The rally was meant to shore up support for Mr. Laschet, but for townspeople and tourists alike, it turned into an opportunity to catch a last glimpse of the woman whose outsize role in their country and in Europe has influenced their lives since November 2005.

Christine Braun, a member of the Christian Democrats in Stralsund, said that Mr. Laschet would be getting her vote, but he was not the reason she was standing in the driving rain on a chilly September night.

“I came to honor Ms. Merkel, our chancellor and representative,” she said, adding that throughout her 30 years representing the constituency, Ms. Merkel would visit regularly, attending meetings and engaging with the community. “She remained approachable and down-to-earth.”

Vilana Cassing and Tim Taugnitz, both students in their early 20s, were vacationing in Stralsund and saw the posters advertising the event and Ms. Merkel’s attendance. They decided to attend more out of curiosity to see the woman who had shaped their lives than out of political interest.

They described their political leanings as “leftist-Green,” saying they would vote on Sunday, but not for Mr. Laschet.

“I think it is good if the Christian Democrats go into opposition,” Mr. Taugnitz said.

That could happen. On Sunday, voters will go to the polls, though many may have already done so, with the pandemic resulting in an unusually high number of requests for mail-in ballots — a form of voting that has been around in Germany since 1957 and that organizers assure is safe.

Should the Social Democrats emerge as the strongest party, they would still need to find at least one partner to form a government. While that means that the roles could be reversed, with the Christian Democrats as the junior partners under Mr. Scholz, more likely is a center-left alliance led by the Social Democrats together with the Greens and the business friendly Free Democrats.

Mr. Laschet has been warning against the threat posed by such an alliance, seeking to paint the other parties as a danger to the prosperity that Germans have enjoyed under Ms. Merkel.

“It’s completely wrong what the S.P.D. and the Left and the Greens are planning,” Mr. Laschet told the crowd on Tuesday, referring to pledges to increase taxes on the country’s highest earners. “They should invest and create jobs.”

Ms. Merkel instead sought to praise Mr. Laschet and Georg Günther, who hopes to win the seat in Parliament that she is vacating after 30 years, for their achievements. She expressed confidence that both men would continue the course that she had set and urged her supporters to back them.

“Several times today I have reported my shoe size,” Ms. Merkel told the crowd in Stralsund. Nodding to Mr. Günther and smiling, she said that he could “manage” to fill her shoes — European size 38, or U.S. 7 and a half. Then she turned to Mr. Laschet and added, “he is the one who can do it,” at the chancellery.

Listening from the sidelines, Thilo Haberstroh, a native of the southwestern city of Karlsruhe who was in Stralsund on business and only happened on the rally by chance, said he wasn’t convinced that anyone in the running had what it takes to be the next chancellor of Germany.

“This was interesting, but none of them have really made an impression on me,” he said. “I still don’t know who I will get my vote on Sunday.”

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Canada Election 2021: Justin Trudeau Projected to Remain Prime Minister

OTTAWA — Prime Minister Justin Trudeau’s political gamble failed to pay off Monday when Canadian voters returned him to office but denied him the expanded bloc of power he was seeking in Parliament.

Election returns late on Monday showed that while he would remain prime minister, it will again be as the head of a minority government, Canadian broadcasters projected.

In August, with his approval ratings high, Mr. Trudeau called a “snap election,” summoning voters to the polls two years before he had to. The goal, he said, was to obtain a strong mandate for his Liberal Party to lead the nation out of the pandemic and into recovery.

But many Canadians suspected that his true ambitions were mere political opportunism, and that he was trying to regain the parliamentary majority the Liberals had until they lost seats in the 2019 election.

Mr. O’Toole, seeking to broaden Conservatives’ appeal, produced a 160-page campaign platform that essentially turned the party’s back on many once-central positions, like opposition to carbon taxes.

Mr. Trudeau broke ethics laws when he and his staff pressured his justice minister, an Indigenous woman, in 2018 to offer a large Canadian engineering firm a deal allowing it to avoid a criminal conviction on corruption charges. Last year a charity with close ties to the Trudeau family was awarded a no-bid contract to administer a Covid-19 financial assistance plan for students. The group withdrew, the program was canceled and Mr. Trudeau was cleared of conflict of interest allegations.

