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Archive Monthly Archives: March 2018

Miss Malini's Malini Agarwal on blogging her way to B-town – The Telegraph India


The Telegraph India

Miss Malini's Malini Agarwal on blogging her way to B-town
The Telegraph India
I joined the first dot com boom and I decided one day that I wanted to make my life extraordinary and didn't think Delhi was where that would happen. I decided to move to Mumbai as I had a friend there. So like they say, I took two suitcases, big

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Friday Cat Blogging – 30 March 2018 – Mother Jones


Mother Jones

Friday Cat Blogging – 30 March 2018
Mother Jones
When I got my new camera I downloaded Sony's imaging software, which supports RAW images. So I went out and snapped a few pictures of the cats in RAW mode and then went inside to play around with them. I don't remember what I did to this one. It couldn

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Joan Crawford’s grandson says he’ll be rooting for ‘Feud’ on Emmys night

If there’s one person Casey LaLonde will be rooting for at the Emmys Sunday night, it’s actress Jessica Lange, whose nominated for her portrayal of his grandmother Joan Crawford in “Feud.”

Ryan Murphy’s FX show tells the story of the movie star’s collaboration with Hollywood rival Bette Davis in the highly publicized 1962 film “What Ever Happened to Baby Jane?” It was nominated for 18 awards. Both Lange and Susan Sarandon, who played Davis, are nominated for Outstanding Lead Actress in a Limited Series or Movie.

LaLonde, who was contacted by Murphy’s production company last fall for his insight on Crawford, gave Lange some footage from his grandmother’s home movie collection shot in the late ‘50s to give the 68-year-old a close look at the woman behind the legend. LaLonde and his mother Cathy, one of a pair of twins adopted by Crawford in 1947, were depicted on the show’s final episode.

WHY DID JOAN CRAWFORD AND BETTE DAVIS ‘FEUD’?

“I truly enjoyed the entire series Ryan Murphy produced,” LaLonde told Fox News. “It was a very critical, adult, non-campy look at the history of Joan and Bette Davis… And of course, just because of who my grandmother was, I will root for Jessica Lange to win… Nothing against Susan Sarandon. She’s a wonderful actress. But for personal reasons, I’ll be rooting for Jessica on Emmy night for sure.”

Even though Crawford passed away in 1977 at age 71 when LaLonde was 6-years-old, he still has vivid memories of his grandmother, an actress who starred in more than 80 films since 1925.

“We’d go to to New York City, she would greet us at her apartment door [and] she would be in a housecoat,” he recalled. “But of course, I was never allowed to call her grandma because she was Joan Crawford. So our nickname for her was JoJo… She was loving, supportive. She was intently interested in what I was doing, even me as a 5-year-old. And wanting to just be a grandmother. She was always there. She was always present and focused on us whenever we would visit.”

LaLonde, who lived two hours outside of New York City, said Crawford enjoyed babysitting whenever his parents would drop him off at her Upper East Side apartment.

“She would feed us lunch, she played with us, she hung out with us,” said LaLonde. “And at that age I didn’t know who she was, except she was just my grandmother. I vividly recall being in her apartment, her plastic-covered furniture, her parquet floors… I was a little kid in the big city, so I was completely excited to be there.”

LaLonde revealed that while Crawford stayed in touched with loved ones, she rarely stepped outside during the final years of her life. Her last public appearance was in September 1974 in New York when she hosted a party for fellow actress Rosalind Russell. When a photo of the 69-year-old appeared in the papers the following day, LaLonde said Crawford declared, “If that’s the way I look, they won’t see me anymore.”

“She didn’t feel she looked like Joan Crawford anymore,” LaLonde added. “She started to retreat and never went out in public again… [But] she had good friends over… She’s famous for writing over a million-plus fan letters in her life. She still sent photographs to friends and fans. She kept in excellent correspondence with everyone.”

LaLonde recalled when something changed with “JoJo.”

“… On her death certificate it said heart attack, but she had pancreatic cancer,” he said. “I don’t know where she was diagnosed or when, but as time when on, even in my childhood eyes, she started to get thinner. She would wear a wig when we’d see her. She still had makeup on, but it wasn’t overdone. It was very natural.”

Despite newfound interest on Crawford’s career, LaLonde was concerned how “Feud” would address “Mommie Dearest,” the shocking 1978 tell-all written by her eldest adopted daughter Christina, which depicted her as an abusive alcoholic prone to rage.

