fuel Refueling Property Credit:

Overview: This credit covers 30% of the cost, up to $1,000 for residential installations and up to $30,000 for commercial installations, for purchasing and installing qualified alternative fuel vehicle refueling property, including EV charging stations. ​.

Duration: Available for property placed in service before December 31,2032. ​.

5. Residential Clean Energy Credit:

Overview: Homeowners can receive a tax credit equal to 30% of the costs for installing qualified clean energy property, such as solar panels, wind turbines, and geothermal heat pumps. ​.

Duration: Applicable for installations from 2022 through 2032, with a phased reduction thereafter. ​.

6. Energy Efficient Home Improvement Credit:

Overview: Homeowners can claim credits for specific energy-efficient improvements, including insulation, windows, and doors. ​.

Energystar. Gov.

Annual Limit: Up to $3,200 annually through 2032. ​.

7. Biofuel Incentives:

Overview: Producers of biodiesel and renewable diesel are eligible for a $1. 00 per gallon tax credit. An additional $0. 10 per gallon credit is available for small agri-biodiesel producers. ​.

8. Accelerated Depreciation:

Overview: The Modified Accelerated Cost-Recovery System (MACRS) allows businesses to recover investments in certain property through depreciation deductions. Renewable energy technologies, including solar, wind, and geothermal, qualify for accelerated depreciation over a five-year period. ​.

9. State and Local Incentives:

Overview: Many states and local governments offer additional incentives, such as rebates, tax credits, and grants, to promote renewable energy and energy efficiency. These incentives vary by location and can significantly enhance the benefits provided by federal programs. ​.

Recent Developments: The political landscape can influence the availability and structure of these incentives. For instance, discussions around the future of the Inflation Reduction Act and associated subsidies have created some uncertainty within the clean energy sector. Companies like Engie have expressed concerns that tariff and tax uncertainties could threaten investments in the USA Additionally, the potential rollback of EV subsidies under the current administration has raised questions about the future of such incentives. ​.

And here are some more, provided by Biden's Inflation Reduction Act, which according to Goldman Sachs will cost the Treasury over $1 trillion:

Residential Clean Energy Credit.

Extends the 30% tax credit for installing solar panels, battery storage, and small wind or geothermal systems (available through 2032, then phases out).

High-Efficiency Electric Home Rebate Program.

Provides up to $14,000 in rebates for low- and moderate-income households to switch to efficient electric appliances (e. G. , heat pumps, stoves, insulation).

Home Energy Audits.

Covers 30% of the cost (up to $150) for professional home energy audits.

Clean Electricity Production and Investment Tax Credits.

Extends Production Tax Credit (PTC) and Investment Tax Credit (ITC) for renewable energy projects (solar, wind, geothermal, hydropower, etc.).

Base credit: 30% of project costs, with potential bonuses for projects in low-income or energy communities.

Advanced Manufacturing Production Credit.

Incentives for USA Production of solar panels, wind turbines, batteries, and critical minerals.

Carbon Capture, Utilization, and Storage (CCUS) Tax Credit.

Increased to $85 per ton for carbon capture used in industrial and power facilities.

$180 per ton for direct air capture.

Clean Hydrogen Production Tax Credit.

Up to $3 per kg for clean hydrogen production, depending on emission levels.

Energy-Efficient Commercial Buildings Deduction (179 D).

Up to $5 per square foot for businesses improving energy efficiency in buildings.

Commercial Clean Vehicle Credit.

Up to $40,000 per vehicle for businesses purchasing electric or fuel-cell commercial vehicles.

Rural Energy for America Program (REAP).

Grants and loans for rural businesses and farmers to install renewable energy systems.

[Tiny 12]

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.

MLPs Tax Advantages:

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.

O&G companies, are making billions, you'd think their time at the gov't trough should have ended long ago.



The GILTI Tax O&G Loophole:

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: https://www.npr.org/2021/12/14/10640...-first-thought), 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 ...intangible assets.

