article highlighting the inequity of the tax treatment. It prompted lawmakers from both parties to try to close the so-called carried interest loophole. The on-again, off-again campaign has continued ever since.

Whenever legislation gathers momentum, the private equity industry — joined by real estate, venture capital and other sectors that rely on partnerships — has pumped up campaign contributions and dispatched top executives to Capitol Hill. One bill after another has died, generally without a vote.

One day in 2011, Gregg Polsky, then a professor of tax law at the University of North Carolina, received an out-of-the-blue email. It was from a lawyer for a former private equity executive. The executive had filed a whistle-blower claim with the I.R.S. alleging that their old firm was using illegal tactics to avoid taxes.

The whistle-blower wanted Mr. Polsky’s advice.

Mr. Polsky had previously served as the I.R.S.’s “professor in residence,” and in that role he had developed an expertise in how private equity firms’ vast profits were taxed. Back in academia, he had published a research paper detailing a little-known but pervasive industry tax-dodging technique.

$89 billion in private equity assets — as being “abusive” and a “thinly disguised way of paying the management company its quarterly paycheck.”

Apollo said in a statement that the company stopped using fee waivers in 2012 and is “not aware of any I.R.S. inquiries involving the firm’s use of fee waivers.”

floated the idea of cracking down on carried interest.

Private equity firms mobilized. Blackstone’s lobbying spending increased by nearly a third that year, to $8.5 million. (Matt Anderson, a Blackstone spokesman, said the company’s senior executives “are among the largest individual taxpayers in the country.” He wouldn’t disclose Mr. Schwarzman’s tax rate but said the firm never used fee waivers.)

Lawmakers got cold feet. The initiative fizzled.

In 2015, the Obama administration took a more modest approach. The Treasury Department issued regulations that barred certain types of especially aggressive fee waivers.

But by spelling that out, the new rules codified the legitimacy of fee waivers in general, which until that point many experts had viewed as abusive on their face.

So did his predecessor in the Obama administration, Timothy F. Geithner.

Inside the I.R.S. — which lost about one-third of its agents and officers from 2008 to 2018 — many viewed private equity’s webs of interlocking partnerships as designed to befuddle auditors and dodge taxes.

One I.R.S. agent complained that “income is pushed down so many tiers, you are never able to find out where the real problems or duplication of deductions exist,” according to a U.S. Government Accountability Office investigation of partnerships in 2014. Another agent said the purpose of large partnerships seemed to be making “it difficult to identify income sources and tax shelters.”

The Times reviewed 10 years of annual reports filed by the five largest publicly traded private equity firms. They contained no trace of the firms ever having to pay the I.R.S. extra money, and they referred to only minor audits that they said were unlikely to affect their finances.

Current and former I.R.S. officials said in interviews that such audits generally involved issues like firms’ accounting for travel costs, rather than major reckonings over their taxable profits. The officials said they were unaware of any recent significant audits of private equity firms.

For a while, it looked as if there would be an exception to this general rule: the I.R.S.’s reviews of the fee waivers spurred by the whistle-blower claims. But it soon became clear that the effort lacked teeth.

Kat Gregor, a tax lawyer at the law firm Ropes & Gray, said the I.R.S. had challenged fee waivers used by four of her clients, whom she wouldn’t identify. The auditors struck her as untrained in the thicket of tax laws governing partnerships.

“It’s the equivalent of picking someone who was used to conducting an interview in English and tell them to go do it in Spanish,” Ms. Gregor said.

The audits of her clients wrapped up in late 2019. None owed any money.

As a presidential candidate, Mr. Trump vowed to “eliminate the carried interest deduction, well-known deduction, and other special-interest loopholes that have been so good for Wall Street investors, and for people like me, but unfair to American workers.”

wanted to close the loophole, congressional Republicans resisted. Instead, they embraced a much milder measure: requiring private equity officials to hold their investments for at least three years before reaping preferential tax treatment on their carried interests. Steven Mnuchin, the Treasury secretary, who had previously run an investment partnership, signed off.

McKinsey, typically holds investments for more than five years. The measure, part of a $1.5 trillion package of tax cuts, was projected to generate $1 billion in revenue over a decade.

credited Mr. Mnuchin, hailing him as “an all-star.”

