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Enhancing Tax Competitiveness in Connecticut
by | Jul 31, 2018 | Tax Tips and News
Tax Policy – Enhancing Tax Competitiveness in Connecticut
Connecticut is struggling. The state is affluent, but a shrinking population and departing employers, coupled with mounting costs of government and the high taxes that pay for it, have the state headed in the wrong direction.
The state's high and economically inefficient taxes are only one of several reasons for the outmigration of people and jobs, but taxes are an important consideration and one within policymakers' power to address.
In addition to its high rate, Connecticut's volatile corporate income tax suffers from its inclusion of an alternative capital stock base and limitations on the utilization of net operating losses. The state's recent shift to unitary combined reporting can also raise both tax and compliance costs for some businesses.
The individual income tax has grown far beyond the expectations set when it was first implemented in 1991, and its structure, in tandem with the unique economic characteristics of Connecticut's population, result in substantial revenue instability.
Like most states, Connecticut exempts broad swaths of personal consumption from the sales tax. Broadening the tax base could pay down substantial reforms to other taxes, as could the use of newfound authority to tax remote sales.
The absence of a de minimis threshold for business tangible property tax liability imposes substantial compliance costs on many businesses while yielding a negligible amount of additional revenue for local governments.
Keeping faith with an electorate which adopted a spending cap alongside the authorization of an individual income tax requires properly implementing and abiding by the cap.
With businesses and individuals heading for the exits, policymakers cannot afford complacency.
Connecticut's population is shrinking. From year to year the decline is not dramatic, but the trend is there—and the effects are beginning to be felt. They have been noticed, too: in 2017, The Atlantic asked, "What on Earth Is Wrong with Connecticut?"[1] At Slate, it was "Something has gone wrong with Connecticut."[2] The Hartford Courant is keeping tabs on the number of billionaires leaving the state.[3] Business journals are fretting about sustained outmigration.[4] Even the state itself is getting into the act, producing a 2017 study on population and migration trends.[5]
That migration is not limited to people: companies are leaving, too. While CVS Health's acquisition of Aetna kept the company–which had planned a relocation to New York City–in Hartford,[6] there was no such reprieve with General Electric or Alexion Pharmaceuticals, both of which decamped to Boston.[7] Corporations headquartered elsewhere, like Caterpillar, Motorola, and Kraft Heinz, reduced the size of their Connecticut workforces—and that's just the companies that shifted jobs to one city, Chicago.[8] The biggest companies garnered the most headlines, but for every General Electric or Alexion, there are many more small businesses that have pulled up stakes.
Stay Informed on Tax Policy in Your State
These companies did not relocate to the Sun Belt. That might have been worrying enough. Instead, companies are being pulled toward New York City, Boston, and Chicago. For some, taxes are the clear culprit, with proponents of this theory pointing to the statements of companies and individuals making their exodus. For others, taxes are at most incidental to the main story, particularly given that Boston and New York City are not exactly known as oases of low taxation.
The truth, as is often the case, likely lies somewhere in between. High (and rising) tax burdens have contributed to stagnation. So has the revitalization of major urban centers. So, too, have broader economic and demographic trends, greater mobility, and a shift in the entrepreneurial center of gravity in the country.
Younger workers increasingly want to move back into the cities their parents and grandparents abandoned for the suburbs. Lifestyles have changed; industry balances have shifted. Connecticut can address some of these problems, but not all. What it can do, though–what it must do–is make its tax code more competitive.
Taxes, after all, are within policymakers' authority in a way that the weather, or the rising appeal of big cities, really aren't. Cities and states with enough cachet can often thrive despite high costs of living, including high tax costs, but states that are losing ground enjoy no such luxury. If policymakers wish to arrest the outmigration of jobs and people to more welcoming climes, they will need to do something about a tax code that increasingly penalizes those who might otherwise be inclined to stay.
Connecticut's Economy
At $70,121, Connecticut has the highest per capita income of any state in the country[9]—an unusual preface to a tale of a state in a snowballing fiscal crisis. Nor does the state lack for resources, at least by conventional measures: Connecticut has the third-highest state and local tax collections per capita, at $7,410 per person.
As a wealthy state, Connecticut receives less federal funding than average, since fewer residents are beneficiaries of state-administered programs with federal funding sources.[10] Therefore, while the state's $7,410 per capita tax collections is substantially higher than the national average of $4,875, its total revenue per capita of $9,121 is just slightly above the national average. This should, however, also come with fewer demands on that revenue, since higher levels of federal assistance typically imply substantial low-income populations which create additional financial pressures on the state treasury as well.
But Connecticut has historically prioritized relatively high provision of government services. Generous public pensions, meanwhile, are beginning to catch up with the state, particularly as the population declines. Some of the traditional engines of economic activity in Connecticut are slowing, and in some cases businesses and individuals are going elsewhere.
The state benefits from a strong manufacturing base and an educated workforce. Its geography is advantageous for multinational firms which require an East Coast presence but not a big city headquarters. For many years, it has proven an attractive alternative to New York City and Boston. Increasingly, however, the state is struggling. Connecticut's high and distortive taxes are part of the problem, and their reform can be part of the solution.
Connecticut's corporate tax has two components: a traditional tax on net income and an alternative minimum tax on net assets. Businesses pay the greater of 7.5 percent of net income (no cap) or 3.1 mills on the value of their capital stock up to a cap of $1 million in capital stock tax liability. Companies with at least $100 million in gross income also face a surtax of 10 percent, down from 20 percent prior to 2018.[11]
Corporate Net Income and Capital Stock Taxes
Imagine a company with $20 million in net assets and $3 million in net taxable income. This company would owe $225,000 in corporate income taxes under the net income calculation and $62,000 under the capital stock calculation, so the company would remit the higher of the two ($225,000). If, however, the next year the company posted a loss, it would still face positive tax liability, now paying against its assets. This illustrates one of the shortcomings of capital stock taxes: they are levied without regard to ability to pay, imposing burdens even when a business is losing money.
Capital stock taxes are also nonneutral, as different industries and business structures have vastly different asset mixes. Finally, capital stock taxes penalize investment and expansion. Most established, profitable companies in Connecticut have little reason to be concerned with the state's capital stock tax, since it functions as a minimum tax within the corporate income tax, but new and expanding companies can be penalized by it, as can businesses that are struggling to survive. The tax favors the status quo to the detriment of less established businesses, and thus holds back Connecticut's economy.