And while Mr. Trudeau champions diversity and racial justice, it came out during the 2019 vote that he had worn blackface or brownface at least three times in the past.

“Every Canadian has met a Justin Trudeau in their lives — privileged, entitled and always looking out for No. 1,” Mr. O’Toole said during the campaign. “He’ll say anything to get elected, regardless of the damage it does to our country.”

Mr. Trudeau returned the criticism, saying Mr. O’Toole’s willingness to ditch Conservative policies and alter his platform mid-campaign showed it was he who would say or promise anything to voters.

While many voters eagerly bumped elbows and posed for selfies with Mr. Trudeau at campaign stops, his campaign was often disturbed by unruly mobs protesting mandatory vaccines and vaccine passports. One event was canceled out of safety concerns, and Mr. Trudeau was pelted with gravel at another.

Mr. Trudeau did have a strong political challenger on the left nationally with Jagmeet Singh of the New Democrats. Mr. Singh, a lawyer and former provincial lawmaker from Ontario, consistently had the highest approval ratings of all the leaders before and during the campaign. But personal popularity was not enough: His party gained three seats but won only a total of 27.

As before the election, the New Democrats are likely to be Mr. Trudeau’s primary source of support in Parliament.

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How Top Accounting Firms Help Their Clients Sidestep Taxes

This year, Mr. Harter returned to PwC.

“I fully complied with Treasury Department conflicts rules by not meeting with PwC representatives” during a two-year “cooling off” period that restricts government officials from meeting with their former employers, Mr. Harter said. Although he was involved in the construction of the offshore tax break and met with corporate lobbyists, Mr. Harter said he did not recall meeting with Ms. Olson or other PwC officials on the topic.

Ms. Olson referred questions to PwC.

The 2017 tax overhaul included a provision that let some people take a 20 percent tax deduction on certain types of business income. But the law — known as Section 199A — largely excluded an undefined category of “brokerage services.” In 2018, lobbyists for several industries, including real estate and insurance, visited the Treasury to try to persuade officials that the broker prohibition should not apply to them.

On Aug. 1, records show, Ms. Ellis met with her former PwC colleague, Mr. Feuerstein, and three other lobbyists for his client, the National Association of Realtors. They wanted real estate brokers to qualify for the 20 percent deduction.

The meeting took place before the first draft of the proposed rules was even made public, which meant that, right off the bat, Ms. Ellis’s former PwC colleague and his client had an inside track.

When the Treasury published its first version of the proposed rules a week later, real estate brokers were eligible. The National Association of Realtors took credit for the victory on its website. (The final rules applied only to brokers of stocks and other securities.)

Ms. Ellis’s meeting with Mr. Feuerstein appeared to violate a federal ethics rule that restricts government officials from meeting with their former private sector colleagues, said Don Fox, the acting director of the Office of Government Ethics during the Obama administration and, before that, a lawyer in Republican and Democratic administrations.

Mr. Fox described the meeting as improper. “It certainly is going to call into question how that regulation was drafted,” he said. “There’s no way to undo the taint that is now going to be attached to that.”

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Hedge Fund’s Insiders Agree to Pay as Much as $7 Billion to I.R.S.

A yearslong dispute between a pioneering hedge fund and the Internal Revenue Service ended Thursday with an enormous bill for taxes and penalties: as much as $7 billion.

James Simons, a mathematician whose algorithmic approach has been adopted by many other investment funds, and some of his former colleagues at Renaissance Technologies have settled a decade-long dispute with the government over the tax treatment of some of their investments, the firm said in letter to investors.

The settlement, which involves 10 years’ worth of trades made by the hedge fund, could be worth as much as $7 billion, according to a person with knowledge of the agreement. It is one of the largest federal tax disputes in history.

The deal ends a standoff that led to a congressional investigation and involved two politically connected financiers: Mr. Simons, a longtime patron of Democratic candidates with an estimated net worth of $25 billion, and Robert Mercer, a former Renaissance executive whose advocacy for conservative causes included helping to found Cambridge Analytica. After Donald J. Trump won the 2016 presidential election, the now-defunct political consulting firm became embroiled in a scandal for harvesting Facebook data without users’ consent to assist his campaign.