Mr. Fleischer, who a decade earlier had raised alarms about carried interest, said the measure “was structured by industry to appear to do something while affecting as few as possible.”

Months later, Mr. Callas joined the law and lobbying firm Steptoe & Johnson. The private equity giant Carlyle is one of his biggest clients.

It took the Treasury Department more than two years to propose rules spelling out the fine print of the 2017 law. The Treasury’s suggested language was strict. One proposal would have empowered I.R.S. auditors to more closely examine internal transactions that private equity firms might use to get around the law’s three-year holding period.

The industry, so happy with the tepid 2017 law, was up in arms over the tough rules the Treasury’s staff was now proposing. In a letter in October 2020, the American Investment Council, led by Drew Maloney, a former aide to Mr. Mnuchin, noted how private equity had invested in hundreds of companies during the coronavirus pandemic and said the Treasury’s overzealous approach would harm the industry.

The rules were the responsibility of Treasury’s top tax official, David Kautter. He previously was the national tax director at EY, formerly Ernst & Young, when the firm was marketing illegal tax shelters that led to a federal criminal investigation and a $123 million settlement. (Mr. Kautter has denied being involved with selling the shelters but has expressed regret about not speaking up about them.)

On his watch at Treasury, the rules under development began getting softer, including when it came to the three-year holding period.

Monte Jackel, a former I.R.S. attorney who worked on the original version of the proposed regulations.

Mr. Mnuchin, back in the private sector, is starting an investment fund that could benefit from his department’s weaker rules.

Even during the pandemic, the charmed march of private equity continued.

The top five publicly traded firms reported net profits last year of $8.6 billion. They paid their executives $8.3 billion. In addition to Mr. Schwarzman’s $610 million, the co-founders of KKR each made about $90 million, and Apollo’s Leon Black received $211 million, according to Equilar, an executive compensation consulting firm.

now advising clients on techniques to circumvent the three-year holding period.

The most popular is known as a “carry waiver.” It enables private equity managers to hold their carried interests for less than three years without paying higher tax rates. The technique is complicated, but it involves temporarily moving money into other investment vehicles. That provides the industry with greater flexibility to buy and sell things whenever it wants, without triggering a higher tax rate.

Private equity firms don’t broadcast this. But there are clues. In a recent presentation to a Pennsylvania retirement system by Hellman & Friedman, the California private equity giant included a string of disclaimers in small font. The last one flagged the firm’s use of carry waivers.

The Biden administration is negotiating its tax overhaul agenda with Republicans, who have aired advertisements attacking the proposal to increase the I.R.S.’s budget. The White House is already backing down from some of its most ambitious proposals.

Even if the agency’s budget were significantly expanded, veterans of the I.R.S. doubt it would make much difference when it comes to scrutinizing complex partnerships.

“If the I.R.S. started staffing up now, it would take them at least a decade to catch up,” Mr. Jackel said. “They don’t have enough I.R.S. agents with enough knowledge to know what they are looking at. They are so grossly overmatched it’s not funny.”

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Biden Aides Quietly Say His Tax Increases Would Help Charities

WASHINGTON — President Biden’s plan to raise taxes on high earners and the wealthy is likely to entice more rich Americans to give property or other assets to charity before they die in order to avoid large tax bills, a top administration official told nonprofit leaders last week in a private conference call.

On the call, a deputy director of Mr. Biden’s National Economic Council, David Kamin, was asked how the president’s tax plans would affect charitable giving — in particular, his proposals to change the tax treatment of the capital gains income that high earners receive from selling assets that have gained value, like businesses or stocks.

The plan “actually increases the incentive to give to charity,” Mr. Kamin told the group. “And it basically says if you want to not pay tax on the gain, the way you need to do that is to give the property to charity.”

Mr. Kamin further explained the administration’s rationale, saying “at that point it’s obviously with a charitable organization.”

published an online guide to Mr. Biden’s tax plans for its donors in November, noting that donating stocks and other assets that have gained value “to a public charity — like Duke — can have two powerful tax benefits.” The president’s proposed increase in the capital gains rate for high earners, it wrote, “would mean that significantly more tax could be avoided through a charitable gift, greatly incentivizing gifts of these appreciated investments.”

