Discussion:Tax Reduction and Reform Act of 2007 Goodbye AMT?
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Ksnoopytax (talk|edits) said: | 25 October 2007 |
| This just emailed to me by RIA:
Rangel introduces Tax Reduction and Reform Act of 2007
This morning, House Ways and Means Chair Charlie Rangel (D-NY) introduced the "Tax Reduction and Reform Act of 2007." The bill would:
-- Repeal the AMT for post-2007 tax years, paid for with a tax increase on upper- income taxpayers;
-- Boost AMT exemption amounts for 2007 to the same level they were at for 2006, allow nonrefundable personal credits to offset regular tax and AMT for 2007, plus provide a one-year reprieve for a number of provisions expiring at the end of 2007, paid for with a variety of changes including taxation of carried interest of investment fund managers as ordinary income (to the extent not a reasonable return on investment capital), taxing deferred compensation plans of offshore hedge funds, and basis reporting on securities; and
-- Reduce the top corporate tax rate from 35% to 30.5%, paid for by reducing or eliminating a variety of business tax breaks (e.g., eliminating the Sec. 199 domestic production activities deduction and repealing the LIFO accounting method).
The bill's three titles are said to be self-contained in terms of offsets (it doesn't use revenues raised from the corporate side to pay for the individual reforms and vice-versa).
Rangel is said to be planning to consider the 2007 AMT relief provisions and the extenders as a separate bill, to be introduced as early as next week.
Here is a link to the bill itself. http://waysandmeans.house.gov/media/pdf/110/Summary%20for%20Distribution.pdf | |
Mtmckeecpa (talk|edits) said: | 25 October 2007 |
| He is looking at a sur-tax rate of 4%(?), to cover the AMT repeal, on AGI of high income taxpayers...NOT taxable income. Another reduction in itemized deductions, mort interest, charity, etc... | |
| 25 October 2007 | |
| Ah, but no more questions on reasonable compensation for S Corp shareholders. ♫ | |
Death&Taxes (talk|edits) said: | 25 October 2007 |
| We would all be millionaires if we had a dollar for every proposal that starts life in Congress. Many of my artist clients swear there was a law passed allowing a charitable deduction for FMV of their works. They might have been proposed but never disposed. | |
| 25 October 2007 | |
| He also wants to eliminate LIFO. The AMT repeal w/b for incomes below $200,000.
Some of the changes I'd like to see are: How about an adjustment to the ss income of the elderly? That hasn't been changed since it was put into place. Also student loans should not has an income cap. Our doctors and lawyers etc need big incomes in order to pay the loans which can exceed 100,000. Their incomes are too high to deduct the loan interest. | |
| 25 October 2007 | |
| I would support anything that passes so that tax preparers don't have to have that dreaded discussion with the TP, "you owe AMT, and there's nothing to be done about it." Philosphically, however, I wish they'd let it hit in full force for a year. The reason would be to let the public know that these tax cuts in the present Administration have been pure smoke and mirrors. The AMT income to the Treasury (and the future expected AMT revenue) were in the budget calculations going forward, and they allowed the unchecked spending and wild tax cuts to proceed with some cover of respectibility. It was a bad joke. In addition, will the American public really be told the truth about the potential demise of the AMT? The revenue will be made up somewhere, in spades. It's got to be. | |
Death&Taxes (talk|edits) said: | 25 October 2007 |
| From MSNBC: 'In anticipation of Rangel's plan, Rep. Jeb Hensarling, R-Texas, and other GOP conservatives wrote their colleagues Wednesday urging them to oppose any proposal to raise taxes to pay for the elimination of the AMT. "The correction of tax mistakes should never be offset with tax increases," they wrote.'
Somewhere here there is room for an Onion headline: "Solons propose elimination of Departments of State, Treasury, Labor and Agriculture to bridge missing AMT gap." | |
| 26 October 2007 | |
| That's a sneaky little statement too. As you know, they are not really raising tax, just trying to shift what we would have collected through the AMT elsewhere. You'd don't think they would try to cut a little fat out of DOD, do you? Hah. | |
| October 26, 2007 | |
| Keep reading, it would also codify that all personal services would be subject to SE tax without regard to entity!!!!! | |
| 26 October 2007 | |
| Yeah, I saw that. Reading between the lines of the article I read, it seems to answer one of the questions we've discussed many times. It seems that many "partnerships" (I assume these are LLC's) are taking it to the limit in the in the wake of the withdrawn Reg. 1.1402(a)-2 (service partners in professional service partnerships are never treated as limited partners for SE tax purposes). So these people will get slammed. What I would like to see is whether even with this change, we would exceed the revenue generated by the AMT in full effect, with no indexing. | |
| 26 October 2007 | |
| Overall, I think I'd still like to see the AMT go, as it's a parallel tax system, and it's essentially a flat tax. The upper middle class, and near wealthy client does not like to spend money on tax planning and tax preparation, only to see that it's essentially for naught in the end. | |
Death&Taxes (talk|edits) said: | 26 October 2007 |
| JR is probably thinking more along S Corp lines, where we saw one 'professional' yesterday talk about shareholders making 1M, taking 200K in salaries and the balance as dividends. What would happen is government might go a bit of the way to solving the medicare crisis....2.9% of 800K is not chicken-feed.