$10 million in Breitbart News, and was a key supporter of Stephen K. Bannon, who was Breitbart’s chairman before becoming Mr. Trump’s chief strategist.

The billions in payments to the I.R.S. will be made by current and former investors in a small group of Renaissance funds, but principally its Medallion fund. Those investors include seven people who were members of the firm’s board between 2005 and 2015, as well as their spouses. Mr. Simons will make a payment of $670 million on top of his obligation as part of that group, according to the letter.

“Renaissance’s board ultimately concluded that the interests of our investors from the relevant period would be best served by agreeing to this resolution with the I.R.S., rather than risking a worse outcome, including harsher terms and penalties, that could result from litigation,” Peter Brown, the firm’s chief executive, wrote.

Renaissance is best known for pioneering a data-intensive form of stock trading called quantitative strategy, which has been adopted by many other hedge funds and trading platforms on Wall Street. The settlement centers on the firm’s Medallion fund, which manages about $15 billion, mostly for employees and former employees of the firm and their family members.

Mr. Simons founded the firm in 1982. Once the head of the math department at Stony Brook University on Long Island, he was a code-breaker for the U.S. military during the Vietnam War. He stepped down from the firm’s day-to-day operations in 2010, handing the reins to Mr. Mercer and Mr. Brown as co-chief executives.

reported that contractors and employees of Cambridge Analytica, eager to sell psychological profiles of American voters to political campaigns, acquired the private Facebook data of tens of millions of users — the largest known leak in the company’s history. Facebook eventually said as many as 87 million users — mostly in the United States — had their data harvested by the firm.

Mr. Mercer’s decision to resign as co-chief of Renaissance shortly after Mr. Trump won the presidency came about in part because of his involvement in bankrolling Cambridge Analytica. Some of the hedge fund’s investors had voiced concerns about Mr. Mercer’s political activities.

The firm’s letter on Thursday said that aside from the board members and their spouses, other investors will be required to pay additional tax and interest owed, but no penalties. Renaissance’s outside clients, who include wealthy individuals, pensions and other investors, are not expected to be affected by the settlement.

The tax dispute involved Medallion’s fast-paced options trading and how those transactions should be taxed — a major consideration given that the firm’s rapid-fire trading had a history of generating big profits.

At the time of the transactions the federal tax rate on long-term capital gains was about half what it was for short-term capital gains. The hedge fund argued that many of its trades were eligible to be taxed at the lower rate because it had converted those options trades into longer-term holdings through the use of complex financial instruments.

These instruments involved baskets of stocks put together by a bank. But Medallion didn’t buy the actual basket of stocks; it instead bought an option on that basket and sometimes gave the banks instructions on how to trade those stocks. Basket options have been criticized for having allowed hedge funds to borrow money more easily and allowing them to make bigger and potentially riskier trades.

The I.R.S. argued that the basket option trades should have been taxed at the higher rate because they were mainly the result of short-term trading.

The disagreement drew the attention of Congress, and led to rule changes. Following a report from the Senate Permanent Committee on Investigations, the I.R.S. issued new guidance in 2015 that sought to clamp down on this type of trading by making it more difficult and costly for hedge funds to buy basket options. Such investment vehicles had to be declared on the tax returns of any investor who used them, the agency said.

The I.R.S. had said its guidance on basket options would be retroactive, and applied to all transactions as far back as Jan. 1, 2011.

Still, some senators were critical of the I.R.S. for taking so long to change its rules and start investigating the trading practice, including at Renaissance.

Senator Carl Levin, the Michigan Democrat who headed the Senate committee in 2014 and died in July, said the I.R.S. guidance would stop banks and hedge funds from using “dubious structured financial products” that had cost taxpayers billions.

Elise Bean, a former aide to Mr. Levin, said she wished her former boss had lived to see the settlement. “It’s good to see that, despite a yearslong, knock-down, bare-knuckles battle, the I.R.S. prevailed in compelling at least one set of billionaires to pay the taxes they owe,” she said.

Jesse Drucker contributed reporting.

