#KisanKraft

[dontmeantobepoliticalbut]

Supreme Court upholds repatriation provision in sweeping 2017 tax law | The Hill

The Supreme Court in a 7-2 decision Thursday upheld a provision in then-President Trump’s sweeping 2017 tax bill while sidestepping a far-reaching question about Congress’s broader taxing authority.

The high court avoided weighing in on what constitutes “income” that the federal government can tax under the 16th Amendment, which has implications for large swaths of the U.S. tax code and could also foreclose the possibility of a wealth tax.

Justice Brett Kavanaugh, writing for the majority, did not delve into whether the 16th Amendment imposes a realization requirement. Instead, he resolved a couple’s challenge to the law’s mandatory repatriation tax on narrow grounds.

“So the precise and narrow question that the Court addresses today is whether Congress may attribute an entity’s realized and undistributed income to the entity’s shareholders or partners, and then tax the shareholders or partners on their portions of that income,” Kavanaugh wrote.

“This Court’s longstanding precedents, reflected in and reinforced by Congress’s longstanding practice, establish that the answer is yes.”

Kavanaugh’s opinion was joined by Chief Justice John Roberts and the court’s three liberals.

Though the majority sidestepped the broader constitutional question, the four other conservative justices did address it, all expressing that they believe the 16th Amendment does impose a realization requirement.

“The Moores are correct. Sixteenth Amendment ‘incomes’ include only income realized by the taxpayer,” Justice Clarence Thomas dissented, joined by Justice Neil Gorsuch.

Justice Amy Coney Barrett, joined by Justice Samuel Alito, agreed with their two fellow conservatives, rejecting the government’s argument that the amendment authorizes Congress to tax unrealized income without apportionment among the states.

“The answer is straightforward: No,” Barrett wrote.

But Barrett and Alito still voted to uphold the tax alongside the majority, writing that the couple had not met their burden after conceding a key point during oral arguments.

Justice Ketanji Brown Jackson, who joined the majority in upholding the tax, wrote separately to cast doubts about a realization requirement.

“I have no doubt that future Congresses will pass, and future Presidents will sign, taxes that outrage one group or another—taxes that strike some as demanding too much, others as asking too little. There may even be impositions that, as a matter of policy, all can agree are wrongheaded,” Jackson wrote.

“However, Pollock teaches us that this Court’s role in such disputes should be limited,” she added, referring to a key precedent implicated in the case.

Charles and Kathleen Moore brought their challenge to the Supreme Court after paying roughly $15,000 in taxes under the provision in Republicans’ 2017 law.

The mandatory repatriation tax imposed a one-time tax on Americans who owned shares in foreign corporations, even if the corporation hadn’t distributed any earnings to the taxpayer.

The Moores had invested in KisanKraft, an Indian company that sells farm equipment. But the couple claimed they never received any distributions or payments from the company, meaning they did not realize any income the federal government was authorized to tax.

Under the 16th Amendment, Congress can levy taxes “on incomes, from whatever source derived.” Otherwise, all other direct taxes must be apportioned among the states.

The Supreme Court’s decision leaves unresolved whether income must be realized for it to fall under the Amendment’s carveout.

Instead, the justices sided against the Moores by finding the income in their situation was realized. KisanKraft realized the income, the court ruled, and Congress fairly attributed the income to the couple.

Alito previously rejected calls to recuse from the case after he sat down for two interviews with an attorney who represents the couple.

[justinspoliticalcorner]

Lauren Aratani at The Guardian:

The US supreme court on Thursday ruled against a Washington couple who argued they were unconstitutionally taxed $15,000 for their investment in a foreign company – in a case some have argued was a backdoor attempt to ban future wealth taxes. The case, Moore v US, put into question what assets are considered taxable income. Some experts say the case was used as a vehicle to give the supreme court an opportunity to weigh in on a hypothetical billionaire’s tax, which would raise similar questions on what assets can be taxed. As the court was hearing the case in December, experts were worried that it put into question the long-established tax code, threatening to wreak havoc on what Americans may be taxed for. The vote was 7-2 with Justice Clarence Thomas and Justice Neil Gorsuch dissenting. In his opinion, Justice Brett Kavanaugh described the ruling as “narrow”, leaving an opening for future challenges.

Senator Elizabeth Warren hailed the ruling. “Right-wing billionaires hoped an obscure legal case would blow up the tax code to avoid paying what they owe, but this effort failed at the supreme court. The fight goes on to tax the rich, pass a wealth tax on ultra-millionaires and billionaires, and make the system more fair,” she wrote on X. The case focused on Charles and Kathleen Moore, a couple from Washington state who owned a small stake in an India-based company that sells affordable farm equipment in India. Charles Moore met one of the future founders of the company, KisanKraft, when he was a software engineer at Microsoft. The Moores invested $40,000 into the company, which gave them an 11% stake. In 2017, as part of a way to fund Donald Trump’s tax giveaway to US corporations, Americans who owned at least 10% of a foreign company were charged a one-time Mandatory Repatriation Tax (MRT) on their holding, regardless of whether the investment remained in the company, whereas such investments were previously exempt. Total tax revenue raised by the MRT is estimated to be $340bn.

