[quote]ZJStrope wrote:
In addition to what Beans listed above, how about discussing the controversial Non-Profit status of entities like the NFL or NCAA? I know that’s a hot topic.[/quote]
lol. Great idea for a paper.
I could go on and on about it… lol
[quote]usmccds423 wrote:
[quote]ZJStrope wrote:
In addition to what Beans listed above, how about discussing the controversial Non-Profit status of entities like the NFL or NCAA? I know that’s a hot topic.[/quote]
Ya this is a good one too. It was one of the ideas my professor suggested; although, different orgs. under a different sub chapter I believe (I’d have to look at the regs). [/quote]
Be sure to come to the “the IRS should be able to collect money from them” conclusion, irrelevant of the facts and circumstances.
[quote]countingbeans wrote:
[quote]usmccds423 wrote:
[quote]ZJStrope wrote:
In addition to what Beans listed above, how about discussing the controversial Non-Profit status of entities like the NFL or NCAA? I know that’s a hot topic.[/quote]
Ya this is a good one too. It was one of the ideas my professor suggested; although, different orgs. under a different sub chapter I believe (I’d have to look at the regs). [/quote]
Be sure to come to the “the IRS should be able to collect money from them” conclusion, irrelevant of the facts and circumstances. [/quote]
It’s so obvious, I’m still very confused as to why it’s not happening.
[quote]ZJStrope wrote:
[quote]countingbeans wrote:
[quote]usmccds423 wrote:
[quote]ZJStrope wrote:
In addition to what Beans listed above, how about discussing the controversial Non-Profit status of entities like the NFL or NCAA? I know that’s a hot topic.[/quote]
Ya this is a good one too. It was one of the ideas my professor suggested; although, different orgs. under a different sub chapter I believe (I’d have to look at the regs). [/quote]
Be sure to come to the “the IRS should be able to collect money from them” conclusion, irrelevant of the facts and circumstances. [/quote]
It’s so obvious, I’m still very confused as to why it’s not happening.
[/quote]
Well, to be honest, I’m of the opinion it is irrelevant if the NFL itself is TE or not, the money is taxed before it comes in and when it goes out. Taxing the actual NFL is just government greed and an insignificant drop in the bucket.
The NFL 990 should be a matter of public record, and I would have to see the return to fully comment, but end of the day, the IRS won’t get shit, and it is simply class warfare propaganda to rile up the masses and distract from larger more important issues.
Shit is newspeak.
I dunno, it just doesn’t feel like it belongs under 501(c)(6) Business Leagues.
Business Leagues
"Section 501(c)(6) of the Internal Revenue Code provides for the exemption of business leagues, chambers of commerce, real estate boards, boards of trade and professional football leagues, which are not organized for profit and no part of the net earnings of which inures to the benefit of any private shareholder or individual.
A business league is an association of persons having some common business interest, the purpose of which is to promote such common interest and not to engage in a regular business of a kind ordinarily carried on for profit. Trade associations and professional associations are business leagues. To be exempt, a business league’s activities must be devoted to improving business conditions of one or more lines of business as distinguished from performing particular services for individual persons. No part of a business league’s net earnings may inure to the benefit of any private shareholder or individual and it may not be organized for profit to engage in an activity ordinarily carried on for profit (even if the business is operated on a cooperative basis or produces only enough income to be self-sustaining). The term line of business generally refers either to an entire industry or to all components of an industry within a geographic area. It does not include a group composed of businesses that market a particular brand within an industry.
Chambers of commerce and boards of trade are organizations of the same general type as business leagues. They direct their efforts at promoting the common economic interests of all commercial enterprises in a trade or community, however."
See bold items above. The problem I have is that they are the ONLY brand in the industry. A monopoly. It constantly promotes one thing only.
[quote]ZJStrope wrote:
It constantly promotes one thing only.
[/quote]
Well, that seals the deal then.
It doesn’t engage in promoting the NFL, the business of professional football for the sake of its own profit, the actual NFL, the people who work there and there alone, promote the business of football for the “profit” of everyone involved. The fan, the player and the owner. (At least ideally.)
If the NFL, started to run other sports too, like the NFL and NBA merged, then you would have a much stronger case that the organization was in the business of running sport leagues, but as it is, you can’t really say they do anything other than promote the one business of professional football.
[quote]usmccds423 wrote:
I’m considering researching the impact IRC 1411 Net Investment Income Tax has on high net worth individuals, to give you an idea of what I’m looking for.
Thanks,
Chris [/quote]
This is purely a suggestion so take it for what it’s worth, but instead of focusing on high net worth individuals why don’t you focus it on middle class families that are doing everything right and saving in both tax-deferred and taxable accounts?