Then again, as I noted, if this corp were in PA under current law, its book earnings are capitalized by dividing thru by .095 [or over 8.4M] then divided in half, 4.2M, and then an exemption of 125K is given, meaning the company is taxed at .00489 on 4M, or 20K of tax....this is not bird feed either. There is still a small saving since PA would tax the wages at 3.07%, and the CST is a corporate deduction. Note that this same tax applies to LLCs also. Other states might not have such levies, and to be fair, PA eliminates the tax on most small corporations thru that 125K exemption, but it goes to show skinning cats is an equal opportunity employer. | |
| 26 October 2007 | |
| Yes, any entity form, where you can "play" with the SE tax will get slammed. But the MMLLC's could theorectically take it all with no SE tax under one reading of it, and I think some (a lot?) were doing this ("we're all limited partners" because we are an LLC). So there was a lot of Russian Roulette in this anyway. I mean, you had to feel for the guy in a sole proprietorship with both a greater chance of audit, and his SE burden, who just never S'd himself. I guess the next shoe to drop will be the estate tax, and boy was there a lot of hot air about that (and more to come). I mean, they were saying, look, we collect so little revenue with it, true: but demographically, we stand to collect a huge sum with it over the next 20 years. I think Dennis can rest easy. Hehe. With a 2.4 trillion dollar tab to be expected on our "security". I guess they could raise the cigarette tax by $4.00/pack. We'd have 1 smoker left, but .... | |
| 26 October 2007 | |
| Oh, I forget, there is one other way to solve this problem of our rising national debt: pay it off with cheaper money. In the past, this was known as debasing the currency, then it was known as printing money, now, it's the operations of the Federal Open Market Committee (as in Federal Reserve) (popularly phrased as "will the Fed. lower rates"). Anyone been watching the dollar recently? P.S. By the way, you don't have to trade currencies in the FOREX to protect your wealth, any American can open an account in Euro's etc. at his home town bank with a little planning. Debasement amounts to the stealthiest tax increase of all. | |
Actionbsns (talk|edits) said: | 26 October 2007 |
| I'm not clear on the issue of the S-Corp and SE Tax. Are they saying that the pass through amounts are now going to be subject to SE tax? Can someone put that in clearer English? I also see they have not clarified the issue bandied about a lot last year concerning Health Insurance for S Corp shareholders. | |
| October 26, 2007 | |
| Yes, exactly. All income earned by an S or an LLC would be subject to SE. All. So....no more salary reporting I guess? Who knows as to the other. The bill's got a snowball's chance in Vegas, but still, it opens a window to what might be the current politico thinking. Scary. | |
| 26 October 2007 | |
| Just income from businesses providing a service. What's scary about that? | |
Actionbsns (talk|edits) said: | 26 October 2007 |
| Dennis - what business doesn't provide a service? Unless they are talking about personal service corps, but that's not what it says. Are you suggesting that some types of S corps won't be in this category and if so what types? This will certainly take away a huge advantage to being taxed as an S-Corp if it's passed, unless someone needs the corp to protect personal assets, going back to a SP would be easier for a lot of people. | |
| October 26, 2007 | |
| It takes entity planning out of the game. What's the point? It effectively makes everyone a sole proprietor for tax purposes regardless of income, and is a not well disguised whack to business owners. Why should SE be an unlimited amount? Will there be exemptions for businesses where the owner doesn't actively work? Or any recognition at all of the amount and value of the services provided? It flies in the face of a lot of years of case law. | |
| 26 October 2007 | |
| We shall have to wait and see. From the wording, it certainly won't apply to retail stores or manufacturers. Personally I like the sucker. It's revenue neutral and goes after some of the larger abusers. The four percent surcharge in exchange for no AMT isn't going to be that painful in states with high income taxes. | |
Death&Taxes (talk|edits) said: | 27 October 2007 |
| But the first reason for entity planning is to limit liability, which is why corporations etc were started anyway. I am always leery when the tax tail wags the horse. | |