SCOTUS issued a 7-2 (or 5-2-2) ruling in Moore v. United States dealing with the Mandatory Repatriation Tax in which Justice Brett Kavanaugh issued the ruling that rejected bans on wealth taxes.

See Also:

HuffPost: Supreme Court Turns Back Stealth Attack On Wealth Tax — For Now

[xlntwtch2]

from this AP News article (10/15/23)

"...The Moores are the latest example of plaintiffs whose lawsuits seem to simply be exercising their legal rights, but whose cases are backed by others with enormous amounts of money or a consequential social issue at stake. The Moores sought help from the anti-regulatory Competitive Enterprise Institute....

"...“The story the Moores told about Charles’ involvement with KisanKraft is directly at odds with the fiduciary responsibilities of an individual holding a board seat for an Indian company,” Mindy Herzfeld, director of the masters program in international tax at the University of Florida law school, wrote in Tax Notes.

And there are other indications of Moore’s more extensive involvement with KisanKraft than his testimony indicated. The company paid for his travel to India four times and he made at least two investments beyond the $40,000 stake he put up in 2006.

Moore also was prepared to invest an another roughly $250,000. That money was ultimately returned by KisanKraft, along with 12% interest....

"The omissions, along with the Moores’ failure to take advantage of other legal options that would have deferred, if not eliminated, their tax liability make Avi-Yonah and other experts in international tax law suspect the case was manufactured to get at a larger issue, the tax on billionaires that has been proposed by some prominent Democrats but never enacted.

A wealth tax would apply not to the incomes of the very richest Americans, but their assets, like stock holdings, that now only get taxed when they are sold.

“There really was no reason for the court to take it on, other than to send a signal to warn off the Congress from passing a billionaire tax,” said Steven Rosenthal, a senior fellow at the Urban-Brookings Tax Policy Center."

[firesafetytoolssupplier]

Garden Hose Distributor supplier in India

Garden Hose Distributor Supplier in India

India's agricultural sector, landscaping businesses, and gardening enthusiasts have created a substantial demand for high-quality garden hoses. As a result, the market for garden hose distributor suppliers in India has grown significantly. These suppliers play a crucial role in ensuring the availability of a variety of garden hoses tailored to different needs, from small urban gardens to large agricultural fields.

This article explores the landscape of garden hose distribution in India, highlighting key players, product varieties, quality standards, and the factors influencing this dynamic market. The increasing awareness about the importance of gardening and landscaping has led to a surge in the demand for garden hoses in India. Urbanization has spurred the growth of residential gardens and green spaces, while the agricultural sector continues to rely heavily on efficient irrigation systems.

Garden hoses are essential tools in these settings, making reliable distributors and suppliers critical to meeting this demand. Some of the leading names in this industry include:

Eagle Plant Garden Tools: Known for their extensive range of garden hoses, Eagle Plant Garden Tools has established a strong presence in the market. Their products are recognized for durability, flexibility, and resistance to weather conditions.

KisanKraft: A major player in the agricultural tools and equipment sector, KisanKraft supplies high-quality garden hoses designed for both domestic and agricultural use. Their products are popular for their longevity and efficiency.

AJ Enterprises: This company specializes in manufacturing and distributing a variety of garden hoses, including PVC, rubber, and expandable hoses. AJ Enterprises is noted for its innovative products and customer-centric approach. A Garden Hoses Distributor & Suppliers in India typically refers to a business or company involved in the wholesale distribution and supply of garden hoses to retailers, hardware stores, garden centers, and other businesses or individuals. These hoses are crucial for various outdoor activities, such as watering plants, gardening, washing cars, and general outdoor cleaning. MANX IMPEX sources its products from reputable manufacturers, ensuring durability, flexibility, and resistance to common wear and tear. The hoses are designed to withstand varying weather conditions, making them ideal for year-round outdoor use. Conclusion; The garden hose distributor market in India is thriving, driven by the increasing demand for efficient irrigation solutions in both agricultural and urban settings. Key players in the industry are focusing on quality, durability, and innovation to meet the diverse needs of their customers. As awareness about sustainable gardening and efficient water usage grows, the market is poised for further expansion, offering significant opportunities for distributors and suppliers.

website:-

call us:- +91-7428115550

Email-info@manximpex.com

[rajagro]

Unlock the Power of Modern Farming Tools: Your Premier Destination for Agricultural and Garden Solutions! We will explore the various agricultural tools available at RajAgro Udaipur, provide essential tips for buying them online, share insights into the outstanding purchase experience, and introduce you to the top brands like Sharpex, Falcon, Maxgreen, MTD Wolf Garten, Concorde, Aspee, Masand, Baaz, Golf King, KisanKraft, Stihl and many more for best Lawn Mowers, Agri Machinery, Garden Implements, Garden Tools, Sprayers & Sprinklers.