To calculate the foreign taxes on oil and gas (O&G) tangible assets, 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...where the tax loophole comes into play, 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 intangible assets.

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 vast, expanding and growing portfolio of intangible assets, 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!

• QBAI Calculation and Its Impact on Tax Planning Strategies:"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.
  
  Businesses can manage effective tax rates by increasing investment in tangible assets, 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." https://accountinginsights.org/qbai-...ng-strategies/

• Intangibles and performance in oil and gas industry --"Findings: Results show that intangibles had a significant impact on firm performance in multiple financial measures. Firms intangibles also influence their market capitalization, indicating that the financial markets discount such information in their pricing." --Brief Synopsis by Emerald Insight. (Bedtime Reading) https://www.researchgate.net/publica...d_gas_industry OR https://www.emerald.com/insight/cont...1139/full/html

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 intangible assets for O&G companies, using the GILTI tax loophole, is a windfall!

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!

As Elvis and I have already told you, oil and gas producers in general aren't MLP's. A number of the pipeline and other midstream companies are. I can think of a few exceptions, like royalty trusts that don't actually produce hydrocarbons, and at least one producer, Vanguard. But my wild guess is that less than 1% of USA oil and gas is produced by MLP's. If you were dictator and decided there would be no new MLP's, I wouldn't have a problem with that. As long as you treated all companies equally. Meaning no new green energy MLP's like Brookfield Renewable Partners either. I'm all for leveling the playing field.

You've gone off on a tangent on GILTI. Income from oil and gas extraction isn't subject to the GILTI tax. My comments earlier about tangible and intangible assets were just to indicate that the GILTI tax, if imposed on foreign income realized by oil and gas companies, wouldn't raise that much revenue. If you're going to have the GILTI tax on foreign income, oil companies should be subject to it. However, at the same time, you should remove the provisions of IRC Section 907, targeted towards oil companies, that limit their ability to take advantage of foreign tax credits. You level the playing field on GILTI and Section 907 and I bet the oil and gas producers would end up paying more tax.

In fact, if you've been paying attention, I've favored removing all oil and gas "subsidies, tax advantages and loopholes" mentioned by you and in your links, except expensing of Intangible Drilling Costs. And if you want to eliminate Section 179 Depreciation and other accelerated depreciation, for all companies, along with IDC expensing, that would make sense.

The fact is, again, because of severance tax, gasoline taxes, and Section 907, oil and gas is taxed at higher rates than the average for USA. If you removed all the "subsidies, tax advantages and loopholes" available exclusively to oil and gas producers, USA oil and gas output wouldn't fall significantly and revenues to the USA Treasury wouldn't increase significantly.

Contrast with green energy, which in many instances wouldn't be viable without government support. When it's windy in Texas and so there's a surplus of electricity, companies that generate electricity from wind have to pay $.01 or $.02 per kilowatt hour "sell" energy into the grid. And instead of shutting down the windmills to reduce wear and tear, they do it! Why? Because the tax credits are worth $.02+ per kilowatt hour. In the words of Elvis, how fucked up is that?

[SubCmdr]

I expect for the government of the United States of America to work as designed in the constitution. I did not expect for the Legislative Branch of Government to lay down and just take it like a *****. Straight fucking no kissin!! Without giving anyone a civics lesson it's up to the courts now. But will will still have to see if the Administration will obey the courts.

I expected for him to keep his promises. The legislation that crypto industry needs will originate in congress. The current administration has other priorities.

There is a new SEC chair. There will be NO CBDC. But now POTUS needs to ask congress to draft specific regulation to cover the crypto industry. Governing by executive order does not cut it. Next president could be a Democrat. Hostile too crypto as it seems the Democratic party was last election.

I don't like what POTUS is doing to the government workers. But, I don't live in the United States of America and I have no plans too. But as long as I hold a passport that they issue, crypto issues affect me way more than all the other stuff that is happening with the current administration.