Patrick M. Rooney, an economist who is the executive associate dean for academic programs at the Indiana University Lilly Family School of Philanthropy, said Mr. Biden’s increases could also create a psychological incentive of sorts for people who were under pressure to pass assets on to their heirs, but instead want to donate them.

“It kind of gives you an out with the kids and the grandkids,” he said. “‘I’m not going to give it to you, because so much will be taken out in taxes — and you can help me decide who to give it to.’”

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Biden’s Modest Tax Plan

Business lobbyists and conservative think tanks are not big fans of President Biden’s proposed tax increases on the wealthy.

The Tax Foundation has said that Biden wants to raise the capital gains tax to “highs not seen since the 1920s.” Suzanne Clark of the U.S. Chamber of Commerce called the same plan “outrageous.” Jay Timmons of the National Association of Manufacturers called the proposed increase in the corporate tax rate “archaic.” And Brendan Bechtel, the chief executive of the construction company that bears his family name, said that “it doesn’t feel fair.”

All of this rhetoric has obscured a basic fact about Biden’s tax plan: It would not actually raise tax rates on the rich to high levels, historically speaking.

If all of Biden’s proposed tax increases passed — on the corporate tax, as well as on investment taxes and income taxes for top earners — the total federal tax rate on the wealthy would remain significantly lower than it was in the 1940s, ’50s and ’60s. It would also remain somewhat lower than during the mid-1990s, based on an analysis that Gabriel Zucman of the University of California, Berkeley, did for The Morning.

just how far taxes on the wealthy have fallen over the past 70 years. In the decades just after World War II, many corporations paid about half of their profits in federal taxes. (Shareholders, who are disproportionately affluent, effectively pay those taxes). Today, corporate taxes are only about one-fourth as large, as a share of G.D.P., as they were in the 1950s and ’60s.

The declines are not all ancient history, either. For most of the past quarter-century, taxes on the affluent have continued falling, including the rates on corporate profits, personal income, stock dividends, stock holdings and inheritances. Barack Obama reversed some of the declines, but only some. “The net effect over the past 25 years of federal income tax policy has been to reduce the overall revenue collected from top earners,” Owen Zidar, a Princeton University economist, told me.

Whether you like Biden’s plan or dislike it, it is not radical. For that reason, it is highly unlikely to have the harmful effects on economic growth that its critics are claiming. Remember: In the 1990s, the last time tax rates were as high as the ones Biden has proposed, the economy boomed. It also grew rapidly after World War II, when tax rates were higher yet.

History suggests that tax rates on the wealthy are not the main determinant of economic growth (and, if anything, higher taxes on the rich can sometimes lift growth). The main effect of Biden’s tax plan probably won’t be on the level of G.D.P. It will instead be on the relative tax burden that wealthy people pay. When they criticize the plan as unfair, archaic and outrageous, they are really saying that they enjoy paying low tax rates.

admit up to 62,500 refugees in the next six months, reversing his decision to keep a lower limit set by Donald Trump.

  • The E.P.A. plans to limit a class of climate-warming chemicals used in air-conditioning and refrigeration.

  • Richard Cordray, an ally of Senator Elizabeth Warren, will oversee federal student aid, putting him at the center of Democratic disagreements over forgiving debt.

  • Representative Liz Cheney, the No. 3 House Republican, accused Trump of “poisoning our democratic system” by making false claims of voter fraud.

  • The country’s increasing diversity isn’t doing as much to help Democrats as liberals hope, Nate Cohn explains.

  • When the World Trade Organization meets this week, should it waive Covid vaccine patents to increase access for poorer countries?

    from Stromboli.

    A Times classic: Can you guess whether these neighborhoods voted for Biden or for Trump?

    Lives Lived: He was born Joseph Jacques Ahearn, but his mother thought Jacques d’Amboise would be better suited to the ballet world. After he became a dancer, d’Amboise found stardom in New York and Hollywood. He died at 86.

    the critic Jesse Green writes in The Times.

    The album, “All the Girls,” also featuring the soprano Sally Wilfert, came out two days after Luker’s death in December. Green calls it beautiful and funny. (It includes this song, which is worth watching.)

