Did Romney enable company's abusive tax shelter?

Dick Tuck

Board Troll
Aug 29, 2009
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Did Romney enable company's abusive tax shelter?


Very technical and detailed article that shows how Romney tried to screw the American people.

Mitt Romney's refusal to release tax returns in the critical years of his income accumulation has done little to dispel the legitimate concern that arises from hints buried in his scant disclosure to date: Did he augment his wealth through highly aggressive tax stratagems of questionable validity?

...

In the Marriott case, the IRS raised both arguments and won on the first interpretive issue.

The Court of Claims (affirmed by the Court of Appeals) rejected Marriott's technical analysis, finding no reliable argument or authority to support it. The court therefore did not need to reach the issue of business purpose and economic substance. In subsequent decisions, involving similar transactions but other parties, the courts have sustained the second line of attack as well, finding the claimed losses to be fictitious.

The complete judicial rejection of the Son of Boss tax scheme was entirely predictable. In mid-1994, for example, roughly contemporaneously with Marriott's execution of its Son of Boss trade and well before Marriott filed its return claiming the artificial loss, the highly respected Tax Section of the New York Bar Association filed a public comment with the U.S. Treasury and IRS urging rejection of the technical claims made by promoters of such schemes.

In his key position as head of the board's audit committee, Romney was required under the securities laws and his fiduciary duties to review the transaction. In fact, it has been publicly reported that Romney was the Marriott Board member most acquainted with the transaction and to whom the other board members turned for advice. This makes sense because aggressive tax-driven financial engineering was a large part of what Romney (and Bain) did for a living. For these reasons, it is fair to hold him accountable for Marriott's spurious tax reporting.
 
From Wiki:

Son of BOSS - Wikipedia, the free encyclopedia

The Son of BOSS was a purported tax avoidance strategy of a corporation. It has been largely attributed to J. Willard Marriott and the role played by audit board member Willard Mitt Romney.[1] First appearing in the late 1990s, "Son of Boss" shelters were some of the costliest tax schemes in U.S. history. "Boss" was an acronym for "bond and option sales strategies." The shelters involved creating paper losses to offset real gains.[2]

This is the type of scheme that totally screwed us over in the early 2000s.
 
This stuff is so complex and shaky that I am starting to feel like tax avoidance is nothing more than a sport to these people.
 
This stuff is so complex and shaky that I am starting to feel like tax avoidance is nothing more than a sport to these people.

It certainly is what Bain specialized in. But in laymans terms, what Son of BOSS shelters did, was create paper losses, which had no business or financial impact on a company, and done solely to reduce their tax liability. In other words, it's a sham.
 
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Did Romney enable company's abusive tax shelter?


Very technical and detailed article that shows how Romney tried to screw the American people.

Mitt Romney's refusal to release tax returns in the critical years of his income accumulation has done little to dispel the legitimate concern that arises from hints buried in his scant disclosure to date: Did he augment his wealth through highly aggressive tax stratagems of questionable validity?

...

In the Marriott case, the IRS raised both arguments and won on the first interpretive issue.

The Court of Claims (affirmed by the Court of Appeals) rejected Marriott's technical analysis, finding no reliable argument or authority to support it. The court therefore did not need to reach the issue of business purpose and economic substance. In subsequent decisions, involving similar transactions but other parties, the courts have sustained the second line of attack as well, finding the claimed losses to be fictitious.

The complete judicial rejection of the Son of Boss tax scheme was entirely predictable. In mid-1994, for example, roughly contemporaneously with Marriott's execution of its Son of Boss trade and well before Marriott filed its return claiming the artificial loss, the highly respected Tax Section of the New York Bar Association filed a public comment with the U.S. Treasury and IRS urging rejection of the technical claims made by promoters of such schemes.

In his key position as head of the board's audit committee, Romney was required under the securities laws and his fiduciary duties to review the transaction. In fact, it has been publicly reported that Romney was the Marriott Board member most acquainted with the transaction and to whom the other board members turned for advice. This makes sense because aggressive tax-driven financial engineering was a large part of what Romney (and Bain) did for a living. For these reasons, it is fair to hold him accountable for Marriott's spurious tax reporting.