Meanwhile, the surtax, while applicable to very few businesses, imposes an unusually high corporate rate on some of the state's largest employers. At 10 percent, the surtax brings the corporate net income tax rate to 8.25 percent for businesses with more than $100 million in gross income, which is on the high side nationally, though about in line with regional peers.
Net Operating Loss Provisions
Connecticut's net operating loss provisions are slightly less generous than those of many peer states. Although corporate income tax liability is determined on an annualized basis, business cycles do not follow the calendar. This can be problematic for corporations with cyclical income, enjoying high profitability one year and losses the next. To mitigate this reality, states (along with the federal government) allow corporations to deduct losses from previous and future years to offset current taxes owed. These net operating loss (NOL) "carrybacks" and "carryforwards" smooth out tax obligations over time, ensuring that industries with cyclical income are not at a competitive disadvantage against industries with more consistent and stable revenue streams.
Under a well-designed system of net operating losses, businesses which experience a period of negative income but return to profitability have the opportunity to deduct their losses against future taxable income. The NOL deduction helps ensure that, over time, the corporate income tax is a tax on average profitability. Without the NOL deduction, corporations in cyclical industries pay much higher taxes than those in stable industries, even assuming identical average profits over time.
There are two important variables of a state's NOL provisions: the number of years allowed for carrybacks and carryforwards, and caps on the amount of carrybacks and carryforwards. The maximum that any state allows for carrybacks is three years, with no cap (that is, an unlimited dollar amount allowed up to the entirety of current year taxable income). Among the states that allow carrybacks, the most common time span is two years with no cap. Most states offer a 20-year uncapped carryforward, and under the Tax Cuts and Jobs Act, the federal government now permits losses to be carried forward indefinitely but limits them to 80 percent of pre-NOL taxable income.
Connecticut disallows net operating loss carrybacks. Furthermore, while the state permits a 20-year carryforward, the deduction is limited to 50 percent of net income in any given year. Among neighboring states, New York has 20-year uncapped carryforwards and a three-year uncapped carryback period, and Massachusetts offers 20-year uncapped carryforwards but no carrybacks. Neighboring Rhode Island has an uncommonly stingy approach to net operating losses, only permitting them to be carried forward for five years.
Unitary Combined Reporting
Since 2016, Connecticut has mandated unitary combined reporting for corporations, requiring companies with common ownership that are engaged in a unitary business to calculate their tax liability on a combined basis.[12] Functionally, this means that all related businesses are treated as a single entity for tax purposes, rather than filing separately.
Taxing all affiliated businesses as if they constitute a single legal entity is designed to undermine tax planning, where companies shift income to some subsidiaries and park losses in others to minimize tax exposure. Opponents point to high compliance costs, increased complexity, and taxation of legitimate business activity in no way associated with the state or not otherwise subject to corporate taxes.
Unitary combined reporting shifts tax liability among related firms in ways that have no connection to ability to pay. It assumes that all member companies have the same level of profitability per dollar of sales, an assumption which cannot be borne out in the real world. Just because two companies are affiliated does not mean that each entity is in similar shape financially; increasing the tax burden on one company, which may be struggling, because a related company elsewhere is doing well, can be economically devastating.
Where differences in profitability are the result of tax planning, those strategies can be adjusted; where, as is more often the case, they represent the actual financial standing of each company, splitting tax liability this way can be uniquely burdensome for some operations.
The challenges associated with combined reporting do not end–or even begin–with an inequitable distribution of tax burdens. The first step is calculating that tax liability, which can be complex, costly, and controversial under combined reporting. There is often no easy answer to the question of which affiliated businesses should be considered as part of the unitary group; in fact, answers to this definitional question can vary from state to state and even year to year, meaning that just because a company is already subject to combined reporting in other states does not mean that Connecticut's requirements create no additional burden.[13] Disputes can take years or even decades to untangle. In 2010, California (which used combined reporting) was still processing tax cases from the 1970s, and General Electric had just closed its 1982 California tax return.[14]
Combined reporting increases complexity and can misallocate tax burdens. Statistical analyses demonstrate that combined reporting reduces gross state product.[15] Expectations of higher state revenue, meanwhile, have not always panned out. [16]
Other Issues in Corporate Taxation
Revenue volatility is a frequent complaint in Connecticut, and the state's reliance on a high-rate corporate income tax contributes to that revenue uncertainty. Since 2008, 16 states and the District of Columbia have cut corporate income taxes.[17] Reductions in corporate rates elsewhere reflect a trend toward decreased reliance on the highly volatile tax, which is imposed on an ever-declining amount of taxable income. Furthermore, a number of states have undertaken efforts to simplify the tax structure by broadening the base and lowering the rate. Corporate income tax revenue is in decline across the country as more businesses choose to structure as S corporations and limited liability corporations (LLCs), single sales factor apportionment schemes become more common, and states give away more of their tax base in special credits and deductions.
Like most states, Connecticut relies on tax incentives to reduce liability for select industries and economic activities. Some of the state's business tax credits have unlimited carryforward periods, while others are capped, most frequently at five years of carryforwards.[18] Tax incentives are a patch for an otherwise uncompetitive tax code, and Connecticut policymakers should explore paring back incentives in exchange for rate reductions or other structural reforms. They should not, however, reduce the value of credits already issued by further limiting their carryforward periods or otherwise capping claims, as this constitutes retroactive taxation.
Corporate income taxes tend to be complex and impose substantial administrative burdens for both payers and the government, and this complexity has not abated as the tax base has eroded. Finally, revenue volatility necessarily follows from the nature of the tax, since in periods of economic distress, many companies may post losses and thus be exposed only to the capital stock portion of the tax—significant for some, but negligible for others. As such, collections tend to be highly unstable, spiking sharply in good years and collapsing in bad ones.
Connecticut's individual income tax is of a recent vintage. Implemented in 1991, it is the newest state income tax in the country. Touted as a way to diversify the state's revenue stream and take the pressure off other taxes, it has expanded at a rapid clip and accounts for a far larger share of the state's total collections than was originally envisioned.
Connecticut's individual income tax has a top rate of 6.99 percent, which is above the national average, and it is imposed on a broad base of income. State income tax collections consume 3.05 percent of personal income in the state, a percentage only exceeded by five states and the District of Columbia. Collections per dollar of personal income are about 41 percent higher than the national average, reflecting the state's above-average top rate and broad definition of taxable income.[19] As a wealthy state, Connecticut also sees an above-average share of state income exposed to the top rate.