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Invitation Homes & PulteGroup Form Strategic Relationship For Purchase Of Approximately 7,500 New Homes

DALLAS–(BUSINESS WIRE)–Invitation Homes Inc. (NYSE: INVH)(“Invitation Homes” or the “Company”) , the nation’s premier single-family home leasing company, and PulteGroup, Inc. (NYSE: PHM), the nation’s third largest homebuilder, announced today the formation of an innovative strategic relationship. As part of this relationship, Invitation Homes expects to purchase approximately 7,500 new homes over the next five years that PulteGroup will design and build expressly for this purpose.

The companies have already reached agreement on the construction and sale of over 1,000 homes across seven communities over the next several years, with the first sales expected to close in 2022. Initial projects are scheduled for delivery in Florida, Georgia, Southern California, North Carolina and Texas.

At Invitation Homes, we’re committed to serving the growing share of Americans who are opting not to buy a house by providing high-quality homes with valued features such as close proximity to jobs and access to good schools,” said Dallas Tanner, President and CEO of Invitation Homes. “We’re thrilled that this strategic relationship with PulteGroup further strengthens that commitment while also enhancing our multichannel acquisition approach to growth.”

We have been evaluating potential structures for participating in the single-family rental market that would seek to capitalize on our strengths in community development and new-home construction while delivering high returns,” said Ryan Marshall, PulteGroup President and CEO. “We are excited to be working with an industry leader in Invitation Homes, and believe this relationship will allow us to increase our scale in our existing markets, make investing in larger land parcels more practical, and generate attractive risk adjusted returns.”

About Invitation Homes

Invitation Homes is the nation’s premier single-family home leasing company, meeting changing lifestyle demands by providing access to high-quality, updated homes with valued features such as close proximity to jobs and access to good schools. The company’s mission, “Together with you, we make a house a home,” reflects its commitment to providing homes where individuals and families can thrive and high-touch service that continuously enhances residents’ living experiences.

About PulteGroup

PulteGroup, Inc. (NYSE: PHM), based in Atlanta, Georgia, is one of America’s largest homebuilding companies with operations in more than 40 markets throughout the country. Through its brand portfolio that includes Centex, Pulte Homes, Del Webb, DiVosta Homes, American West and John Wieland Homes and Neighborhoods, the company is one of the industry’s most versatile homebuilders able to meet the needs of multiple buyer groups and respond to changing consumer demand. PulteGroup’s purpose is building incredible places where people can live their dreams.

For more information about PulteGroup, Inc. and PulteGroup brands, go to pultegroup.com; www.pulte.com; www.centex.com; www.delwebb.com; www.divosta.com; www.jwhomes.com; and www.americanwesthomes.com. Follow PulteGroup, Inc. on Twitter: @PulteGroupNews.

Forward-Looking Statements

This press release contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), which include, but are not limited to, statements related to the Company’s expectations regarding the performance of the Company’s business, its financial results, its liquidity and capital resources, and other non-historical statements. In some cases, you can identify these forward-looking statements by the use of words such as “outlook,” “guidance,” “believes,” “expects,” “potential,” “continues,” “may,” “will,” “should,” “could,” “seeks,” “projects,” “predicts,” “intends,” “plans,” “estimates,” “anticipates,” or the negative version of these words or other comparable words. Such forward-looking statements are subject to various risks and uncertainties, including, among others, risks inherent to the single-family rental industry and the Company’s business model, macroeconomic factors beyond the Company’s control, competition in identifying and acquiring properties, competition in the leasing market for quality residents, increasing property taxes, homeowners’ association (“HOA”) fees, and insurance costs, the Company’s dependence on third parties for key services, risks related to the evaluation of properties, poor resident selection and defaults and non-renewals by the Company’s residents, performance of the Company’s information technology systems, risks related to the Company’s indebtedness, and risks related to the potential negative impact of the ongoing COVID-19 pandemic on the Company’s financial condition, results of operations, cash flows, business, associates, and residents. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Moreover, many of these factors have been heightened as a result of the ongoing and numerous adverse impacts of COVID-19. The Company believes these factors include, but are not limited to, those described under Part I. Item 1A. “Risk Factors” of the Annual Report on Form 10-K for the fiscal year ended December 31, 2020, and in the Company’s Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2021, filed with the Securities and Exchange Commission (the “SEC”), as such factors may be updated from time to time in the Company’s periodic filings with the SEC, which are accessible on the SEC’s website at www.sec.gov. These factors should not be construed as exhaustive and should be read in conjunction with the other cautionary statements that are included in this release and in the Company’s other periodic filings. The forward-looking statements speak only as of the date of this press release, and the Company expressly disclaims any obligation or undertaking to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise, except to the extent otherwise required by law.