So please post accounts of Romney being convicted for illegal activity regarding these tax issues. I'll wait.
 
Did Romney enable company's abusive tax shelter?


Very technical and detailed article that shows how Romney tried to screw the American people.

Mitt Romney's refusal to release tax returns in the critical years of his income accumulation has done little to dispel the legitimate concern that arises from hints buried in his scant disclosure to date: Did he augment his wealth through highly aggressive tax stratagems of questionable validity?

...

In the Marriott case, the IRS raised both arguments and won on the first interpretive issue.

The Court of Claims (affirmed by the Court of Appeals) rejected Marriott's technical analysis, finding no reliable argument or authority to support it. The court therefore did not need to reach the issue of business purpose and economic substance. In subsequent decisions, involving similar transactions but other parties, the courts have sustained the second line of attack as well, finding the claimed losses to be fictitious.

The complete judicial rejection of the Son of Boss tax scheme was entirely predictable. In mid-1994, for example, roughly contemporaneously with Marriott's execution of its Son of Boss trade and well before Marriott filed its return claiming the artificial loss, the highly respected Tax Section of the New York Bar Association filed a public comment with the U.S. Treasury and IRS urging rejection of the technical claims made by promoters of such schemes.

In his key position as head of the board's audit committee, Romney was required under the securities laws and his fiduciary duties to review the transaction. In fact, it has been publicly reported that Romney was the Marriott Board member most acquainted with the transaction and to whom the other board members turned for advice. This makes sense because aggressive tax-driven financial engineering was a large part of what Romney (and Bain) did for a living. For these reasons, it is fair to hold him accountable for Marriott's spurious tax reporting.

So please post accounts of Romney being convicted for illegal activity regarding these tax issues. I'll wait.

The point is still that the scheme was used and was punished, and Romney was the director of the audit committee. The result was that Marriott was forced to pay the tax, interest, and penalties and fines. That doesn't happen unless you're trying to do something illegal.
 
If he used tax loopholes it's not his fault. His job was to make companies profitable, and if government loopholes where there to be used, then good for him. He didn't do anything different than any other company executive out there did. And you can bet your ass Obama would have done the same thing had he been in the same position.
 
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Did Romney enable company's abusive tax shelter?


Very technical and detailed article that shows how Romney tried to screw the American people.

Mitt Romney's refusal to release tax returns in the critical years of his income accumulation has done little to dispel the legitimate concern that arises from hints buried in his scant disclosure to date: Did he augment his wealth through highly aggressive tax stratagems of questionable validity?

...

In the Marriott case, the IRS raised both arguments and won on the first interpretive issue.

The Court of Claims (affirmed by the Court of Appeals) rejected Marriott's technical analysis, finding no reliable argument or authority to support it. The court therefore did not need to reach the issue of business purpose and economic substance. In subsequent decisions, involving similar transactions but other parties, the courts have sustained the second line of attack as well, finding the claimed losses to be fictitious.

The complete judicial rejection of the Son of Boss tax scheme was entirely predictable. In mid-1994, for example, roughly contemporaneously with Marriott's execution of its Son of Boss trade and well before Marriott filed its return claiming the artificial loss, the highly respected Tax Section of the New York Bar Association filed a public comment with the U.S. Treasury and IRS urging rejection of the technical claims made by promoters of such schemes.

In his key position as head of the board's audit committee, Romney was required under the securities laws and his fiduciary duties to review the transaction. In fact, it has been publicly reported that Romney was the Marriott Board member most acquainted with the transaction and to whom the other board members turned for advice. This makes sense because aggressive tax-driven financial engineering was a large part of what Romney (and Bain) did for a living. For these reasons, it is fair to hold him accountable for Marriott's spurious tax reporting.

Your link sucks dick......................

See you in 24.........
 