Adopted as a way to improve revenue stability, it has proved the opposite.[20] Capital gains are a significant source of income for high earners, but investment income is inherently volatile. A graduated-rate tax in a high-income state results in heavy reliance on income streams which may change sharply from year to year. Capital gains are taxed upon realization, meaning that taxes are only owed once an asset is sold. They are, moreover, offset by capital losses, and in some years, many more people will be cutting their losses than taking their gains.
Nationally, capital gains realizations soared 91 percent in the tax reform year of 1986, then plummeted 55 percent the next year.[21] They slid 71 percent between 2007 and 2009, during the Great Recession. They slipped 55 percent in 1987 and 46 percent in 2001.[22] Other sources of tax revenue showed volatility in these years as well, but at nowhere near the intensity of capital gains.
Capital gains are taxed upon realization, meaning that you only owe the tax once you sell the asset. And of course, capital gains are offset by capital losses. In some years, many more people will be cutting their losses than taking their gains.
Connecticut acknowledges this problem, which served as the motivation for the state's volatility cap. Recognizing that a sizable share of capital gains income is reported by individuals who file quarterly returns, the state set a $3.15 billion cap on collections from quarterly filers and sweeps any additional amounts into the budget reserve fund, part of which can be transferred to help pay down unfunded pension liabilities.[23] This policy represents a meaningful step in the right direction, but can only partially remedy the tax's underlying instability.
Revenue stability can also be undermined if people choose to vote with their feet. Taxes are only one of many factors in deciding where to live and work, but especially for high-income taxpayers–who enjoy greater mobility–an uncompetitive individual income tax has the potential to drive people away faster than the state can attract new residents.
In fiscal year 2016, more than 82,000 people left for another state, while 63,000 moved to Connecticut from another state, representing a net outflow. Even more significantly, however, the newcomers of fiscal year 2016 had a cumulative adjusted gross income (AGI) of $3.2 billion, while those departing had a cumulative AGI of $5.8 billion. This represents a net loss of $2.6 billion of AGI from departures that year alone. [24]
Initially a 4.5 percent single-rate tax,[25] the individual income tax's rate structure has changed five times since the income tax's adoption in 1991.[26] The tax became a graduated rate tax in 1996, but its current status as a highly progressive income tax only dates to 2009. When the state first shifted from a flat income tax to a two-rate tax, the former flat rate was adopted as the new flat rate (on income above $10,000), making the change a small net tax cut. The top rate crept up to 5 percent in 2003, but it was not until 2009 that the tax's character changed, with a new top rate of 6.5 percent on income above $500,000.
Two tax increases later, 6.5 percent is the rate on income between $200,001 and $250,000, while the top rate stands at 6.99 percent. All income above $10,000 is taxed at higher rates than it was under the initial 4.5 percent flat-rate tax.[27] The income tax had expanded to include seven brackets by 2015.
Table 1. Individual Income Tax Rate and Bracket History
Kick-In of Top Rate
Source: Connecticut Office of Legislative Research
1991 4.50% $0 1
1996 4.50% $2,250 2
1999 4.50% $10,000 2
2009 6.50% $500,000 2
Aggressive increases in recent years contribute to a sense that the state's desire for additional revenue is insatiable. In conversations with leaders of traditional C corporations, we found that the individual income tax was cited frequently as a consideration for businesses making location decisions. Even though the businesses themselves pay corporate, not individual, income taxes, the individual income tax drives up the cost of living in Connecticut and makes the state less attractive overall.
The last budget adopted prior to the adoption of an individual income tax ran $7.15 billion.[28] In the fiscal year 2019 budget, total appropriations reached $20.86 billion.[29] Had Connecticut's budget merely kept pace with inflation, appropriations would stand at $13.67 billion. Instead, state spending burgeoned, driven in large part by an expanding individual income tax.
Once championed as a way to diversify revenue sources and reduce volatility, with additional revenues as a secondary consideration, the income tax has transformed Connecticut's budget through a dramatic expansion in revenue capacity. Unfortunately for taxpayers, even this remarkable rate of revenue growth has proven incapable of keeping up with the demands of an ever-costlier state government.
First adopted in 1947, the sales tax long held pride of place as Connecticut's most important source of tax revenue. As the state's spending soared, the sales tax rate peaked at 8 percent in 1989,[30] which helped build support for the adoption of an individual income tax in 1991. The sales tax rate was rolled back to 6 percent, and the new income tax initially yielded slightly less revenue than the 6 percent sales tax. Changes to the income tax since then, however, have caused the two taxes to diverge sharply, and today the income tax raises more than twice as much as the sales tax.
If the sales tax were still at 8 percent, it would raise an additional $1.06 billion each year. The income tax that occasioned the rate reduction generates $9.86 billion a year.
One of the great advantages of the sales tax is its stability. All tax revenue is subject to economic cycles, but consumption taxes experience considerably less volatility than income taxes. Over time, however, Connecticut's sales tax base has eroded as the economy becomes increasingly service-oriented. Lawmakers have also carved certain goods out of the sales tax for policy reasons.
The exemption for groceries, for instance, reduces collections by an estimated $451 million each year. The prescription drug exemption costs $412 million, while the state forgoes another $31 million by exempting nonprescription drugs.[31] Most services go untaxed by default, as the state tax base includes tangible goods unless otherwise exempted, but only includes such services which are directly mentioned in statute.
Accordingly, the state does not provide estimates for the exclusion of many services from the base. However, a first-order estimate of amount forgone by not taxing personal services alone is $150 million.[32] The following table delineates just a few of the major exemptions within the sales tax code, together worth $2 billion in forgone revenue. To place the magnitude of these exemptions in context, if they were included in the base, the sales tax would raise the same amount of revenue with a 4.3 percent rate as it currently does at a 6.35 percent rate.
Table 2: Select Sales Tax Exemptions
Good or Service
* Author's estimate. Sources: Office of Fiscal Analysis; Bureau of Economic Analysis; author's calculations (personal services category).