In 1981 the story, which was published shortly after Crawford’s death, was then turned into a film starring Faye Dunaway. LaLonde’s mother and her twin refuted all of Christina’s claims but their adopted brother Christopher stood by them until his death in 2006 at age 62.

“I don’t think any reconciliation could ever happen because of the impact ‘Mommie Dearest’ had as a book and a movie on the overall family from Christina’s perspective,” said LaLonde, who has never met his aunt. “I think once the book came out, we were already headed downhill. Once the movie came out, it was over. I don’t think there’s any room for reconciliation.”

He added the last time his mother ever saw Christina was when Crawford’s will was read after her death. Crawford famously omitted both Christina and her adopted son Christopher “for reasons well known to them.”

In 2008, Vanity Fair reported a dying Crawford may have believed Christina was gearing up to publish a slanderous memoir “full of lies and twisted truths” to make money. Consequently, Christina and Christopher were disinherited.

But these days, LaLonde is determined to revamp Crawford’s legacy in Hollywood, which has become forever linked with “Mommie Dearest.” This year, he reissued her 1962 autobiography, as well as a 1971 lifestyle guide titled “My Way of Life.” The audiobook for that self-help book is actually Crawford reading her own words.

“In 1973, a couple of years after the book was published, she did a recording of herself reading it,” he explained. “It was pressed on vinyl. We located what we believe is the only copy in the world, bought it, and had it digitized. So it’s Joan herself reading the entire copy with extra comments peppered throughout.”

New fans will even learn some fun facts about Crawford in “My Way of Life,” which was previously out of print for decades. It’s one of many things LaLonde enjoys sharing about his grandmother.

“Joan kept a tiny refrigerator next to the bed for [husband] Al Steele, where she’d feed him cheese, pepperoni, salami, and Pepsi Cola,” he chuckled.

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Live-streaming app Spotlite raises $10 million from Sequoia Capital China to help singers make money

Described to me as “American Idol meets musical.ly,” startup Spotlite recently raised more than $10 million from Sequoia Capital China and BlueRun Ventures. The plan is to use the funding to build out the product, make key hires and expand its marketing and advertising efforts.

Spotlite is a direct-to-fan music platform for artists who want to make money and have direct access to their fans, Spotlite founders Ke Tang and Jason Ma told TechCrunch. The app combines video, live streaming, messaging technology and gifting to establish a business model that enables aspiring artists to make money.

Through Spotlite’s partnerships with publishers like Sony/ATV and Universal Music Group, Spotlite’s users get access to a variety of songs to perform covers to. Listeners can then gift virtual coins, which are redeemable for real money, to their favorite artists. As a listener, for example, I can buy coins from Spotlite, with $5.99 getting me 599 coins. On the artist side, I can convert my diamonds into cash, with a daily maximum cash out amount of $500. Spotlite has different tiers of revenue-shares with publishers.

“Currently our focus is increasing users and perfecting the product,” Spotlite VP of Marketing and Content Gina Juliano said. “We expect to generate income via different model,s including virtual gifting, memberships and advertising sponsorships, etc.”

The gifting model, the team says, is successful in Asia. It’s true. Last year, China’s live-streaming market grew 180 percent year over year to hit $3 billion in revenues, according to iResearch. With Spotlite, the idea is to “create a new gifting model that may fit different countries,” Ke said.

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Spotlite also hosts contests for people to make money. Right now, there’s a contest around singing your own original song. The prize is $1,000 or more. Spotlite allocates part of its revenue on contests to offer cash rewards to the winners. The winners also receive cash gifts from listeners.

“Many talents such as Adrian Ammsso, Saahas Patil, Charly, Kuhleeuh, Buddhi De Mal, DivaGiga Huerta, Kat McDowell, AmarioT, Mau Jimenez have come to Spotlite to join the contests and some have made thousands of dollars on a monthly basis,” Ma said.

Spotlite seems to most directly compete with Smule, which has raised more than $100 million and, as of May, has 52 million monthly active users. A key difference, however, is that artists on Smule can’t make money.

Spotlite, which launched just a couple of months ago on both iOS and Android, currently has 250,000 active users. In the next 12 months, the plan is to expand into the Latin American and Asian markets. The app currently sits at No. 32 on the Apple App Store’s top free music apps chart.