    Tonight, Luker’s colleagues and friends will tell stories and sing songs from her career at a fund-raising concert you can stream. — Claire Moses, Morning writer

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    Why Biden’s Plan to Raise Taxes for Rich Investors Isn’t Hurting Stocks

    “Most Democrats seem to be on board with narrowing the differential between the tax rate on capital gains and ordinary income, but there’s opposition for treating the rates as the same,” wrote analysts with Beacon Policy Advisors, a political consultancy. “This means there’s probably a middle ground for raising the capital gains rate on top earners to, say, 28 percent.”

    If stocks continued their climb, it would largely be in keeping with previous periods when capital gains taxes were raised.

    In 2013, when the tax rose to the current 23.8 percent, from 15 percent, on Americans with the highest incomes, the S&P 500 climbed nearly 30 percent. It was the best year for stocks in the last two decades. And after the top rate rose to 28 percent, from 20 percent, at the end of 1986, the market continued to roar higher, by nearly 40 percent through most of 1987.

    Stocks eventually suffered their worst single-day collapse ever on Black Monday in October 1987, but that crash had little to do with tax policy, and the markets ended the year slightly higher. In 1991, a small increase to 28.9 percent in the capital gains rate for those with the largest incomes coincided with a 26 percent rise in the S&P 500. The major driver for that gain had nothing to do with taxes; it was the emergence from a recession.

    Similarly, investors appear to be focusing on evidence that the economy is on the brink of breakneck growth. That surge is being fueled by a river of federal government spending, rock-bottom interest rates and more Covid-19 vaccinations. In the first three months of the year, the economy grew at an annualized clip of 6.4 percent. At that pace, 2021 would be the best year for growth since 1984.

    Economic growth and corporate profits tend to rise together. And signs of additional oomph in the economy are already showing up in earnings reports from publicly traded companies.

    Tech giants such as Tesla, Microsoft, Amazon, Apple and Google’s parent company, Alphabet, all reported first-quarter profits that trounced analyst expectations.

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    It’s Not Just the Really Wealthy Who Face Tax Increases

    Mr. Biden has cleared up some issues for the middle class in his proposal. He has recommended an exemption of $1 million on the capital gains of assets transferred to heirs. He has also left in place the $250,000 exemption on taxable gains in the value of a person’s primary residence. (These exemptions would double for a couple.)

    But in many cases, this would affect people who would not have had to think about paying any tax at death, whether the estate tax exemption remained the current $11.7 million or dropped to $3.5 million, which had been expected to happen.

    “The changes to the step-up in basis — that’s the curveball,” said Paul Saganey, the founder and president of Integrated Partners, a financial advisory firm. “It’s really going to surprise people. People don’t know what it is or what it means, so how can they quantify the impact of it?”

    Also missing was any mention of reinstating the full deduction for state and local taxes, known as SALT. The cap on these deductions in the 2017 tax law hurt people living in the Northeast and West Coast states, where the property and state taxes are higher.

    Mr. Biden has proposed limiting a break on real estate transactions. He would cap at $500,000 the value of 1031(b) exchanges, which have essentially allowed real estate investors to roll gains from the sale of buildings into new buildings without ever paying capital gains taxes on them. Coupled with the step-up in basis at death, which wiped out all the gains in value of the buildings, this was a large tax break for families whose wealth rested on real estate investment and ownership.

    What is less known is what, if anything, may be adopted from the “For the 99.5 percent” plan. The plan would close some popular tax-reduction strategies, many of which were targeted during the Obama administration.

    Three of the proposals would be relatively easy to enact. One would end short-term trusts that allow people to pass tax-free to their heirs expected appreciation — say from the sale of a private business. Another would limit tax-free gifts that can be given each year to trusts to fund things like life insurance to pay estate taxes. A third would curtail special tax treatment that family partnerships receive, even when they own liquid securities and not an operating business.

    “They already have the regulations written of these,” Ms. Lucina said. “I don’t want to scare anyone that these will be enacted. But some of these could be enacted quickly and looked at as loophole closers.”