Food $450.8 million
Prescription Drugs $411. 8 million
Motor Fuel $411.7 million
Patient Care Services $382.9 million
Consumer Utilities $156.1 million
Personal Services* $150.6 million
Nonprescription Drugs $30.8 million
Amusement and Recreation $12.3 million
Total $2.01 billion
The Supreme Court's decision in Wayfair v. South Dakota, eliminating physical presence as a requirement for collecting sales taxes on transactions involving out-of-state sellers,[33] gives states new opportunities to collect additional revenue as well. However, the size of this windfall should not be overestimated. The federal General Accountability Office provides low- and high-end estimates of potential revenue gains through remote sales tax collection authority, giving Connecticut a range from $128 to $194 million.[34] For simplicity's sake, this paper will use a midpoint estimate of $161 million, but this figure–as with estimates from sales tax base broadening–should be considered a rough estimate only. Adding remote sales authority to the above base-broadeners would be enough to permit a revenue-neutral 4.2 percent rate.
Connecticut does not, however, need a 4.2 percent sales tax rate. (Earlier this year, a state tax commission recommended raising the sales tax rate from 6.35 to 7.25 percent to help pay down reforms elsewhere in the code.[35]) What it needs is reforms to other elements of the tax code, and sales tax base-broadening can help pay down rate reductions and reforms elsewhere. If Connecticut wanted to restore its old 6.0 percent sales tax rate, this could be accomplished with about $289 million in base-broadeners; any revenue beyond that could be put toward other reforms.
Property and Wealth Taxes
Business Tangible Property Taxes
Connecticut's property taxes extend to both real and tangible personal property. Real property includes land, buildings, improvements, fixtures, minerals, and other property attached to the land itself, including rights and interests. Tangible personal property encompasses other physical objects, including business equipment—often colloquially defined as property that can be touched and moved. In Connecticut, household goods are exempt from the tangible personal property tax, and automobiles are taxed separately, rendering the tangible personal property tax primarily a tax on machinery and equipment (except when used in manufacturing), trade fixtures, and even some software owned by businesses.
Connecticut has reduced its reliance on tangible personal property taxes over the years, adopting exemptions for inventory and manufacturing machinery and equipment. These reforms are part of the reason why personal property taxes declined from 14.3 to 5.5 percent of the property tax base from 1991 to 2013.[36]
Several of Connecticut's regional competitors forgo tangible personal property taxes. New York, Pennsylvania, and New Hampshire exempt tangible personal property, while collections in Vermont are minimal.[37] This gives businesses in those states an advantage over their Connecticut-based competitors, as tangible personal property taxes reduce capital investment.
In addition to the actual tax burden, tangible personal property taxes impose substantial compliance and administration costs because the tax levy is "taxpayer active." This means that businesses must fill out forms identifying all of their personal property subject to taxation and detailing relevant attributes including, but not limited to, a physical description, the year of purchase, the purchase price, and any identifying information (e.g., serial numbers). The tax is to be remitted upon the depreciated value of each article of personal property.[38]
The direct and indirect costs of tangible personal property taxes have made such taxes a target for reduction or elimination in a growing number of states, as they are a barrier to economic growth. According to the Council on State Taxation, nearly 34 percent of state and local business taxes remitted in Connecticut are property taxes (almost four times as much as is paid in corporate income taxes),[39] and nearly a quarter of it ($590 million a year) is due to personal property taxes.[40] A direct tax on capital formation, tangible personal property taxes are also distortionary, as they apply to some business inputs but not to others. Taxes and machinery and equipment create incentives for mobile capital to flow out of high-tax areas into low-tax areas.
Removing manufacturing machinery and equipment from the base was an important step, but the state should have the ultimate goal of repealing this uncompetitive tax. In the interim, Connecticut policymakers have several options for tangible personal property tax reform.
The state could gradually reduce reliance on tangible personal property taxes by creating a de minimis exemption. Simply exempting taxpayers with $10,000 or less in taxable personal property would eliminate liability for 46 percent of current taxpayers at a cost of 0.014 percent of property tax revenue. The costs of compliance and collections are far too high to justify collecting such a negligible amount of revenue.[41] Setting a higher threshold, such as $200,000 in assessed value, would exempt almost 93 percent of current filers while retaining 88.5 percent of the tax base.[42]
The state could also phase out the tax over time by exempting new property from taxation, as Maine and Kansas have done.[43] This has the advantage of limiting the immediate impact on local bases, while at the same time encouraging economic growth by keeping new and expanding business from entering the system in the future. Over time, taxable old equipment is replaced with new equipment that is exempt from the tax, while local governments avoid steep and sudden reductions in tax revenue, instead relying on gradual cuts that could be absorbed by real property or other taxes over time without large rate increases.
Connecticut is one of 13 states which levies an estate tax, and one of 18 states with some sort of tax on transfers at death.[44]
Until recently, the federal government provided a credit against state death taxes paid (CSDT), up to a certain amount. Consequently, all 50 states adopted estate taxes designed, at the very least, to capture all revenue up to this threshold (commonly called the "pick-up tax"), since they could do so without increasing anyone's tax liability. With the elimination of the credit, most states have repealed their estate taxes—some immediately, and some in the intervening years. Connecticut remains one of a dwindling number of holdouts.[45]
In recent years, Connecticut's nine-bracket estate tax, with rates ranging from 7.2 to 12 percent, has yielded above-average burdens on estates valued at less than $5 million, but below-average burdens for the largest estates. The state is currently phasing in conformity with the federal exemption level, however, which will ultimately exempt from taxation all estates valued under $11.2 million.
This reform will eliminate liability for most taxpayers currently subject to the estate tax, and will make compliance and administration easier by mirroring federal law. Even a tax limited to the largest of estates, however, can have detrimental economic effects, as it can encourage tax avoidance activities or even drive wealthy older taxpayers out of state, potentially depriving the state of income tax and other tax collections (and broader economic activity) in their final years.