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Bachelor In Paradise’s Attempt To Address The Controversy Just Caused More Controversy

The illustrious members of Bachelor Nation have spent most of the summer being pretty fricking P.O.’d, thinking our absolute favorite summer series was dunzo. I mean, we were like, concerned about the seriousness of the allegations and shit, but we also definitely wanted to see our favorite cast members who failed to find love have sex with each other on the beach. Fortunately for us, the producers have literally no shame, and all the DeMario and Corinne drama did nothing to diminish their desire to make money off of our guiltiest pleasure.

Now, the teaser for the season that almost never happened is out, and, TBH, I hate saying it, but it actually looks kind of lame. Part of why we were all so excited about BiP this season was because Corrine was going to be on it. Now that’s not happening. Chad is busy with for some reason. DeMario is also out, so, like who is even going to bring the drama? Amanda? Raven? I don’t think so.

So let’s break this down: The preview starts with a bunch of tweets from Bach fans basically just talking about how devastated they (we) were the show was maybe almost sort of not going to happen when allegations of sexual misconduct started swirling.

Of course when a show called “Bachelor in Paradise” almost gets shut down but then totally doesn’t, you have to throw in a “Paradise Lost” reference. Clever.

We get a few flashes of some of the cast members, including baby-voiced Amanda from Ben’s season and one of Rachel’s more annoying suitors, Iggy. We also see that Kristina is on the show. I almost didn’t recognize her because she has highlights now. She legit looks good and I’m happy she didn’t end up with Nick because she’s already been through too much shit in her life — fuckin Russia, amirite?

Anyway, then we get some more tweets about how happy people are that the show is back on. Then Robby says “It’s crazy” and that’s pretty much it.

Can I just say: booooooooo.

I don’t particularly like that they’re capitalizing on the fact the season almost didn’t happen, ya know, because the reason it almost didn’t happen was because there was a sexual assault investigation. Like, if it almost didn’t happen because of a hurricane or some shit, sure, play that up. IDK I just had a weird feeling about how they approached that whole thing, and critics generally agree. The trailer has been panned by basically everyone, with critics calling it both exploitative and tone deaf. So basically like everything BiP related. Isn’t the first rule of PR like, not to bring up the shitty parts of your brand all the time? IDK.

The show comes out August 14, though and we’ll be watching. Duh. 

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The Seven Deadly Sins of Social Media – The Cipher Brief


The Cipher Brief

The Seven Deadly Sins of Social Media
The Cipher Brief
Social media providers make money when we are easily manipulated. Advertisers will pay more when the public is more malleable. Too many of us spend hours unknowingly fighting bots and trolls in forum and chat rooms. And each fight we have gives

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Should Photographers Have a Blog? | Fstoppers – Fstoppers


Fstoppers

Should Photographers Have a Blog? | Fstoppers
Fstoppers
Blogging has always been a sore spot for photographers. After all, we didn't become photographers to write, but instead, we became photographers to take photos. So why, then, is blogging necessary for a successful photography business?

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And Then I Made My First Million (Only To Lose It Later)

Vitaly

Theres a lot ofdisgustingly bad booksand articles about habits for millionaires. AWFUL.

I wont say the titles. I have a lot of respect for the authors even though they have written useless books.Its hard to write a book.

It takes a year out of your life while you do something totally unnatural for the body: sit in a chair and type buttons on a keyboard to put something on a screen. For 2 million years, primates didnt do that. Now for 50 years we have.

Unnatural.

So.respect.

But the books are awful and dangerous.

A lot of the books are based on research. People who did X, Y, and Z for 50 years ended up with $ABC more money than other people.

I hate research. I admire experience.

Ive made and lost millions several times. I didnt do it just once, which might be luck or it might not be. I can tell you in each case how I went from scratch to millions.

AndIve interviewed hundreds of peoplewho have made and lost millions and gone on to achieve peak performance in their lives.

But Im going to stick to my own story. Specifically: four times I started from $0 and made millions.

MILLION #1

Some of these are habits.Some of these are factors of what was going on in my life.

A) VISION.

I felt that eventually every company would have an Internet website.

I had no business experience at allother than books I had read. When I was a kid I read biographies of many businessmen: Rockefeller, Howard Hughes, Carl Icahn, Andrew Carnegie, and on and on.