You take a year like 2013 and it’s not at all hard to imagine a middle class family finding themselves subject to this tax. A savvy investor could have easily had gains over 50% last year. Put that on top of a couple of $60k/year jobs and they would have only needed to start with $260k in capital to be subject to the NIIT. $260k for a couple in their late 40’s or so with blue collar $60k/year jobs is not exactly high income of high net worth. We’re now punishing some of the very people that are supposed to benefit from this tax, and discouraging savings in taxable accounts. This couple could very easily have three or four kids still at home that they are supporting as well. Remember this tax is based on MAGI, so their exemptions won’t help them any. Say the started at $500k (which despite what some want you to believe is not an astronomical amount, especially if they want to retire in their early 60’s and expect to live 30+ years) and they could have underperformed the markets and still be subject to the tax. Maybe our hypothetical couple should just put the money in a “MyRA” and stick to government bonds.
I’d throw in the 20% cap gains tax, too. It has a higher threshold but it also has a ridiculous marriage “penalty”. $400k for individuals and $450k for married couples? In what world does that make sense?
[quote]countingbeans wrote:
[quote]ZJStrope wrote:
It constantly promotes one thing only.
[/quote]
Well, that seals the deal then.
It doesn’t engage in promoting the NFL, the business of professional football for the sake of its own profit, the actual NFL, the people who work there and there alone, promote the business of football for the “profit” of everyone involved. The fan, the player and the owner. (At least ideally.)
If the NFL, started to run other sports too, like the NFL and NBA merged, then you would have a much stronger case that the organization was in the business of running sport leagues, but as it is, you can’t really say they do anything other than promote the one business of professional football. [/quote]
I disagree. I think it DOES engage in promoting the NFL.
I’ll admit I’m a bit torn on the subject. Perhaps it meets the STRICT definition I posted, even though I think it’s still a stretch. But it doesn’t seem to fit the spirit.
I’ll give you an example of what goes through my head.
An NFL team, on it’s own, is rather useless there’s a league to play in.
Compare that to the American Dairy Association. Even if the ADA did not exist, people would still be selling and buying milk.
The “NFL” is an integral part of the business of professional football, almost a necessity and vice-versa.
Keeping on the lines of the NIIT, and considering the fact that this is supposed to help pay for medicare, why don’t you continue down the healthcare tract? Examine why health premiums paid in an employer-sponsored plan are paid pre-tax, but if you have an individual plan you can’t deduct the costs until you hit 7.5% of AGI. Discuss the merits of health savings accounts and their tax implications, then discuss why they should be available to individuals outside of an employer plan. The current social environment wants to be all about fairness, so why are we rigging the tax code in favor of the employed? You can even spin it for your liberal professor: The unemployed are likely in a bad enough financial position, and the tax code is disadvantaging them even further.
[quote]tedro wrote:
[quote]usmccds423 wrote:
I’m considering researching the impact IRC 1411 Net Investment Income Tax has on high net worth individuals, to give you an idea of what I’m looking for.
Thanks,
Chris [/quote]
This is purely a suggestion so take it for what it’s worth, but instead of focusing on high net worth individuals why don’t you focus it on middle class families that are doing everything right and saving in both tax-deferred and taxable accounts?
You take a year like 2013 and it’s not at all hard to imagine a middle class family finding themselves subject to this tax. A savvy investor could have easily had gains over 50% last year. Put that on top of a couple of $60k/year jobs and they would have only needed to start with $260k in capital to be subject to the NIIT. $260k for a couple in their late 40’s or so with blue collar $60k/year jobs is not exactly high income of high net worth. We’re now punishing some of the very people that are supposed to benefit from this tax, and discouraging savings in taxable accounts. This couple could very easily have three or four kids still at home that they are supporting as well. Remember this tax is based on MAGI, so their exemptions won’t help them any. Say the started at $500k (which despite what some want you to believe is not an astronomical amount, especially if they want to retire in their early 60’s and expect to live 30+ years) and they could have underperformed the markets and still be subject to the tax. Maybe our hypothetical couple should just put the money in a “MyRA” and stick to government bonds.
I’d throw in the 20% cap gains tax, too. It has a higher threshold but it also has a ridiculous marriage “penalty”. $400k for individuals and $450k for married couples? In what world does that make sense?[/quote]
I certainly appreciate the suggestion. When I mentioned high net worth individuals I was think along the lines of, “these are the majority of folks that would be hit with this tax.”
I don’t know very much about 1411 yet (not sure if it’s going to be the topic at this point). The concern I have is first defining what the middle class is and second determining how many people/families actually fit what you describe. I don’t need census #'s or anything, but I do need to clearly define the issues.