Since 1991, Connecticut's constitution has imposed a spending cap, ratified by the voters in tandem with the individual income tax. Ostensibly, the cap prohibits the state budget from increasing faster than the percentage increase in personal income or inflation (whichever is higher), subject to supermajority overrides or an emergency finding by the governor. In practice, however, the requirement is largely ineffectual, with the legislature and governor repeatedly redefining the base for the authorized budget or leaning on enabling legislation to exclude elements of the budget from the capped general budget expenditures.[46] And now, according to the Office of the Attorney General, the cap is not only ineffectual but unenforceable.[47]
The constitutional amendment requires that the General Assembly define the terms "increase in personal income," "increase in inflation," and "general budget expenditures" in statute, all of which are necessary to the operation of the cap. Prior to the amendment's ratification, the legislature adopted a stopgap statutory spending cap, but never proceeded to adopt legislation defining terms for the new constitutional requirement. Accordingly, the Attorney General contends that the constitutional cap is not in operation, and that while the statutory cap also imposes a supermajority requirement, it is legally unenforceable, and could be suspended by a simple majority vote.[48]
Previous Attorneys General came to a different conclusion, opining that the statutory caps provided the required definitions for purposes of the constitutional amendment.[49] Policymakers have long evaded the cap by shifting costs outside it, but under the new interpretation, they are spared even this hurdle. When voters ratified an income tax and a spending cap side-by-side, it is reasonable to assume that they wanted real spending restraint. Instead, they got a nearly toothless measure, and now no constraint at all. Maintaining faith with the public requires fixing the spending cap.
Connecticut has failed to live up to the expectations of 1991. Changes intended to make tax collections more stable, combined with constraints intended to promote fiscal prudence, have strayed far wide of the mark. In recent years, policymakers have pursued a range of tax hikes which have created uncertainty and undermined the state's competitiveness, without addressing structural shortcomings which become more pronounced with time. The time has come to rebalance and restructure the tax code, and perhaps to cast a more critical eye upon the rising expenditures that helped bring the state to this point.
There will be hard choices. But as the state's finances falter and its people and businesses look for the exits, the status quo is no choice at all.
[1] Derek Thompson, "What on Earth is Wrong With Connecticut?" The Atlantic, July 5, 2017, https://theatlantic.com/business/archive/2017/07/connecticut-tax-inequality-cities/532623/.
[2] Henry Grabar, "Trouble in America's Country Club," Slate, June 2, 2017, http://slate.com/articles/business/metropolis/2017/06/something_is_wrong_with_connecticut.html.
[3] Dan Haar, "Two Billionaires Head For Florida, Deepening CT's Cash Crisis," Hartford Current, March 3, 2016, http://courant.com/business/dan-haar/hc-haar-forbes-list-thomas-peterffy-exit-costs-state-20160302-column.html; Russell Blair, "Forbes: Connecticut Retains Its 17 Billionaires," Hartford Courant, March 7, 2018, http://courant.com/politics/hc-pol-no-billionaires-left-connecticut-20180307-story.html.
[4] HartfordBusiness.com, "CT Fourth Highest State in Out-Migration," Jan. 4, 2018, http://hartfordbusiness.com/article/20180104/NEWS01/180109967/ct-fourth-highest-state-in-out-migration.
[5] Manisha Srivastava, "Connecticut's Population and Migration Trends: A Multi-Data Source Dive," Connecticut's Office and Policy and Management, May 2017, http://ct.gov/opm/lib/opm/budget/resourcesanddata/CTs_Population_and_Migration_Trends.pdf.
[6] Jon Chesto, "CVS Health Confirms that Aetna Will Stay in Hartford," Boston Globe, Jan. 12, 2018, https://bostonglobe.com/business/2018/01/12/cvs-health-confirms-that-aetna-will-stay-hartford/KhNHIzNDG455v5Nt9QgyEI/story.html.
[7] Stephen Singer, "General Electric Moving Headquarters to Boston," Hartford Courant, Jan. 13, 2016, http://courant.com/business/hc-boston-ge-moving-20160113-story.html; Stephen Singer, "Alexion Exits New Haven For Boston, Agrees To Repay Millions In State Aid," Hartford Courant, Sept. 12, 2017, http://courant.com/news/connecticut/hc-alexion-moving-new-haven-boston-20170911-story.html.
[8] Henry Grabar, "Trouble in America's Country Club."
[9] This is true of states, though the District of Columbia posts a higher per capita income ($76,986). Bureau of Economic Analysis, "Regional Economic Accounts, SA1 Personal Income Summary: Personal Income, Population, Per Capita Personal Income," https://www.bea.gov/regional/.
[10] States receive block grants or partial federal matches for many expenditures, Medicaid perhaps most notably. Not all federal grants are for low-income individuals, however, or for individuals at all; for instance, states receive highway dollars from the federal government as well.
[11] Connecticut Commission on Fiscal Stability and Economic Growth, "Final Report," March 2018, 27-28, https://www.cga.ct.gov/fin/tfs/20171205_Commission%20on%20Fiscal%20Stability%20and%20Economic%20Growth/20180301/Final%20Report%20with%20Appendix.pdf.
[12] PricewaterhouseCoopers, "Connecticut – Guidance on unitary combined reporting requirements," March 2, 2016, 1, https://www.pwc.com/us/en/state-local-tax/newsletters/salt-insights/connecticut-guidance-on-unitary-combined-reporting-requirements.html.
[13] William F. Fox and LeAnn Luna, "Combined Reporting with the Corporate Income Tax: Issues for State Legislatures," Center for Business and Economic Research, University of Tennessee, November 2010, iv.
[14] Commonwealth Foundation, "Pennsylvania Budget Facts 2010: Corporate Taxes," June 29, 2010, https://www.commonwealthfoundation.org/research/detail/pennsylvania-budget-facts-2010-corporate-taxes.
[15] William F. Fox and LeAnn Luna, "Combined Reporting with the Corporate Income Tax: Issues for State Legislatures," 36-40.
[16] William F. Fox, LeAnn Luna, Rebekah McCarty, Ann Boyd Davis, and Zhou Yang, "An Evaluation of Combined Reporting in the Tennessee Corporate Franchise and Excise Taxes," Report to the Tennessee Comptroller of the Treasury, Oct. 30, 2009, 35, http://cber.haslam.utk.edu/pubs/combrpt.pdf.
[17] See Joseph Bishop-Henchman, "Trend #3: Corporate Tax Reductions, Top 10 State Tax Trends in Recession and Recovery, 2008 to 2012," Tax Foundation, June 13, 2012, http://taxfoundation.org/article/trend-3-corporate-tax-reductions; Facts & Figures: How Does Your State Compare? Tax Foundation, multiple years.
[18] Rute Pinho, "Guide to Connecticut's Business Tax Credits," Connecticut Office of Legislative Research, Dec. 11, 2017, 23, https://cga.ct.gov/2017/rpt/pdf/2017-R-0287.pdf.
[19] Author's calculations using U.S. Census Bureau and U.S. Bureau of Economic Analysis data.
