{"id":8383,"date":"2016-12-28T09:00:56","date_gmt":"2016-12-28T14:00:56","guid":{"rendered":"http:\/\/www.escapeartist.com\/?p=8383"},"modified":"2020-09-03T17:22:23","modified_gmt":"2020-09-03T21:22:23","slug":"thoughts-upcoming-2017-u-s-tax-policy-changes-part-2","status":"publish","type":"post","link":"https:\/\/www.escapeartist.com\/blog\/thoughts-upcoming-2017-u-s-tax-policy-changes-part-2\/","title":{"rendered":"Thoughts on the Upcoming 2017 U.S. Tax Policy Changes: Part 2"},"content":{"rendered":"
Link to previous article in this series:\u00a0Part 1<\/a><\/em><\/p>\n As many of you may know, the U.S. House, on April 16, 2015, passed the Death Tax Repeal Act of 2015. (Source: House Congressional Website) This bill would repeal the U.S. estate and generation-skipping transfer taxes, and would also revise U.S. gift tax rates to lower the top rate to 35%, with a lifetime exemption for gifts set at $5 million and a cost-of-living adjustment. \u00a0The bill failed to pass the Senate. \u00a0There is every reason to expect that a similar bill will be reintroduced in 2017 as part of a comprehensive tax reform package. \u00a0This is probable since House Speaker Paul Ryan (who set up the Republican Task Force On Tax Reform, which released a “blueprint” on tax reform on June 24, 2016, which also called for the elimination of the estate and generation-skipping transfer taxes) will undoubtedly push the “blueprint” recommendations into law.<\/p>\n The proffered Trump tax plan he campaigned on will repeal the death tax, gift tax, and generation-skipping transfer tax systems, but capital gains held until death (and valued over $10 million for couples) will be subject to tax with exemptions for small businesses and family farms. (Source: Trump Campaign Website)<\/p>\n <\/p>\n The theoretical core of the U.S. corporate tax system (and the individual tax and transfer tax systems as well, for that matter) is a worldwide basis. \u00a0As I have told many clients over many years, if you are a U.S. citizen or income tax resident, you can have a soda pop stand on Mars selling lemonade to aliens from the Andromeda Galaxy, and the IRS will want a piece of your action. \u00a0This stems from the jurisdictional mechanics of the income tax as enacted in the Civil War and was really brought about because Lincoln feared that Americans currently living abroad would not pay their fair share of the income tax into the war effort and that U.S. citizens and residents in the U.S. would purposefully move abroad to negate their obligation to pay U.S. income and other taxes helping the war effort. \u00a0<\/span><\/p>\n But the genesis for this global view of tax liability is far deeper in history \u00a0Dictator Julius Caesar instituted a republic-wide sales tax on all commercial transactions wherever occurring. \u00a0Imperator Caesar Augustus, who actually instituted an estate tax, instituted it on all Roman citizens’ estates wherever their property lay (inside or outside Italy), and wherever they lived (inside or outside Italy). \u00a0These taxes violated traditional rules which had typically differentiated between the peninsula of Italy (i.e., that which was viewed as uniquely “Rome” and uniquely “Roman”) and the rest of the territories outside of the Italian peninsula (i.e., that which was viewed as the “republic” or “empire,” and “non-Roman”) in which differing rules of assessment and collection and liability existed. \u00a0Thus, the Romans were essentially the first and only government to assess taxes on its citizens on a true “global” basis, irrespective of source. \u00a0No other significant government, besides the U.S.A., has ever done this. \u00a0\u00a0The real story of Rome is, therefore, the extension of “Romanism” to persons all over the empire, not just to those inside Italy. \u00a0With Romanism came citizenship and taxes on an extent yet then unseen or thereafter, with the exception of the U.S.A. Roman tax collectors would easily and quickly do well at the modern IRS.<\/span><\/p>\n <\/p>\nDeath Tax Repeal<\/h3>\n
III. Upcoming 2017 Changes in the U.S. Worldwide Corporate Tax System: Great Caesar’s Ghost, The 2000-Year-Old Roman Empire System to be Revised.<\/h3>\n