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    Biden’s Tax Proposals Are Not Just for the Really Wealthy

    Mr. Biden has cleared up some issues for the middle class in his proposal. He has recommended an exemption of $1 million on the capital gains of assets transferred to heirs. He has also left in place the $250,000 exemption on taxable gains in the value of a person’s primary residence. (These exemptions would double for a couple.)

    But in many cases, this would affect people who would not have had to think about paying any tax at death, whether the estate tax exemption remained the current $11.7 million or dropped to $3.5 million, which had been expected to happen.

    “The changes to the step-up in basis — that’s the curveball,” said Paul Saganey, the founder and president of Integrated Partners, a financial advisory firm. “It’s really going to surprise people. People don’t know what it is or what it means, so how can they quantify the impact of it?”

    Also missing was any mention of reinstating the full deduction for state and local taxes, known as SALT. The cap on these deductions in the 2017 tax law hurt people living in the Northeast and West Coast states, where the property and state taxes are higher.

    Mr. Biden has proposed limiting a break on real estate transactions. He would cap at $500,000 the value of 1031(b) exchanges, which have essentially allowed real estate investors to roll gains from the sale of buildings into new buildings without ever paying capital gains taxes on them. Coupled with the step-up in basis at death, which wiped out all the gains in value of the buildings, this was a large tax break for families whose wealth rested on real estate investment and ownership.

    What is less known is what, if anything, may be adopted from the “For the 99.5 percent” plan. The plan would close some popular tax-reduction strategies, many of which were targeted during the Obama administration.

    Three of the proposals would be relatively easy to enact. One would end short-term trusts that allow people to pass tax-free to their heirs expected appreciation — say from the sale of a private business. Another would limit tax-free gifts that can be given each year to trusts to fund things like life insurance to pay estate taxes. A third would curtail special tax treatment that family partnerships receive, even when they own liquid securities and not an operating business.

    “They already have the regulations written of these,” Ms. Lucina said. “I don’t want to scare anyone that these will be enacted. But some of these could be enacted quickly and looked at as loophole closers.”

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    Biden’s Big Speech, by the Numbers

    The S.E.C.’s new enforcement chief resigns unexpectedly. Days into her new job, Alex Oh, a former partner at Paul, Weiss, stepped down after a federal court ruling involving one of her former clients, Exxon Mobil. In a case involving claims of human rights abuses in Indonesia, the presiding judge rebuked Exxon’s legal team for derogatory comments about opposing counsel.

    Endeavor will finally go public. The entertainment giant co-founded by Ari Emanuel, which owns the WME talent agency and the UFC mixed martial arts league, raised $511 million in its I.P.O. at a $10 billion valuation, the top of its expected price range. Its successful offering comes two years after it called off an I.P.O. amid a lukewarm reception from investors.

    Verizon considers selling its old-guard internet media business. The telecom giant is exploring the sale of assets like AOL and Yahoo, according to The Wall Street Journal. Potential buyers include Apollo Global Management, and the WSJ reports that a deal could be valued at up to $5 billion. Verizon spent $9 billion buying the once-dominant web giants.

    For many cryptocurrency supporters and investors, U.S. regulatory approval of a Bitcoin exchange-traded fund represents the holy grail. It would allow the crypto-curious to get exposure to Bitcoin without having to buy the tokens themselves, signifying that digital assets are really, truly mainstream. But it’s not meant to be — yet. Yesterday, the S.E.C. delayed a decision on a Bitcoin E.T.F. proposal from the investment manager VanEck, saying it needs more time but offering no other explanation.

    Delay is not denial, and it may be a good sign, Todd Cipperman, the founder of the compliance services firm CCS, told DealBook. When considering the concept of a crypto E.T.F. in 2018, the S.E.C. raised questions about investor protection issues and put a “wet blanket on the whole idea,” he said. Now crypto is much bigger, and Gary Gensler, who taught courses about blockchain technology at M.I.T., is chair of the S.E.C. His expertise doesn’t guarantee success for crypto E.T.F.s, but it will be easier for an expert in the field to approve them, Cipperman suggested.

    The deadline can be extended again. The S.E.C. gave itself until mid-June, with the option to take more time, but it must decide before year’s end. The regulator has rejected every proposal to date, starting with the first Bitcoin E.T.F. pitch in 2013, presented by the Winklevoss twins, which was eventually rejected in 2017 (and again in 2018). There are several E.T.F. proposals on the table now, including one from the traditional finance giant Fidelity.