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Child Tax Credit Payments Have Begun. Should You Opt Out?

“The advance of the credit reduces the total amount of taxes paid,” said Rob Seltzer, an accountant in Los Angeles. “So there could be a problem with an estimated tax penalty,” depending on how much the taxpayer earns this year compared with last. It may make sense to run a tax projection with a professional to see if it makes sense to opt out.

You need to live in the United States for more than half of 2021 to be eligible for the advanced payments, but expatriate taxpayers can still claim the expanded credit on their return, according to the I.R.S. (The refundable portion of the credit, however, will be curtailed to the prior $1,400 limit.) Military members stationed abroad are still eligible for the advanced payments.

Some households are simply accustomed to getting a large refund when they file, using it as a forced savings plan. If you have come to depend on a big refund, you can opt out of all future payments and receive the full value of the credit when you file your return next year.

“Opting out or making changes to the payment comes down to personal preference of when and how you want to receive the money,” said Andy Phillips, the director of the Tax Institute at H&R Block. “If you prefer monthly payments of smaller amounts, no need to make changes.”

Sheila Taylor-Clark, a certified public accountant and secretary of the National Society of Black C.P.A.s, has practical advice for clients who don’t necessarily want to opt out but who may be uncertain on where they stand: “Drop that money into an interest-bearing account, so if you owe money you can just send that back next April,” she said.

To opt out of receiving the payments, taxpayers should visit the Child Tax Credit Update Portal. If you don’t already have an account, you’ll need to create one. And if you’re married and file a joint return, both spouses will need to create accounts and opt out; spouses who don’t opt out will continue to receive half of the advance monthly payment.

Besides stopping the checks, the portal can be used to check the status of your payments; change the bank account receiving them; or to switch your payments to direct deposit from paper checks.

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How Private Equity Firms Avoid Taxes

There were two weeks left in the Trump administration when the Treasury Department handed down a set of rules governing an obscure corner of the tax code.

Overseen by a senior Treasury official whose previous job involved helping the wealthy avoid taxes, the new regulations represented a major victory for private equity firms. They ensured that executives in the $4.5 trillion industry, whose leaders often measure their yearly pay in eight or nine figures, could avoid paying hundreds of millions in taxes.

The rules were approved on Jan. 5, the day before the riot at the U.S. Capitol. Hardly anyone noticed.

The Trump administration’s farewell gift to the buyout industry was part of a pattern that has spanned Republican and Democratic presidencies and Congresses: Private equity has conquered the American tax system.

one recent estimate, the United States loses $75 billion a year from investors in partnerships failing to report their income accurately — at least some of which would probably be recovered if the I.R.S. conducted more audits. That’s enough to roughly double annual federal spending on education.

It is also a dramatic understatement of the true cost. It doesn’t include the ever-changing array of maneuvers — often skating the edge of the law — that private equity firms have devised to help their managers avoid income taxes on the roughly $120 billion the industry pays its executives each year.

Private equity’s ability to vanquish the I.R.S., Treasury and Congress goes a long way toward explaining the deep inequities in the U.S. tax system. When it comes to bankrolling the federal government, the richest of America’s rich — many of them hailing from the private equity industry — play by an entirely different set of rules than everyone else.

The result is that men like Blackstone Group’s chief executive, Stephen A. Schwarzman, who earned more than $610 million last year, can pay federal taxes at rates similar to the average American.

Lawmakers have periodically tried to force private equity to pay more, and the Biden administration has proposed a series of reforms, including enlarging the I.R.S.’s enforcement budget and closing loopholes. The push for reform gained new momentum after ProPublica’s recent revelation that some of America’s richest men paid little or no federal taxes.

nearly $600 million in campaign contributions over the last decade, has repeatedly derailed past efforts to increase its tax burden.

Taylor Swift’s back music catalog.

The industry makes money in two main ways. Firms typically charge their investors a management fee of 2 percent of their assets. And they keep 20 percent of future profits that their investments generate.