[20] Editorial, "25 Years After Reviled Income Tax Came In, CT Is Hooked On It," Hartford Courant, Aug. 12, 2016, http://www.courant.com/opinion/editorials/hc-ed-income-tax-still-riles-25-years-later-20160811-story.html.
[21] Congressional Budget Office, "Capital Gains Taxes and Federal Revenues," Revenue and Tax Policy Brief, Oct. 9, 2002, 3, https://cbo.gov/sites/default/files/107th-congress-2001-2002/reports/taxbrief2.pdf.
[22] Congressional Budget Office, "Budget and Economic Data," https://www.cbo.gov/about/products/budget-economic-data#7.
[23] Rute Pinho, "OLR Backgrounder: Connecticut's Volatility Cap," Connecticut Office of Legislative Research, Jan. 29, 2018, https://cga.ct.gov/2018/rpt/pdf/2018-R-0041.pdf.
[24] U.S. Census Bureau, "State to State Migration Flows," https://census.gov/data/tables/time-series/demo/geographic-mobility/state-to-state-migration.html.
[25] Rute Pinho, "Connecticut Income Tax Rates and Brackets Since 1991," Connecticut Office of Legislative Research," June 14, 2018, https://www.cga.ct.gov/2018/rpt/pdf/2018-R-0058.pdf.
[26] In 1996, when the single-rate tax was first transformed into a two-rate graduated income tax, the threshold for the second bracket was gradually phased up from $2,250 to $10,000 over several years. We count this as a single structural change.
[27] Rute Pinho, "Connecticut Income Tax Rates and Brackets Since 1991," 3-4.
[28] Office of Fiscal Analysis, Connecticut General Assembly, "The State Budget for the 1990-1991 Fiscal Year," July 1990, xxix, https://cga.ct.gov/ofa/Documents/year/BB/1991BB-19900701_FY%2091%20Connecticut%20State%20Budget.pdf.
[29] Office of Fiscal Analysis, Connecticut General Assembly, "SB-543: An Act Concerning Revisions to the State Budget for Fiscal Year 2019 and Deficiency Appropriations for Fiscal Year 2018," 2018, https://cga.ct.gov/2018/FN/2018SB-00543-R00-FN.htm.
[30] Connecticut Department of Revenue Services, "Special Notice – Sales and Use Tax," TSSN-20, 1989, http://ct.gov/drs/cwp/view.asp?a=1475&q=268944.
[31] Office of Fiscal Analysis, Connecticut General Assembly, "Connecticut Tax Expenditure Report," Feb. 13, 2018, https://cga.ct.gov/ofa/Documents/year/TER/2018TER-20180201_Tax%20Expenditure%20Report%20FY%2018.pdf.
[32] Author's calculations based on U.S. Bureau of Economic Analysis Personal Consumer Expenditures data.
[33] South Dakota v. Wayfair, Inc., 585 U.S. ___, slip op. (2018).
[34] United States Government Accountability Office, "Sales Taxes: States Could Gain Revenue from Expanded Authority, But Businesses Are Likely to Experience Compliance Costs," November 2017, 48, https://gao.gov/assets/690/688437.pdf.
[35] Connecticut Commission on Fiscal Stability and Economic Growth, "Final Report," 44.
[36] Lawrence C. Walters, "The Business Personal Property Tax in Connecticut," Draft Paper, Nov. 6, 2015, 3, https://cga.ct.gov/fin/tfs%5C20140929_State%20Tax%20Panel%5C20151117/Business%20Tangible%20Property%20Tax%20Walters.pdf.
[37] Joyce Errecart, Ed Gerrish, and Scott Drenkard, "States Moving Away From Taxes on Tangible Personal Property," Oct. 4, 2012, https://taxfoundation.org/states-moving-away-taxes-tangible-personal-property/.
[39] Council on State Taxation, "Total State and Local Business Taxes: State-by-State Estimates for Fiscal Year 2016," August 2017, 22, https://ey.com/Publication/vwLUAssets/ey-total-state-and-local-business-taxes-2016/$File/ey-total-state-and-local-business-taxes-2016.pdf.
[40] Id., 10; and Lawrence C. Walters, "The Business Personal Property Tax in Connecticut," 1.
[41] Lawrence C. Walters, "The Business Personal Property Tax in Connecticut," 23.
[42] Id., 17.
[43] Joyce Errecart, Ed Gerrish, and Scott Drenkard, "States Moving Away From Taxes on Tangible Personal Property."
[44] Six states impose inheritance taxes; one of them (Maryland) has an estate tax as well. New Jersey had both an inheritance and an estate tax until this year, but now only imposes an inheritance tax.
[45] Jeffrey A. Cooper, "Interstate Competition and State Death Taxes: A Modern Crisis in Historical Perspective," Pepperdine Law Review 33:4 (May 15, 2006), 840.
[46] Stan McMillen et al., "Connecticut's Spending Cap: Its History and an Alternative Spending Growth Rule," Connecticut Center for Economic Analysis, September 2005, 2, https://webshare.business.uconn.edu/ccea/studies/Connecticut's-Spending-Cap-History-Alternative-Spending-Growth-Rule.pdf.
[47] Office of the Attorney General of Connecticut, "Formal Opinion 2015-05," Nov. 17, 2015, https://portal.ct.gov/-/media/AG/Opinions/2015/2015-05_fasano_spending_caps-pdf.pdf.
[48] Id., 7-9.
[49] Keith M. Phaneuf and Mark Pazniokas, "AG Declares Constitutional Spending Cap Unenforceable," The Connecticut Mirror, Nov. 17, 2015, https://ctmirror.org/2015/11/17/ag-declares-constitutional-spending-cap-invalid/.
Source: Tax Policy – Enhancing Tax Competitiveness in Connecticut
Decomposing a Dynamic Revenue Estimate
Tax Policy – Decomposing a Dynamic Revenue Estimate
Last week, The New York Times published a chart showing that corporate tax revenues have fallen significantly since passage of the Tax Cuts and Jobs Act (TCJA). This has led some to wonder whether the dynamic revenue effects that were promised by supporters of the TCJA are going to materialize. If the economy is supposed to grow in response to a tax cut, thus boosting the tax base, shouldn't corporate tax revenues stay relatively constant, or at least not fall too significantly?
The answer is no. Leaving aside possible micro-dynamic (behavioral) responses by taxpayers, there is little reason to think that corporate tax revenues would not decline by as much as a conventional estimate implies, even if the economy grows in response to the tax cut.