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    California Is Awash in Cash, Thanks to a Booming Market

    In the early days of the pandemic, no one would have looked to the stock market for salvation. From February to late March last year, the S&P 500 suffered one of its sharpest crashes ever, falling nearly 34 percent. But once the federal government began pumping money into the markets and the economy through bond-buying programs and stimulus, the market began rebounding.

    And professional money managers kept buying stocks. Amateur investors, stuck at home, piled into the market and drove up stock prices further. After hitting a bottom in March 2020, the S&P 500 is up nearly 90 percent, creating close to $17 trillion in paper gains.

    Much of that value was created by California companies. The market value of Apple, based in Cupertino, Calif., has risen by over $1 trillion in the past year. The gains for Alphabet and Facebook, combined, have created another $1 trillion in value. Tesla, based in Palo Alto, Calif., added over $500 billion.

    The surge in market value created a significant amount of wealth for executives and workers, including in the technology sector. Executives at major companies typically have pre-established stock sale programs that are constantly converting some of their shares into cash. As they’ve sold into a rising market over the last year, those gains have been especially large; in August, Apple’s chief executive, Tim Cook, sold more than $130 million worth of his stock.

    “When the stock market does well, they do very well,” said David Hitchcock, the primary analyst on California for the bond-rating firm S&P Global, of the state’s wealthy residents. “And in fact, it’s not just the stock market but initial public offerings. Because with Silicon Valley, when entrepreneurs get stock grants that they exercise, or stock options, California makes out very well.”

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    Biden Seeks $80 Billion to Beef Up I.R.S. Audits of High-Earners

    WASHINGTON — President Biden, in an effort to pay for his ambitious economic agenda, is expected to propose giving the Internal Revenue Service an extra $80 billion and more authority over the next 10 years to help crack down on tax evasion by high-earners and large corporations, according to two people familiar with the plan.

    The additional money and enforcement power will accompany new disclosure requirements for people who own businesses that are not organized as corporations and for other wealthy people who could be hiding income from the government.

    The Biden administration will portray those efforts — coupled with new taxes it is proposing on corporations and the rich — as a way to level the tax playing field between typical American workers and very high-earners who employ sophisticated efforts to minimize or avoid taxation.

    Mr. Biden plans to use money raised by the effort to help pay for the cost of his “American Families Plan,” which he will detail before addressing a joint session of Congress on Wednesday.

    $2.3 trillion infrastructure package, is expected to cost at least $1.5 trillion and will include universal prekindergarten, a federal paid leave program, efforts to make child care more affordable, free community college for all and tax credits meant to fight poverty.

    The administration also aims to pay for the plan by raising the top marginal income tax rate for wealthy Americans to 39.6 percent from 37 percent and raising capital gains tax rates for those who earn more than $1 million a year. Mr. Biden will also seek to raise the tax rate on income that people earning more than $1 million per year receive through stock dividends, according to a person familiar with the proposal.

    Administration officials have privately concluded that an aggressive crackdown on tax avoidance by corporations and the rich could raise at least $700 billion on net over 10 years. The $80 billion in proposed funding would be an increase of two-thirds over the agency’s entire funding levels for the past decade.

    The administration is expected to portray the $780 billion it expects to collect through enhanced enforcement as conservative. That figure includes only money directly raised by enhanced tax audits and additional reporting requirements, and not any additional revenue from people or companies choosing to pay more taxes after previously avoiding them.

    Previous administrations have long talked about trying to close the so-called tax gap — the amount of money that taxpayers owe but that is not collected each year. This month, the head of the I.R.S., Charles Rettig, told a Senate committee that the agency lacked the resources to catch tax cheats, costing the government as much as $1 trillion a year. The agency’s funding has failed to keep pace with inflation in recent years, amid budget tightening efforts, and its audits of rich taxpayers have declined.

    whose research with the Harvard University economist Lawrence H. Summers suggests that the United States could raise as much as $1.1 trillion over a decade via increased tax enforcement.