But the biographies are just guideposts. You have to experience.
If I had experience I would have done many things differently.

BUT EVEN WITHOUT any experience at all, having a strong vision about the near and long-term future is enough to make a million dollars.

How can you get a vision?

Every daywrite down ten ideasof things you think will happen.

See what feels true inside of you. See what you can learn more about. Ask yourself over and over again why your vision will happen.

How it can be better?

Every day you have to make sure you are not smoking crack on your own vision. I am a crack addict of my own ideas so its important for me to always step outside and make sure I am not breaking bad.

B) COMMUNICATE 24 HOURS A DAY

I told everyone I knew that I thought they needed a website. Small restaurants, big billion dollar companies, artists, stores, writers, friends.

I loved looking at well-done websites. There were only a few dozen websites when I first got on the web. I made my own website and put a short story I wrote on it.

What a mind blowing event it was from me when someone from Sweden reached out to me and said he liked my story. I felt connected to a larger world.

I told the opera they needed a website. I told schools they needed a website. I told every company they needed a website.

Eventually, some people wanted to pay me to do a website. A diamond dealer. Then a shoe company. Then a TV company. Then an electric company.

ThenAmerican Express for $275,000. Then The Matrix for $250,000. And so on.

C) LEARN EVERYTHING

There were no books about the Internet or making websites. It took me a long time to learn the basics.

First there was HTML. Then there was setting up my own web servers. Then learning C++ and how to write networking software. Then there was PERL. Then writing software to manipulate graphics.

There was no WordPress then. If I had been smarter or had more experience then maybe I would have made a WordPress-like site.

Instead, I learned how to make websites by reading the initial code of the first ever web server made by Tim Berners-Lee.

I learned everything about all the subtleties of the protocols. I learned what was inside a gif, I learned how to compress files.

I learned about how to process credit cards inside the code. I learned how to compress videos into unified format. And on and on.

D) PARTICIPATE

I spoke with the few other people out there who knew how to make websites. I got to know every company in our industry.

There were maybe four or five in NYC.

I had lunch with my competitors. Dinner. Id go to their charities. Wed exchange notes. I felt such respect for them because I felt we shared something unique.

When you are in an area with a big enough vision (today: virtual reality, internet of things, genomics, etc), then there is no such thing as competition. The best players will share and do co-opetition.

Id offer to host other companies. Or share the work on clients. When my company was acquired, I acquired the companies of my friends. And so on.

It was always about learning. We were creating something we felt was important. We were creating the commercial world wide web.

I still know these people. 22 years after I first advertised in Jason Calacaniss tiny magazine, The Silicon Alley Reporter, Jason and I are doing a live podcast at Squarespace in a few weeks.

NEVER FORGET its a small world and the best people (your scene) will rise together not as competitors but as peers.

Build your scene.

E) NO RISK

I stayed at my job for EIGHTEEN MONTHS before I left to join my own company full time. We had a dozen employees by then but I did not want to take the risk of relying on my company for my survival.

Else I would panic too much.

I also de-risked by having many clients. And by offering more than just one service. We offered software, design, consulting, marketing, etc.

And we were constantly trying to come up with new ideas to market. We considered making a record label, a tea company, etc.

Millionaires dont take risks. Non-millionaires buy lottery tickets.

Only when I took risks (later on in life) did I lose millions.

F) PROFITS

If I had more business experience I would have raised money, lost money, gotten revenues really fast, productized our service offering, and gone public and made a lot more money (e.g.: Audionet and Mark Cuban).

Smart people who had a deep understanding of market history took all the steps to be much more successful.

I did not have that benefit. I was a failed novelist, grad school dropout, computer programmer. Not a business guy.

So I focused on offering a service where I did work, got paid for it, and every piece of work was profitable.

People tried to invest money in Reset but I was profitable and growing why did I need it?

Nevertheless, this was a special time in market history.

In the real world, the best way to make money is to build a growing profitable business where much of your time is spent on minimizing risk.

G) BE AROUND GOOD PEOPLE

My business partner was my sister. I trusted her and love her.

My employees were all people I truly loved. We got along like a family. 20 years later there are still reunions of my initial employees. Were still like a family.

Whenever we partnered with someone we didnt like, it was too stressful. Wed get rid of that relationship or minimize it. This is so important.

Most people dont realize THIS about business: at least 50% of your time is spent talking about people:

partners, competitors, employees, shareholders, customers , etc.