To the extent the federal government gains revenue from additional economic output to offset the initial revenue loss of a corporate tax cut, it will be through increased individual and payroll taxes, not through steady or increasing corporate income tax revenues.
To illustrate, let's assume the federal government cuts the corporate income tax rate from the current 21 percent to 16 percent, a 5-percentage-point reduction. This would be a significant tax cut. Using the Tax Foundation model, I estimate that this would reduce federal revenue by $916 billion over the next decade on a conventional basis, or without any macroeconomic feedback (Table 1).
At the same time, a corporate tax cut will increase the incentive for companies to invest and increase the size of the capital stock and boost economic output (GDP) over the next decade. I estimate that, on average, GDP will be 0.3 percent higher than otherwise.
The larger economy over the next decade means that a 5-percentage-point reduction in the corporate tax rate will reduce revenue by $757 billion on a dynamic basis compared to its conventional cost of $916 billion. This is a revenue feedback of $158.5 billion, or an average of $15.8 billion a year.
However, this revenue feedback is not due to additional corporate tax revenue. Rather, it is due to higher tax collections from all other federal taxes. Corporate tax revenue on a dynamic basis ($914.4 billion) is effectively the same as it is on a conventional basis ($915 billion). The intuition here is that the larger economy does mean that corporations are making more sales, but it also means that they are investing more and, thus, taking even more deductions against their taxable income. In this case, we are estimating that the capital stock will grow faster than GDP and be 0.5 percent larger over the budget window compared to 0.3 percent for GDP (Table 2). On net, this means that corporate taxable income will be roughly steady over the budget window.
Table 1: Total Ten-Year Revenue Impact, 5-Percentage-Point Reduction in the Corporate Income Tax Rate, 2019-2028
in Billions of dollars
Individual Income Taxes $0.0 $101.6
Payroll Taxes $0.0 $46.4
Corporate Income Taxes -$915.9 -$914.4
Excise Taxes $0.0 $3.6
Estate and Gift Taxes $0.0 $0.9
Other $0.0 $4.5
Total -$915.9 -$757.4
Table 2: Average Ten-Year Economic Impact, 5-Percentage-Point Reduction in the Corporate Income Tax Rate, 2019-2028
GDP 0.29%
Wages 0.24%
Capital Stock 0.53%
Corporate Revenue 0.30%
Dynamic revenue feedback from economic growth is due to higher revenue collections from the income, payroll, and other taxes. The larger economy drives an increase in capital income, wages, and salaries, which boosts tax collections from those taxes. The model estimates that wages will be 0.24 percent higher on average over the budget window. As a result, the individual income tax ends up collecting $101.5 billion more over the decade, and the payroll tax collects an additional $46.4 billion. All other taxes collect the remaining $9 billion due to higher output.
It is worth noting that in terms of the TCJA, the federal government will still lose individual income tax revenue, on net, even with a larger economy. This is because individual income taxes were cut significantly.
There are also noneconomic factors that could influence corporate tax collections that are worth mentioning. For example, a lower statutory corporate tax rate could make it more attractive to shift profits to the United States. Additionally, a lower statutory corporate tax rate could make it more attractive for noncorporate businesses (pass-throughs) to reorganize as traditional C corporations. Both of these "behavioral" effects would boost corporate revenues and lead to a smaller revenue loss than a simply "static" score would imply. However, they are separate from the pure "dynamic" or economic effects and are generally captured in both conventional and dynamic revenue estimates.
Many people are watching federal revenue collections closely after the passage of the TCJA. The big question is whether the TCJA will deliver the economic gains and revenue feedback that were projected. At this point it is probably too soon to tell, but it is important to understand what to expect. Our modeling suggests that corporate tax revenue will remain low while additional individual income and payroll tax revenue will offset some of the initial revenue loss.
Source: Tax Policy – Decomposing a Dynamic Revenue Estimate
Final rules govern adequate substantiation for charitable contributions
IRS Tax News – Final rules govern adequate substantiation for charitable contributions
Final regulations address how taxpayers can comply with the requirements for adequate substantiation of charitable contributions of money or property.
Source: IRS Tax News – Final rules govern adequate substantiation for charitable contributions
Bureau of Economic Analysis Releases Q2 2018 GDP Estimate
Tax Policy – Bureau of Economic Analysis Releases Q2 2018 GDP Estimate
Today, the Bureau of Economic Analysis (BEA) released its initial estimate of major components of GDP for the second quarter of 2018, showing that the U.S. economy grew at an annual rate of 4.1 percent. The U.S. economy is likely on track to reach 3 percent GDP growth for the year, and growth this quarter reached the highest point since the third quarter of 2014. While a positive sign of continued economic expansion, it's important to remember that this is a snapshot of economic activity over the last three months, not necessarily a long-term trend.
According to the BEA, second quarter GDP rose by 4.1 percent (annualized rate), which is up from the revised 2.2 percent growth in the first quarter of 2018. Exports increased 9.3 percent, likely in reaction to trade policy; companies rushed to export goods like soybeans before tariffs took effect. This particular change is not expected to persist. Personal consumption expenditures increased 4.0 percent, indicating that consumers are spending more. Gross private domestic investment decreased 0.5 percent, driven by a decrease in residential investment.
Today's release also included a comprehensive update of the National Income and Product Accounts (NIPA). This update included changes the BEA made to seasonal adjustments, other measurement methods, and some definitions. The update also features a change in reference year, going from 2009 to 2012 for chained-dollar estimates.
As we noted last quarter, we should be careful making definitive conclusions from macroeconomic aggregates. A short time period is not sufficient to make conclusions about long-term policy changes, and these are estimates of economic activity that are often revised later. It is nearly impossible to tease out interactions among tariffs, trade uncertainty, tax policy, and hundreds of other changing economic factors, and we can never observe the counterfactual, or the economy in which tariffs had not been imposed and the tax law never passed.
Source: Tax Policy – Bureau of Economic Analysis Releases Q2 2018 GDP Estimate
Testimony: Tax Burdens and Tax Triggers in Arkansas
Tax Policy – Testimony: Tax Burdens and Tax Triggers in Arkansas
With only a month until their final recommendations are due, the Arkansas Tax Reform and Relief legislative task force is working furiously to develop tax reform options for the Natural State. Today, the task force asked me to present again on several key topics: Comparing Arkansas's tax burden to other states, and how to design a tax trigger.