    Mr. Summers praised Mr. Biden’s expected plan in an email late Monday. “This is the broadly right approach,” he said. “Deterioration in I.R.S. enforcement effort and information gathering is scandalous. The Biden plan would make the American tax system fairer, more efficient and, I’m confident, raise more revenue than official scorekeepers now forecast — likely a trillion over 10 years.”

    Mr. Biden’s efforts would incorporate some of Ms. Sarin and Mr. Summers’s suggestions, including investing heavily in information technology improvements to help the agency better target its audits of high-earners and companies.

    They would also provide a dedicated funding stream to the agency, to enable officials to steadily ramp up their enforcement practices without fear of budget cuts, and to signal to potential tax evaders that the agency’s efforts will not be soon diminished. Mr. Biden would also add new requirements for people who own so-called pass-through corporations or hold their wealth in opaque structures, reminiscent of a program established under President Barack Obama that helps the agency better track possible tax evasion by Americans with overseas holdings.

    Fred T. Goldberg Jr., an I.R.S. commissioner under President George H.W. Bush, called Mr. Biden’s plan “transformative” for combining those efforts.

    “Information reporting, coupled with restoring enforcement efforts, is key to improve in compliance,” Mr. Goldberg said in an email. “Audits alone will never do the trick.”

    He added: “None of this happens overnight. A decade of stable funding is necessary to recruit and train talent and build on the necessary technology — not only for compliance purposes but to meet the quality of services that the vast majority complaint taxpayers expect and deserve.”

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    Biden May Eliminate the Carried Interest Loophole

    President Biden is expected to unveil a $1.5 trillion “human infrastructure” plan next week that will focus on education, child care and paid leave for workers, among other things. It would be paid for in part by new taxes on the rich, including the end of a tax break that lawmakers have tried to eliminate for years.

    The White House will propose a major change to capital gains taxes, with people earning more than $1 million per year paying the top marginal tax rate on their investment gains. Mr. Biden wants to raise that rate to 39.6 percent.

    The carried interest loophole might finally disappear. Profits earned from funds owned by real estate investors and managers of private equity and venture capital firms are taxed as capital gains at about 20 percent, instead of as regular income, which is taxed at more than double that rate when state levies and other taxes are taken into account.

    • Financial industry executives and their lobbyists have long asserted that carried interest merely represents a return on investment, not income, an argument that survived challenges as recently as 2017. (Here’s Andrew back in 2007 writing about how lawmakers were trying, unsuccessfully, to end the “longstanding, but little understood, practice.”)

    • In a 2015 DealBook Op-Ed, the law professor Victor Fleischer, a top proponent for raising taxes on carried interest, estimated that such a move could raise $180 billion.

    • In a 2011 Times Op-Ed, Warren Buffett decried the treatment of carried interest, which allowed him to report a lower tax rate than his secretary. A minimum tax on millionaires was proposed shortly thereafter and dubbed the “Buffett rule.”

    • JPMorgan Chase’s Jamie Dimon has been a regular critic of carried interest, even though it benefits many of the bank’s clients. In his latest letter to shareholders, he said it could be seen as “another example of institutional bias and favoritism toward special interest groups.”

    Other changes to the tax code could be in the works, including to the estate tax. Private equity executives are also worried that the Biden administration may limit the tax deductibility of corporate interest payments, which would be another hit to their business model.

    they may be on board with eliminating some business tax loopholes. The White House wants that tax revenue to fund the infrastructure bill it unveiled last month. But another group of Republican senators yesterday proposed a much smaller infrastructure bill — $568 billion, versus Mr. Biden’s $2.3 trillion — that would do away with any corporate tax increases.

    U.S. health officials may soon lift the pause on Johnson & Johnson’s vaccine. A committee of outside experts will meet today to discuss whether to resume giving the shot; they’re expected to vote in favor. But the damage may be done: The Biden administration has reportedly written off the J&J shot’s importance to U.S. vaccination efforts.

    President Biden sets a new climate goal. At the first day of a climate summit that the U.S. convened, he pledged to cut America’s emissions in half by 2030, compared with 2005 levels, and offered more funding for developing countries to help them meet their targets. Swiss Re estimated that climate change could cost the global economy as much as $23 trillion in the coming decades.