The other 50% of time on your service.

BUTif you work with bad people, 90% of your time is spent talking about people.

Dont do that.

I) FOLLOW UP

One time we met with JP Morgan, the bank. They loved us.

They loved all of our ideas. Lets get started, they said.

I never followed up. Im bad at that. Its a skill I dont have.

We never closed that deal. We never did that business. Maybe we would have been a lot more valuable.

Another guy, one of my competitors, kept calling me. I never called him back. Finally he ran into me in the street.

I have to tell you a story, he said. I was pitching the CEO of Toys R Us. I wrote him an email and called him. Within two hours he called me. He was on his private plane. He never had spoken to me before. We spoke for an hour and now were doing his website.

His conclusion: Good business people call each other back.

Ugh. I always need to get better at this. Thanks Bill!

J) OVER PROMISE AND OVER DELIVER

Whenever I say this, people criticize me. They say, over promising is lying. Well, for me it isnt.

1. I believe so much in what I am offering that I am happy to over promise to get the deal.
2. I like to set myself a challenge that none of my competitors are willing to set for themselves.
3. I like to over deliver and make the clients happy, even if it means working late nights and struggling for me.

You can only do this if you love what you do. BUT IT WORKS AND IS POWERFUL.

Theover-promise/over-delivererwill always beat the under-promiser or the one who just delivers what they promise.

K) CHEAP

I was always cheaper than my competitors. More important to me was building the relationships.

I always wanted to do cool stuff. If October Films or Miramax wanted a website Id almost offer to do it for free.

I knew that those would be fun for me and my employees, creative, and would be artistic and beautiful enough they would attract higher paying customers like American Express.

Money is a side effect of having a strong vision.

It doesnt mean you always charge the maximum. It means that in the long run, sticking to your vision will make you money.

L) EMPLOYEES HAVE TO BE HAPPY

There are several things I wanted from my employees. And all of these were and still are important to me:

1) I had this dream that all my employees would go home each night and call their moms and say, I cant believe how much fun I had today!

I dont know why I pictured they called their moms and not their dads. But thats the way it is.

2) I wanted all my employees to do their best possible work.

I never wanted to worry about what they did. This involved asking them what they wanted to do and always making sure they had opportunities to use their creativity as much as possible.

People are excited when they do activitiesthat make them feel love in their chest.I wanted to be the match that set each heart on fire.

If I had to think too much about what an employee is doing, then usually they were not a good employee. Or they were not that interested in working with me.

3) Each employee needed to see a path to success.

Employees arent hammers. You pick up a hammer when you need to pound a nail and then you put it down when you are done.

Tools are there just to help you. But with employers and employees, its a two way street.

They are there to help me. But just as much, I am there to help them.

My best employees all ended upstarting their own businesses, or being art professors, or writing books, etc.

My best employees learned at the same time I was learning it, what the pathway to success was.

I ran into one employee 16 years later. He has over 200 employees now at his business.

He told me, When I walk the floor where my employees work I always think of two people: my commander in the Israeli Air Forceand you.

This made me happier than just about anything else. Happy enough that I remember it and write it here now.

This shows me that the way I treated my employees was a good instinct and was a great contributor to any success Ive had.

M) ALWAYS BE SELLING

I mentioned above that I was always teaching people why they needed websites. This is one way to sell.

The other way to sellis to sell yourself. You want to be likable, you want people to do business with you, you want to offer value without expectation back so people know you are a partner and not just transaction-oriented.

And you also want tobe always sellingyour business.

Not always literally. Sometimes you want to build your business.

But often, for me at least, and for many others, when your business is at the top its a good idea to take cash off the table.

To be a partner instead of a competitor.

Not that you will stop working at the business or work any less hard. But cash is king and you need to be rewarded for your efforts and your continued efforts.

I sold my first business at the very top of the Internet boom. People thought I was crazy. I could have kept building.

And, in fact, I did keep building. We went from 40 employees to ultimately over 1000.

And the person who bought my company in August 1998 I am still good friends with. Nobody regretted buying my business.

He went on to be a well known movie producer, producing Superman, 300, and a ton of other movies. I am huge fan of his.

We had lunch recently. The sign of a good partner and a good deal is if 20 years later youre still able to be best friends with the people who put their faith in you and gave money to you.