That slice of future profits is known as “carried interest.” The term dates at least to the Renaissance. Italian ship captains were compensated in part with an interest in whatever profits were realized on the cargo they carried.

The I.R.S. has long allowed the industry to treat the money it makes from carried interests as capital gains, rather than as ordinary income.

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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How Long Should It Take to Give Away Millions?

Ms. Madoff and others pushing for change see a growing gap between reputation-burnishing promises of money and distributions to people who need it. The Giving Pledge, which was started by Bill Gates, Melinda French Gates and their friend and collaborator Warren E. Buffett, gave billionaires a space where they could announce their intention to give away half their fortunes or more, often to great acclaim. But it provides no mechanism to monitor or ensure the giving actually happens.

Earlier this year, the Chronicle of Philanthropy ranked Jeffrey P. Bezos, the founder of Amazon, as the top philanthropist of 2020 because he committed $10 billion to his Bezos Earth Fund to fight climate change. But he had handed out less than one-tenth of that, $791 million, to working nonprofits like the Environmental Defense Fund and Natural Resources Defense Council.

Charitable giving has remained relatively steady for decades, clocking in at roughly 2 percent of disposable income per year, give or take a few tenths of a percent. In 1991, the year that Fidelity began to offer donor-advised funds, just 5 percent of giving went to foundations and DAFs. By 2019, the most recent year available, that figure had risen to 28 percent.

It was January 2020 when that small group gathered at the offices of the nonprofit consulting firm the Bridgespan Group in Manhattan for a wonky brainstorming session about the state of philanthropy. The group included foundation leaders, former congressional staff members, former senior Internal Revenue Service officials and a key constituency in any effort to change how billionaires give away their money: billionaires.

One of the organizers was John D. Arnold. Once a trader at Enron, the Houston energy company that infamously collapsed in 2001, Mr. Arnold later ran his own hedge fund, which made him one of the youngest billionaires in the United States.

Ms. Madoff, another leader of the initiative, has written a book, “Immortality and the Law,” about the growing legal power of dead people in America and has applied her knowledge of estate taxes and inheritance law to the rising field of philanthropy.

The group focused on the fact that most of the laws governing philanthropy were half a century old, dating back to 1969.

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Global Tax Deal Reached Among G7 Nations

LONDON — The top economic officials from the world’s advanced economies reached a breakthrough on Saturday in their yearslong efforts to overhaul international tax laws, unveiling a broad agreement that aims to stop large multinational companies from seeking out tax havens and force them to pay more of their income to governments.

Finance leaders from the Group of 7 countries agreed to back a new global minimum tax rate of at least 15 percent that companies would have to pay regardless of where they locate their headquarters.

The agreement would also impose an additional tax on some of the largest multinational companies, potentially forcing technology giants like Amazon, Facebook and Google as well as other big global businesses to pay taxes to countries based on where their goods or services are sold, regardless of whether they have a physical presence in that nation.

Officials described the pact as a historic agreement that could reshape global commerce and solidify public finances that have been eroded after more than a year of combating the coronavirus pandemic. The deal comes after several years of fraught negotiations and, if enacted, would reverse a race to the bottom on international tax rates. It would also put to rest a fight between the United States and Europe over how to tax big technology companies.

has been particularly eager to reach an agreement because a global minimum tax is closely tied to its plans to raise the corporate tax rate in the United States to 28 percent from 21 percent to help pay for the president’s infrastructure proposal.

EU Tax Observatory estimated that a 15 percent minimum tax would yield an additional 48 billion euros, or $58 billion, a year. The Biden administration projected in its budget last month that the new global minimum tax system could help bring in $500 billion in tax revenue over a decade to the United States.

The plan could face resistance from large corporations and the world’s biggest companies were absorbing the development on Saturday.

“We strongly support the work being done to update international tax rules,” said José Castañeda, a Google spokesman. “We hope countries continue to work together to ensure a balanced and durable agreement will be finalized soon.”

said this month that it was prepared to move forward with tariffs on about $2.1 billion worth of goods from Austria, Britain, India, Italy, Spain and Turkey in retaliation for their digital taxes. However, it is keeping them on hold while the tax negotiations unfold.

Finishing such a large agreement by the end of the year could be overly optimistic given the number of moving parts and countries involved.