I do not like that a child of apartheid has been given permission to run roughshod over the traditional processes that have occurred in the government.

apartheid

policy*that governed relations between*South Africas white minority and nonwhite majority for much of the latter half of the 20th century, sanctioning*racial segregation*and political and economic*discrimination*against nonwhites.

The above policy does not work for me. So I am making plans for a new homeland.

Well what did you really expect man? The guy is a serial liar and full of bluster! He's going to end the Ukraine war in just a matter of hours. He's going to bring the price of groceries down. And yadda, yadda, yadda! People hang on to his bullshit words with hope, but anybody with any sense knows that cocksucker isn't going to do shit but fuck everything up! Just like he did last time! He didn't create a strong economy. After Bush and the Republicans fucked it up, Obama and the Democrats fixed it and handed it to his ass. Then what did Trump and the Republicans do? Of course, they fucked it up again, and Biden and the Democrats had to deal with all the turds left on the ground (no good deed goes unpunished)! Fasten your seat belt and hold on! It's only March 2025, and we have a long way to go until this piece of shit is out of office! FAFO (Fuck Around and Find Out)!

[EihTooms]

You just don't get it, do you?

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 for no reason at all! Man, you're not brainless MAGA cultist, how can you possibly NOT see this?

Absolutely. A single reading of your previous post made it clear as day what you meant.

President Chainsaw Musk isn't taking "an axe" to ANY meaningful budget cuts. When has Trump or anyone standing close enough to Trump to smell him ever SAVED anyone else money? Lolol. He SCAMS people out of more and ever more money. He already drove up the deficit more than any president ever the first time around after being handed a near perfect set of economic trajectories, far better than any outgoing Repub ever handed an incoming Dem in history.

What Musk and Trump are doing will COST Americans more money and ADD to the deficit.

And along the way he will, not might, he will hand over all available USA military intel and control of it to whichever enemy or enemies make the highest bid for it. And it will go directly into his and his oligarch friends' pockets, not the USA Treasury.

[Spidy]

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%?

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.

MLPs Tax Advantages:

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.

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.

O&G companies, are making billions, you'd think their time at the gov't trough should have ended long ago.

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.

The GILTI Tax O&G Loophole:

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: https://www.npr.org/2021/12/14/10640...-first-thought), 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 ...intangible assets.

To calculate the foreign taxes on oil and gas (O&G) tangible assets, 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...where the tax loophole comes into play, 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 intangible assets.

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 vast, expanding and growing portfolio of intangible assets, 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!

• QBAI Calculation and Its Impact on Tax Planning Strategies:"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.
  
  Businesses can manage effective tax rates by increasing investment in tangible assets, 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." https://accountinginsights.org/qbai-...ng-strategies/

• Intangibles and performance in oil and gas industry --"Findings: Results show that intangibles had a significant impact on firm performance in multiple financial measures. Firms intangibles also influence their market capitalization, indicating that the financial markets discount such information in their pricing." --Brief Synopsis by Emerald Insight. (Bedtime Reading) https://www.researchgate.net/publica...d_gas_industry OR https://www.emerald.com/insight/cont...1139/full/html

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 intangible assets for O&G companies, using the GILTI tax loophole, is a windfall!

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!

[SubCmdr]

ADA

Huge move after POTUS announced that it will be included in a strategic crypto reserve.

https://www.cnbc.com/2025/03/02/trum...-and-more.html

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 cashed out as soon as the value spiked from nothing to $5. Now president is accused of "rug pulling" 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?

Argentina's $4.6 Billion Crypto Scandal; Largest-Ever Crypto Theft
https://www.forbes.com/sites/digital...-crypto-theft/

What say you, crypto experts?

PS: And to all you wingers, where's the love now, 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? (...kkkk!)

I comment about what I know. I don't know jack about $LIBRA. Why? 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. GET THE FUCK UP OUTTA HERE!!