I take August off, he told me when we had lunch, after I told him some of the situations Im working through right now. Im putting it on my calendar that I will spend time thinking of how I can help you or at least come up with ideas for you.

Always be selling sounds selfish. But it actually means, Always be helping people. Always deliver value. Always fulfill the promise of your very initial sale.

Always make it so that even 20 years later, people are so glad they did business with you that they seek you out to do business with you again.

My current business partner has been with me since 1999. The guy who bought my first business is one phone call away. The guy who bought my third business I saw just the other day and we hugged each other, recalling good times.

But business is hard and I wish I had more experience on that first one (although, by definition, it was my first so all I can wish for is that I had more common sense).

Some bad things that happened.

A) THREE SKILLS

Theres making money, keeping it, and growing it. Back then I only had making it. And I ended up not keeping it (then).

B) BURNOUT

Business is hard. Its 24 hours a day. You cant leave it at work.

I wish I had understood the psychology of it a little better. Every day being in the trenches with someone in a war can create a certain type of post traumatic stress.

I know I still have it. I have it and deal with it every day.

And perhaps this is why my first partner, my sister, and I no longer speak. I reached out to her a few months ago and a few months before that. I never get a response.

C) SOME REGRET

I had the knowledge and the tools and the ideas to make any product out there.

Many products that I thought of, and even built back then, were made into multibillion dollar businesses by others smarter than me.

I wish I had had the business savvy to realize it was more important to build value than create profits. I sacrificed value over profits because I didnt know any better.

D) FOCUS

Although I am not a big believer in focus, I went so quickly from Internet businesses to the hedge fund business that I do suspect I made a mistake.

Thehedge fund businesshas been valuable for me and I gained a HUGE amount of knowledge and new skills and contacts that Ive been able to use for much profit.

But I didnt enjoy it. I didnt feel it in my heart.

Money is in the gut. Passion is in the heart. And money should be a side effect of intelligently applied passion.

I enjoyed the Internet. I enjoyed the creativity of it. I enjoyed the ideas of it. I sort of wish I had stuck with that and kept building my knowledge and my skills and ideas.

Butthat leads me to the second million.

Maybe one day Ill write about it.

Oh, and I made an infographic a few months back on the 20 Habits of Eventual Millionaires.See it here.

(screenshot is fromarchive.orgin 1998 and is one of the many websites we used for that first business).

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‘Orwellian’ Offshore Tax Will Hit Some Firms Harder Than Others

The name that Republican tax writers gave to a new, multi billion-dollar business levy implies that it targets foreign earnings from “intangible” intellectual property — hitting tech firms and drugmakers like Apple Inc. and Pfizer Inc.

But experts agree that the little-understood “global intangible low-taxed income” levy, or GILTI, will also apply to earnings that go far beyond patents, royalties and licensing, and could end up snaring many global firms that earn little such income. Private equity partnerships that aren’t publicly traded, including Bain Capital LP, stand to pay rates three times as high as corporate competitors’, tax lawyers say. Law and advertising firms with overseas offices may also be hit — as will many U.S. companies that make “excess” profit from foreign plants, equipment and inventory.

The name is “Orwellian,” said James Duncan, a tax partner at the law firm Cleary Gottlieb Steen & Hamilton LLP, in a Dec. 20 webcast. “Its most significant effect is on income that is neither intangible nor low-taxed.”

GILTI has been commonly viewed as a minimum tax on foreign earnings from intangible property, one that’s meant to prod American technology and pharmaceutical companies into holding their valuable intellectual properties in the U.S. Currently, many hold their patents in subsidiaries in Ireland or other low-tax countries.

Yet the tax “doesn’t attempt to actually characterize income as tangible or intangible,” said David Miller, an attorney with Proskauer Rose LLP. It’ll apply to both, Miller and others said.

Reaching Overseas

In writing the biggest tax overhaul in three decades — a revamp that’s estimated to cut taxes by $1.5 trillion over 10 years — congressional Republicans made two major changes for corporate income taxes: They cut the rate to 21 percent from 35 percent and they ended the tax’s “global” reach.

For years, the American system has taxed corporations on their foreign profits, but allowed them to defer paying that tax until they brought their overseas earnings back to the U.S. The new system ends that deferral — and will require companies to pay a cut-rate tax on an estimated $3.1 trillion in income that they’ve stockpiled offshore.