“A detailed agreement on something of this complexity in a few months would just be lighting speed,” said Nathan Sheets, a former Treasury Department under secretary for international affairs in the Obama administration.

The biggest obstacle to getting a deal finished could come from the United States. The Biden administration must win approval from a narrowly divided Congress to make changes to the tax code and Republicans have shown resistance to Mr. Biden’s plans. American businesses will bear the brunt of the new taxes and Republican lawmakers have argued that the White House is ceding tax authority to foreign countries.

Representative Kevin Brady of Texas, the top Republican on the House Ways and Means Committee, said on Friday that he did not believe that a 15 percent global minimum tax would curb offshoring.

“If the American corporate tax rate is 28 percent, and the global tax rate is merely half of that, you can guarantee we’ll see a second wave of U.S. investment research manufacturing hit overseas, that’s not what we want,” Mr. Brady said.

At the news conference, Ms. Yellen noted that top Democrats in the House and Senate had expressed support for the tax changes that the Biden administration was trying to make.

“We will work with Congress,” she said.

Liz Alderman contributed reporting from Paris.

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Tasked to Fight Climate Change, a Secretive U.N. Agency Does the Opposite

LONDON — During a contentious meeting over proposed climate regulations last fall, a Saudi diplomat to the obscure but powerful International Maritime Organization switched on his microphone to make an angry complaint: One of his colleagues was revealing the proceedings on Twitter as they happened.

It was a breach of the secrecy at the heart of the I.M.O., a clubby United Nations agency on the banks of the Thames that regulates international shipping and is charged with reducing emissions in an industry that burns an oil so thick it might otherwise be turned into asphalt. Shipping produces as much carbon dioxide as all of America’s coal plants combined.

Internal documents, recordings and dozens of interviews reveal what has gone on for years behind closed doors: The organization has repeatedly delayed and watered down climate regulations, even as emissions from commercial shipping continue to rise, a trend that threatens to undermine the goals of the 2016 Paris climate accord.

One reason for the lack of progress is that the I.M.O. is a regulatory body that is run in concert with the industry it regulates. Shipbuilders, oil companies, miners, chemical manufacturers and others with huge financial stakes in commercial shipping are among the delegates appointed by many member nations. They sometimes even speak on behalf of governments, knowing that public records are sparse, and that even when the organization allows journalists into its meetings, it typically prohibits them from quoting people by name.

Homes are washing away. Much of the nation could become unlivable in the coming decade.

was almost denied a seat. International Registries, which represented the Marshall Islands on the I.M.O., initially refused to yield to the foreign minister, Mr. Woodroofe recalled.

United Nations climate meetings, countries are typically represented by senior politicians and delegations of government officials. At the maritime organization’s environmental committee, however, one in four delegates comes from industry, according to separate analyses by The New York Times and the nonprofit group Influence Map.

Representatives of the Brazilian mining company Vale, one of the industry’s heaviest carbon polluters and a major sea-based exporter, sit as government advisers. So does the French oil giant Total, along with many shipowner associations. These arrangements allow companies to influence policy and speak on behalf of governments.

Connections can be hard to spot. Luiz Gylvan Meira Filho sat on the Brazilian delegation in 2017 and 2018 as a University of Sao Paulo scientist. But he also worked at a Vale-funded research organization and, during his second year, was a paid Vale consultant. In an interview, he described his role as mutually beneficial: Brazilian officials relied on his expertise, and Vale covered his costs.

“Sometimes you cannot tell the difference. Is this actually the position of a nation or the position of the industry?” said David Paul, a Marshallese senator who attended an I.M.O. meeting in 2018.

Hundreds of other industry representatives are accredited observers and can speak at meetings. Their numbers far exceed those of the approved environmental groups. The agency rejected an accreditation request by the Environmental Defense Fund in 2018.

Industry officials and the maritime organization say such arrangements give a voice to the experts. “If you don’t involve the people who are actually going to have to deliver, then you’re going to get a poor outcome,” said Guy Platten, secretary general of the International Chamber of Shipping.

openly opposed strict emissions regulation as a hindrance to economic growth. And an informal bloc of countries and industry groups helped drag out the goal-setting process for three years.