    Airlines see clearer skies ahead. Carriers expect travel to return almost to normal levels by the summer, with the largest airlines expected to offer as many seats this July as they did in July 2019, by one estimate. The industry plans to call back thousands of employees and hire hundreds of pilots.

    Scrutiny over a fatal Tesla crash intensifies. Two senators asked regulators to create recommendations for autonomous vehicle software, following the deaths of two men in a Tesla, in which police said no one was behind the wheel. Consumer Reports said it was able to trick Tesla’s Autopilot into operating without anyone in the driver’s seat.

    AT&T gains ground in the streaming race. The company added 2.7 million subscribers to HBO and HBO Max in the first quarter. Also worth noting: AT&T collects nearly three times more revenue per streaming user than Disney, and trails only Netflix by that measure.

    reckoning on corporate political donations that will be a prominent feature of proxy season, with many shareholder proposals demanding greater disclosure of company spending.

    “Companies are reading the writing on the wall,” Thomas DiNapoli, New York State’s comptroller and trustee for the state’s public pension fund, told DealBook. “Political and social polarization are bad for their business, and they need to decide if political donations are worth the risk.”

    “Time will tell if their increased attention to these issues is lip service or if it represents a sincere change in corporate culture,” Mr. DiNapoli said. “At a minimum, investors need disclosure of this spending.” New York’s public pension fund is the third-largest in the U.S. and since 2010 it has filed more than 155 shareholder proposals on political spending, winning more than 40 adoptions or agreements, including from Bank of America, Delta Air Lines and Pepsi. Three of five resolutions it has advanced this year have already been withdrawn, with the companies agreeing to make changes without putting them to a vote. That’s a 60 percent hit rate, and companies that wouldn’t engage before are now at least responsive, a spokesperson for the fund said.

    “Companies are now expected to have core values — almost personalities,” said Bruce Freed, the president of the Center for Political Accountability, a nonprofit that partners with shareholders on proposals. Recent agreements, like the ones brokered by Mr. DiNapoli, are a “strong indication” that corporations are feeling “real pressure,” he said. Nine of 30 companies (including those noted above) have agreed this year to provide more disclosure on political donations. Last year, eight of 40 companies facing similar proposals agreed to act instead of putting the question to shareholders in a vote. The Capitol riot “raised the stakes,” Mr. Freed said, and the pressure on companies has not relented since.


    read this comprehensive account by The Times’s Tariq Panja and Rory Smith.

    Chicago, Flat Rock, Mich., and Kansas City, Mo., through the first two weeks of May. The Kansas City factory makes the F-150 pickup, Ford’s most profitable model.

  • G.M. has kept its factory in Kansas City, Kan. — which makes the Chevy Malibu sedan — closed since February, and has cut production at other plants.

  • Daimler has temporarily halted production at two plants in Germany that produce lower-cost C-class vehicles.

  • Jaguar Land Rover, Britain’s biggest carmaker, will temporarily shut two of its factories there starting next week.

  • Renault scrapped production forecasts, and said it was prioritizing the manufacturing of its most profitable models.

  • The shortage is unlikely to end anytime soon, according to Intel’s C.E.O., Pat Gelsinger: “This will take a while until people can put more capacity in the ground,” he told The Wall Street Journal.


    Some of the academic research that caught our eye this week, summarized in one sentence:


    Percy Miller, better known to hip-hop fans as Master P, plans to invest $10 million in companies led by or serving people who are Black, Indigenous and people of color, DealBook is first to report. He sees ownership and equity as keys to bridging racial wealth gaps, and wants other investors to follow his lead.

    “This is all about economic empowerment,” Mr. Miller told DealBook. Early in his career, Mr. Miller opened a record store from which he launched No Limit Records, once one of the largest independent labels. More recent projects have been aimed at social entrepreneurship, like an “Uncle P” line of food products to replace Aunt Jemima and Uncle Ben’s (both have since been renamed) that would dedicate a portion of profits to supporting Black communities.

    Mr. Miller wants to invest in an array of industries, with education, including financial literacy, a priority. “I always tell people, product outweighs talent — at the same time, education and wisdom are so important,” he said. “That’s the longevity of my success.”

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