At the same time, the legislation’s drafters sought new ways to prevent companies from shifting profit offshore — to countries with tax rates even lower than the new 21 percent corporate rate. The GILTI is key to that effort; for corporations, the tax applies only in cases where a company’s cumulative overseas tax bill is below a minimum threshold.

The new tax applies to excess foreign profit, and it allows significant deductions that — for those eligible — take its effective rate to 10.5 percent through 2025. After that, the rate increases to a little over 13 percent. Next year, corporations could take a 50 percent deduction and an 80 percent credit for foreign taxes they’ve paid. Together, the provisions mean that any corporation that pays foreign taxes at a rate of at least 13.125 percent could avoid the GILTI entirely before the rate rises in 2026.

Partnerships’ Problem

But those low rates are available only for corporations. Partnerships and other so-called pass-through entities would face much higher rates on some of their foreign income — they wouldn’t get the deduction, experts say. Pass-through entities don’t pay taxes themselves, but pass their income to their owners, who pay tax at their ordinary rates. As of Jan. 1, the top individual income rate is 37 percent.

In effect, experts say, a corporation would pay no more than $10.50 on every $100 of income that’s hit by the GILTI. A pass-through would pay as much as $37.

“The reality of this is going to sink in in the next month,” said Channing Flynn, an international tax partner and global technology industry tax leader at Ernst & Young LLP.

Three other tax experts — Proskauer Rose’s Miller; David Sites of Grant Thornton LLP; and Robert Scarborough of Freshfields Bruckhaus Deringer LLP — agreed that global private equity partnerships that aren’t publicly traded wouldn’t be eligible for the GILTI deduction. Moreover, a separate tax break for partnerships and other pass-throughs applies to domestic income only — not to the global earnings caught up by the GILTI, according to the bill.

Scarborough said the tax will hurt such firms as Bain, TPG Holdings LP and Warburg Pincus LLC, which are all private. By contrast, he said, publicly traded firms like Blackstone Group LP, Apollo Global Management LLC and Carlyle Group LP — all partnerships that are traded like corporations — would get the GILTI deduction.

Charlyn Lusk, a spokeswoman for Bain Capital, declined to comment. So did Luke Barrett, a spokesman for TPG Capital, and Mary Armstrong, a Warburg Pincus spokeswoman.

Different Treatment

The differing treatment could prompt Bain and others to consider forming so-called C corporations to hold their foreign assets, Scarborough said. “I’m sure people are running the numbers and thinking about this alternative,” he said.

Generally speaking, the GILTI will apply to many companies that might not immediately leap to mind as depending on intellectual property, experts agreed. The levy’s potential payers “will include lots of other businesses that don’t depend on factories or turbines to make money,” said Cleary Gottlieb’s Duncan.

One example: banks. While they’re typically structured as corporations — and thus entitled to the deduction and the initial rate of 10.5 percent — the result would still be an increase over their previous tax bills, said Mitch Thompson, a tax partner at Squire Patton Boggs U.S. LLP. That’s because as of Jan. 1, they and other corporations will lose the ability to defer paying taxes on income that will now fall under the GILTI, he said.

The GILTI levy was envisioned as a guardrail to ensure companies pay at least a minimum amount of U.S. tax. It’s estimated to raise $112.4 billion over a decade — receipts that would help underwrite the permanent corporate rate cut and other temporary cuts for individuals.

Another change to international taxation will also disadvantage pass-throughs, according to Grant Thornton’s Sites. A separate deduction sets up an effective tax rate of 13.1 percent on “foreign-derived intangible income” — that is, excess returns earned by U.S. companies on foreign sales. Only domestic corporations get the deduction. Closely held partnerships don’t; for their owners, the rate could be as high as 37 percent.

“Partnerships get slammed,” said Michael Kosnitzky, a tax partner at Pillsbury Winthrop Shaw Pittman LLP. “They’re not being treated as well as C corporations.”

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    What if the odd receiver out in Dallas was actually Cole Beasley? – Blogging The Boys (blog)


    Blogging The Boys (blog)

    What if the odd receiver out in Dallas was actually Cole Beasley?
    Blogging The Boys (blog)
    It hasn't even been a week since Allen Hurns joined the Dallas Cowboys yet his presence has inspired many new questions and concerns. Among the most pressing matters that needs to be discussed is who the odd man out is in the Dallas Cowboys receivers

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