Comments on: Treasury Plays Fairy Godmother to Citi; Kucinich Says Not So Fast http://www.taxgirl.com/treasury-plays-fairy-godmother-to-citi-kucinich-says-not-so-fast/ Paying taxes is painful... but reading about them shouldn't be. Sun, 12 Feb 2012 17:55:29 +0000 hourly 1 http://wordpress.org/?v=3.1.3 By: pharmacy tech http://www.taxgirl.com/treasury-plays-fairy-godmother-to-citi-kucinich-says-not-so-fast/comment-page-1/#comment-13370 pharmacy tech Fri, 08 Jan 2010 19:25:13 +0000 http://www.taxgirl.com/?p=4404#comment-13370 What a great resource! What a great resource!

]]> By: Daniel P. Marsh http://www.taxgirl.com/treasury-plays-fairy-godmother-to-citi-kucinich-says-not-so-fast/comment-page-1/#comment-13169 Daniel P. Marsh Sun, 20 Dec 2009 12:33:08 +0000 http://www.taxgirl.com/?p=4404#comment-13169 So,if I have a 5 percent position,I can change the rules? Are there rules in the code against self-dealing? I did not see an exemption for the government. This administration would argue that the authority is a punumberal authority,an authority that exists in the shadow of all government authority regs to act in the best interest of the people. This of course requires a recharterization of "rights" to "priviledges" which are temporily suspended by the the government to help the people. So,if I have a 5 percent position,I can change the rules?

Are there rules in the code against self-dealing? I did not see an exemption for the government. This administration would argue that the authority is a punumberal authority,an authority that exists in the shadow of all government authority regs to act in the best interest of the people. This of course requires a recharterization of “rights” to “priviledges” which are temporily suspended by the the government to help the people.

]]> By: jpe http://www.taxgirl.com/treasury-plays-fairy-godmother-to-citi-kucinich-says-not-so-fast/comment-page-1/#comment-13154 jpe Fri, 18 Dec 2009 18:37:40 +0000 http://www.taxgirl.com/?p=4404#comment-13154 The change to "change in ownership" rules that would occur as Citi left TARP seems defensible from a legal standpoint. I'm not a corporate tax person, but I work in the code enough to be comfortable with my reading, and my read is that the code kicks the ball to the Treasury to devise regs to deal w/ when a 5% owner sells its position. And if that's right, then the Treasury has the authority to declare that when it sells its position a change of ownership is deemed not to occur. That only deals w/ one of the two transactions, however, and I don't see how the Treasury can declare that its purchase of >5% isn't a change of ownership. The change to “change in ownership” rules that would occur as Citi left TARP seems defensible from a legal standpoint. I’m not a corporate tax person, but I work in the code enough to be comfortable with my reading, and my read is that the code kicks the ball to the Treasury to devise regs to deal w/ when a 5% owner sells its position. And if that’s right, then the Treasury has the authority to declare that when it sells its position a change of ownership is deemed not to occur.

That only deals w/ one of the two transactions, however, and I don’t see how the Treasury can declare that its purchase of >5% isn’t a change of ownership.

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