Thanks,
Chris
[quote]tedro wrote:
Keeping on the lines of the NIIT, and considering the fact that this is supposed to help pay for medicare, why don’t you continue down the healthcare tract? Examine why health premiums paid in an employer-sponsored plan are paid pre-tax, but if you have an individual plan you can’t deduct the costs until you hit 7.5% of AGI. Discuss the merits of health savings accounts and their tax implications, then discuss why they should be available to individuals outside of an employer plan. The current social environment wants to be all about fairness, so why are we rigging the tax code in favor of the employed? You can even spin it for your liberal professor: The unemployed are likely in a bad enough financial position, and the tax code is disadvantaging them even further.[/quote]
Hmmm this does sound interesting.
Thanks!
[quote]tedro wrote:
$400k for individuals and $450k for married couples? In what world does that make sense?[/quote]
lol, a good topic for a paper in and of itself.
Bush largely eliminated it. Bam is bringing it back.
[quote]tedro wrote:
Examine why health premiums paid in an employer-sponsored plan are paid pre-tax, but if you have an individual plan you can’t deduct the costs until you hit 7.5% of AGI. [/quote]
EDIT: Nevermind. I misunderstood the credit. It’s very limiting.
[quote]ZJStrope wrote:
I disagree. I think it DOES engage in promoting the NFL. [/quote]
No you are correct, it does. But that isn’t the issue. What saves it is the fact is it ONLY promotes the NFL.
[quote]I’ll admit I’m a bit torn on the subject. Perhaps it meets the STRICT definition I posted, even though I think it’s still a stretch. But it doesn’t seem to fit the spirit.
I’ll give you an example of what goes through my head.
An NFL team, on it’s own, is rather useless there’s a league to play in.
Compare that to the American Dairy Association. Even if the ADA did not exist, people would still be selling and buying milk.
The “NFL” is an integral part of the business of professional football, almost a necessity and vice-versa.
[/quote]
I would use the same words to promote the idea that is SHOULD be TE. It is a necessity, and doesn’t exist for the sole purpose of profit. It exists for the purpose of running a league, because without it, the league would not exist.
[quote]countingbeans wrote:
I would use the same words to promote the idea that is SHOULD be TE. It is a necessity, and doesn’t exist for the sole purpose of profit. It exists for the purpose of running a league, because without it, the league would not exist. [/quote]
Best part of vague tax laws is the same facts and come to different conclusions. haha.
I certainly concede that it’s within reg, but it still doesn’t sit right in the gut.
[quote]ZJStrope wrote:
[quote]countingbeans wrote:
I would use the same words to promote the idea that is SHOULD be TE. It is a necessity, and doesn’t exist for the sole purpose of profit. It exists for the purpose of running a league, because without it, the league would not exist. [/quote]
Best part of vague tax laws is the same facts and come to different conclusions. haha.
I certainly concede that it’s within reg, but it still doesn’t sit right in the gut.[/quote]
That’s fine. I could be wrong. You see court cases go both ways over the same regs a lot. (Maybe “a lot” is a stretch, but…)
But, yeah, I’m saying, if I were the NFL I would just say “Go ahead and tax me, I’ll be sure to break even every year by lowing each teams dues, and taking a bigger salary.”
[quote]countingbeans wrote:
[quote]usmccds423 wrote:
[quote]countingbeans wrote:
[quote]usmccds423 wrote:
I would write it, but my professor is decidedly left leaning (although he’s a great guy) so I’m not sure it would be in my best interest…[/quote]
He is a professor, of course he “leans” left.
[/quote]
You should hear him go on and on about the IRS targeting of conservative groups. I think the term hoopla has been repeatedly used. Oh and he admits to getting the majority of his news from John Stewart…
My jaw dropped when I heard that one. He’s one of the most intelligent professors I’ve had so I was like, wtf??? [/quote]
College is a good time to be young, dumb and still a liberal. Save awaking for later in life, makes things easier on you. [/quote]
I had only one memorable conservative prof in college. I was in business school though and he was a retired bigshot who did it as a hobby and to keep from being bored while his passive income stream did work for him. Used to give all the youngsters crap. I remember him once asking a kid why he was a democrat(this was the year Obama and McCain were running and campus was just full of register to vote booths). Before the kid had a chance to answer the prof said “because you havent paid taxes yet, ill see you on the other side in a few years”. Shit was gold.
Well, the NIIT is too broad a topic for my professor’s liking…
Oh well.
[quote]usmccds423 wrote:
Well, the NIIT is too broad a topic for my professor’s liking…
Oh well. [/quote]
LOL, TRANSLATION:
No one really understands this clusterfuck of a trainwreak law yet, so I will have to do a boat load of research on my won to grade your paper.
[quote]countingbeans wrote:
[quote]usmccds423 wrote:
Well, the NIIT is too broad a topic for my professor’s liking…
Oh well. [/quote]
LOL, TRANSLATION:
No one really understands this clusterfuck of a trainwreak law yet, so I will have to do a boat load of research on my won to grade your paper. [/quote]
Lol, he did actually say he talked to one of the other professors about writing an article for the Journal of Accountancy on the topic and the response was basically what you wrote.