Documents show that China, Brazil and India, in particular, threw up repeated roadblocks: In 2015, it was too soon to consider a strategy. In 2016, it was premature to discuss setting targets. In 2017, they lacked the data to discuss long-term goals.

a Cook Islands diplomat.

The I.M.O. almost never puts environmental policies to a vote, favoring instead an informal consensus-building. That effectively gives vocal opponents blocking power, and even some of the agency’s defenders acknowledge that it favors minimally acceptable steps over decisive action.

So, when delegates finally set goals in 2018, Mr. de Brum’s ambition had been whittled away.

The Marshall Islands suggested a target of zero emissions “by the second half of the century” — meaning by 2050. Industry representatives offered a slightly different goal: Decarbonization should occur “within” the second half of the century, a one-word difference that amounted to a 50-year extension.

Soon, though, the delegates agreed, without a vote, to eliminate zero-emissions targets entirely.

What remained were two key goals:

First, the industry would try to improve fuel efficiency by at least 40 percent. This was largely a mirage. The target was set so low that, by some calculations, it was reached nearly the moment it was announced.

Second, the agency aimed to cut emissions at least in half by 2050. But even this watered-down goal is proving unreachable. The agency’s own data say emissions may rise by 30 percent.

When delegates met last October — five years after Mr. de Brum’s speech — the organization had not taken any action. Proposals like speed limits had been debated and rejected.

What remained was what several delegates called the “refrigerator rating” — a score that, like those on American appliances, identified the clean and dirty ships.

European delegates insisted that, for the system to work, low-scoring ships must eventually be prohibited from sailing.

China and its allies wanted no such consequence.

So Sveinung Oftedal of Norway, the group’s chairman, told France and China to meet separately and compromise.

Delegates worked across time zones, meeting over teleconferences because of the Covid-19 pandemic. Shipping industry officials said they weighed in through the night.

The Marshallese were locked out.

“We’re always being told ‘We hear you,’” Mr. Ishoda said. “But when it comes to the details of the conversation, we’re told ‘We don’t need you to contribute.’”

Ultimately, France ceded to nearly all of China’s requests, records show. The dirtiest ships would not be grounded. Shipowners would file plans saying they intended to improve, would not be required to actually improve.

German delegates were so upset that they threatened to oppose the deal, likely triggering a cascade of defections, according to three people involved in the talks. But European Union officials rallied countries behind the compromise, arguing that Europe could not be seen as standing in the way of even limited progress.

“At I.M.O., that is as always the choice,” said Damien Chevallier, the French negotiator. “We have the choice to have nothing, or just to have a first step.”

All of this happened in secret. The I.M.O.’s summary of the meeting called it a “major step forward.” Natasha Brown, a spokeswoman, said it would empower customers and advocacy groups. “We know from consumer goods that the rating system works,” she said.

But the regulation includes another caveat: The I.M.O. will not publish the scores, letting shipping companies decide whether to say how dirty their ships are.

Ms. Kabua, the Marshallese minister, is under no illusions that reclaiming the diplomatic seat will lead to a climate breakthrough.

But if it works, she said, it might inspire other countries with private registries to do the same. Countries could speak for themselves rather than through a corporate filter.

Regardless of the outcome, the political winds are shifting. The European Union is moving to include shipping in its emissions-trading system. The United States, after years of being minor players at the agency, is re-engaging under President Biden and recently suggested it may tackle shipping emissions itself.

Both would be huge blows to the I.M.O., which has long insisted that it alone regulate shipping.

Suddenly, industry officials say they are eager to consider things like fuel taxes or carbon.

“There’s much more of a sense of momentum and crisis,” said Mr. Platten, the industry representative. “You can argue about, ‘Are we late to it,’ and all the rest. But it is palpable.”

Behind closed doors, though, resistance remains. At a climate meeting last winter, recordings show that the mere suggestion that shipping should become sustainable sparked an angry response.

“Such statements show a lack of respect for the industry,” said Kostas G. Gkonis, the director of the trade group Intercargo.

And just last week, delegates met in secret to debate what should constitute a passing grade under the new rating system. Under pressure from China, Brazil and others, the delegates set the bar so low that emissions can continue to rise — at roughly the same pace as if there had been no regulation at all.

Delegates agreed to revisit the issue in five years.

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