[etemysore]

Engineering Tools & Equipment offers you best price on kisankraft Intercultivators - Diesel KK-IC-300D.

For more details please visit our website-

https://engg-tools.com/agricultural-equipment_24/intercultivators-diesel-kk-ic-300d_113?isId=true

[kisankraftsblog]

Kisankraft providing pressure washer manufacturer and supplier in India.

[krishitoolindia]

Book Now: https://www.krishitool.in/product_details/Wheel_Type_Earth_Auger_Machine,_82cc_AirCool_Engine_With_3_Auger_Bit

earth auger, earth auger machine, wheel earth auger, wheel earth auger 12 inch bit, Trolley Type Earth Auger, earth auger machine, honda earth auger price india, 24 inch earth auger, 12 inch earth auger manual, 12 inch earth auger machine price, auger, earth auger attachment, really earth auger, earth auger heavy duty, earth auger 4 stroke, Trolley Type Earth Auger, Trolley Mounted Earth Auger, Earth Auger With Stand, Trolley Earth Auger, hydraulic auger, towable hydraulic auger, towable auger, hydraulic post hole auger, hydraulic hole digger, hydraulic earth auger, earth auger trolley, hydraulic post hole digger price, earth auger with trolley, one man hydraulic post hole digger, trolley type earth auger machine, best hydraulic post hole digger, one man hydraulic auger, earth auger stand, Hand Push Earth Auger Machine, Hand Push Type Earth Auger, Earth Auger Automatic,Earth Auger-Trolley Mounted, WHEEL Earth Auger, Trolley Type Earth Auger Machine, 12 inch earth auger machine price, 12 inch earth auger bit, Earth Auger, Auger Digger, Post Hole Diggers, Hole Digger, post hole auger, post digger, post hole, hole digger tool, earth auger bit, earth drill, soil digger, earth auger drill bit, stihl earth auger, earth auger drill, Petrol Earth Auger, soil drilling machine, Honda Auger, honda earth auger price india, kisankraft earth auger, hand earth auger, earth auger heavy duty, earth auger bit, earth auger price in india, 12 inch earth auger, post hole digger machine, post hole digger price, hole digger machine price

[pkstudiosindia]

KisanKraft KK-MSP-6100 Water Can

KisanKraft KK-MSP-6100 Water Can Trending Now:waterfilterindia.com Products on more than 50% Discount Price offer:Get yours from https://waterfilterindia.com Exclusive Offer Ending Soon.......Learn more from This Link https://waterfilterindia.com/kisankraft-kk-msp-6100-water-can/ Trending Now: WaterFilterIndia.com ...................Products on more than 50% Discount Price offer.....................:Get yours from https://waterfilterindia.com/shop ............Exclusive Offer Ending Soon.......................WaterFilterIndia.com..............Our Fast Moving Products on Discount Sale Offer................#WaterFilter ..........#WaterPurifier ...........#Filter .......... #Kitchen .........#HomeAppliance .............#WashingMachineHose .............#WaterFilterSpareParts #BathFilter ...............#Antiscalant ...............#ROMembrane #ROPump ............ #BoosterPump ..................#WaterFilterValve #WashingMachineTapAdapter .............#KitchenSinkFilter #FootValveFilter ...............#DripIrrigationParts.......#DripIrrigationHose........#Aquarium....#PetFood......#Garden....#Garden Hose.......#ROSpanner #ROWaterFilterService #ROParts ............#WaterFilterPowerAdapter ..............#Valve ..................#ROFilter #CarbonFilter ......................#WaterPurifierCover...........................Limited Time Sale Offer................Visit - https://waterfilterindia.com/shop

[krishitool2021]

Brush Cutter Machine | paddy cutter in India - Krishitool.com Book Now :  https://www.krishitool.com/products.php?id=5 Buy brush cutter machine/grass cutter online at lowest price in India. Shop rice cutting & paddy cutting, 4/2 stroke honda gx35 brush cutter machines Crop Cutter 4 Stroke  Price Online at Krishitool.com. ✓ Wholesale Price ✓ COD.

[kisankraft22]

[kisankraft24]

Kisankraft offers a wide, moderate scope of ISI affirmed scope of profoundly effective, energy-saving, lightweight, and reduced water pump with an effectively viable plan that is needed in water system (Agriculture, cultivation, sprinkler, and trickle water system), Domestic and local area water supply in condos, structures, lodgings, including tall structures and in handling businesses.

[kamal0303-blog]

#Kisankraft Cold #Fogger ULV Ultra Low Volume Sprayer

[datoolsvilla]

Buy Electric Chainsaws - Petrol Chainsaws Machine at Offer Prices

Buy best chainsaws online at wholesale pricing. Get exclusive offers on electric & petrol chainsaws with free shipping & COD options only at Toolsvilla. Get chainsaws from brands like Kisankraft, Makita, Husqvarna, STIHL, Oregon, etc.

[kisankraftsblog]

Kisankraft providing best products for reasonable price in India. Electric motor are used to run the machine.