Non sequitur. Obama contributed after tax dollars to his daughters college funds. He took no write-off for those transactions. It's not like he set up a limited partnership to buy them horses, and personally wrote off $77,000 for it. Totally legal, and ethical.

That's quite a difference from using a scam, that incurs paper transactions, which have no material impact on a company financially, and creating a phony loss to avoid taxes.
 
This stuff is so complex and shaky that I am starting to feel like tax avoidance is nothing more than a sport to these people.

My guess is the whole controversy is over the tax returns from 2008/2009. Please correct me if I am wrong but those that pay only 15% under capital gains can write off losses from the previous year. If Romney lost a substantial sum of money during the crash of 2008-2009 his effective rate could be reduced substantially. Cons point to Mcain saying he showed him tax returns for 10 years and Mcain found nothing wrong but Mcain did not see the returns from 2008-2009. I would guess he paid somewhere below 10% and does not want the public to know.
 
This stuff is so complex and shaky that I am starting to feel like tax avoidance is nothing more than a sport to these people.

My guess is the whole controversy is over the tax returns from 2008/2009. Please correct me if I am wrong but those that pay only 15% under capital gains can write off losses from the previous year. If Romney lost a substantial sum of money during the crash of 2008-2009 his effective rate could be reduced substantially. Cons point to Mcain saying he showed him tax returns for 10 years and Mcain found nothing wrong but Mcain did not see the returns from 2008-2009. I would guess he paid somewhere below 10% and does not want the public to know.


You don't get it.

The losses are only real on paper, they have no actual effect on his finances.

Research the "son of boss" tax shelter scheme. basically, if I want a 1,000,000 loss - I pay $1,000,050 to a shell company for a $50 item (it could be anything) - but I pay only $50 in cash and $1,000,000 in a promissory note that I never pay back. Then I sell the item for $50. I can then write down a $1,000,000 loss for my taxes. But the loss isn't real because I never actually pay the shell company $1,000,000.
 
Did Romney enable company's abusive tax shelter?


Very technical and detailed article that shows how Romney tried to screw the American people.

Mitt Romney's refusal to release tax returns in the critical years of his income accumulation has done little to dispel the legitimate concern that arises from hints buried in his scant disclosure to date: Did he augment his wealth through highly aggressive tax stratagems of questionable validity?

...

In the Marriott case, the IRS raised both arguments and won on the first interpretive issue.

The Court of Claims (affirmed by the Court of Appeals) rejected Marriott's technical analysis, finding no reliable argument or authority to support it. The court therefore did not need to reach the issue of business purpose and economic substance. In subsequent decisions, involving similar transactions but other parties, the courts have sustained the second line of attack as well, finding the claimed losses to be fictitious.

The complete judicial rejection of the Son of Boss tax scheme was entirely predictable. In mid-1994, for example, roughly contemporaneously with Marriott's execution of its Son of Boss trade and well before Marriott filed its return claiming the artificial loss, the highly respected Tax Section of the New York Bar Association filed a public comment with the U.S. Treasury and IRS urging rejection of the technical claims made by promoters of such schemes.

In his key position as head of the board's audit committee, Romney was required under the securities laws and his fiduciary duties to review the transaction. In fact, it has been publicly reported that Romney was the Marriott Board member most acquainted with the transaction and to whom the other board members turned for advice. This makes sense because aggressive tax-driven financial engineering was a large part of what Romney (and Bain) did for a living. For these reasons, it is fair to hold him accountable for Marriott's spurious tax reporting.

Your link sucks dick......................

See you in 24.........

Countdown to your next neg rep I see. Enjoy your petty little game. It's easier than thinking about the ethics and values of Romney, and actually giving substantiated refutation.
 

LOL! The money Obama gives to his daughters has already been taxed - that's not a "tax shelter"

So his daughters did not pay income tax on that income.

Final answer?

You don't know your ass from a hole in the ground regarding gift taxes. If they were to apply in this case, which they don't, it would be Obama that were responsible. But they're all withing allowable limits of setting up a fund for kids education, and all done with after tax dollars. It's not like Romney using giving his wife a horse as a write off.
 

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