My presentation, which is below, first included a discussion about how to evaluate tax policies. I've talked about these items to the task force on many occasions, but I wanted to highlight these principles one additional time. All tax policies represent trade-offs, but they should be evaluated through the lens of neutrality, simplicity, transparency, and stability.
Additionally, the task force was quite interested in discussing equity and how Arkansas's tax code compares, particularly on the question of regressivity. Data from the Institute on Taxation and Economic Policy (ITEP) has been frequently citied during conversations, so I took some time to walk through my qualms with their data. Their data tends to overstate regressvitiy in several ways, including the selective use of the federal tax code.
Finally, I discussed how to design a tax trigger. Tax triggers, when well structured, can be a helpful tool to balance revenue adequacy and tax reform. Designing a tax trigger can be tricky, however, as states like Oklahoma illustrate. Because Oklahoma's tax trigger did not include the proper baseline, it continued to cut revenues while the state rebounded from the Great Recession.
Source: Tax Policy – Testimony: Tax Burdens and Tax Triggers in Arkansas
1407 Graymalkin Lane
Minnesota House and Senate at Odds Over Gas Tax Increase
Republican Study Committee Budget Contains Important Tax Policy Proposals
U.S. Businesses Pay or Remit 93 Percent of All Taxes Collected in America
Taxable Income vs. Book Income: Why Some Corporations Pay No Income Tax
How High are Other Nations' Gas Taxes?
Tax Tips and News
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text:
ABC Assessors i Consultors
Notable Services
Formalities and requirements
Holding companies, trading companies and others
Residence without work
Financial and Tax Division
International Division
Intellectual Property Division
With the entry into force of the Law on Corporation Tax, and other direct and indirect taxes, the Principality of Andorra has begun a strategy to harmonize its taxation with other countries of the European Union.
Andorra has left behind being labelled as a tax haven to become a competitive country at both financial and tax level, and to be a country attractive both for foreign investment and for all those Andorran asset holders who wish to channel their investments abroad from Andorra.
Now all those people, assets and business groups wishing to obtain a structure which enables them to optimise the different types of income (dividends, capital gains, fees, royalties, etc.) have the possibility of finding in the Principality of Andorra a suitable country for the formation of a company which meets their objectives.
At ABC Advisors and Consultants we offer professional, personalised advice, always thinking of the type of structure best suited to the needs and particularities of each client.
The Andorran Law on Corporation Tax envisages four types of companies with clear tax advantages:
Holding companies for holdings in foreign entities
Companies for the exploitation of intangibles
International trading companies
Intra group management and financial investment companies (Cash pooling)
These are Andorran companies with the exclusive object of the management and maintenance of holdings in foreign companies.
All the dividends received by these Andorran holding companies, and the results that they obtain from transfers of holdings in other companies, are exempt from taxation in Andorra.
Profits distributed by the holding companies to their shareholders, with a charge to the exempt income, are exempt from Corporation Tax on the member when it is an Andorran company.
COMPANIES FOR THE INTERNATIONAL EXPLOITATION OF INTANGIBLES
These are Andorran companies which are active in the international exploitation of intangibles, that is to say, which make concessions for use, grants or licences of rights, transfers of assets, goods or rights over: patents, designs, industrial models and drawing, trade marks, domain names, plans, secret formulas or procedures, literary, artistic or scientific works, applications, computer systems and rights connected with copyright.
Fiscally, these companies have a tax treatment which means a tax rate on their profits of approximately 2%.
These companies have the obligation to:
• Exploit the assets in their own name in the framework of their financial activity
• Employ one person for at least half days and have premises for exclusive use with a minimum area of 20 square metres, in Andorra
• Ensure that the assignee of the rights of use uses these rights in the development of some type of economic activity and that the results of this use do not generate tax deductible expenses in the assignor entity when they are linked entities
• That the assignee of the right is not an entity or individual resident in Andorra for tax, and that the right is not used directly in the Principality
These are Andorran companies active in international trading in goods and as commission agent or intermediary in general in international trade in goods and any other type of assets, including real estate, located outside Andorra.
For tax purposes, these companies have a tax treatment which means that the tax rate on their profits is approximately 2%.
• That the receiver of the services uses these services in the development of some type of economic activity and that the results of this use do not create tax deductible expenses in the entity providing the service when they are linked entities
• That the receiver of the services is not an entity or individual tax-resident in the Principality of Andorra and the service is not used directly in the Principality
These are Andorran companies whose activity is obtaining loans from linked entities or third parties which, together with their share capital, are used in the making of loans to linked entities non-resident for tax in Andorra.
Intra group management and financial investment companies can also carry out activities of:
• Management and investment of their own treasury or of linked entities non-resident for tax in Andorra
• Services of invoicing, leasing and management of receivables and payables with other linked entities non-resident for tax in Andorra
• Cover of exchange risks in the group
• Issues of bonds, preference holdings and other instruments which can be used to recruit resources for the group in the international capital markets.
For taxes, these companies have a tax treatment which means that the tax rate on their profits is approximately 2%.
The minimum share capital for this type of company is 250,000 euro and they must employ one person for at least half days and have premises for exclusive use with a minimum area of 20 square metres, in Andorra.
Copyright © 2019 ABC Assessors i Consultors. All Rights Reserved.
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redpajama_set_name: RedPajamaCommonCrawl


text:
An Ideal Adventure (Italian: Sballato, gasato, completamente fuso) is a 1982 Italian comedy film directed by Stefano Vanzina and starring Edwige Fenech, Diego Abatantuono and Liù Bosisio.

Cast
 Edwige Fenech as Patrizia Reda
 Diego Abatantuono as Duccio Tricarico
 Liù Bosisio  as Orietta Fallani
 Mauro Di Francesco as Pippo - De Pino's valet
 Enrico Maria Salerno as Eugenio Zafferi
 Cinzia de Ponti as Zafferi's Daughter
 Stefano Gragnani  as Office Boy
 Peter Berling  as Brian De Pino
 Maria Rosaria Spadola
 Sandro Ghiani  as The Zookeeper
 Giorgio Giuliani  as Giorgetti - Patrizia's colleague
 Ivana Milan as Claudia - Zafferi's Second Daughter
 Annibale Rocco

References

Bibliography
 Roberto Chiti & Roberto Poppi. Dizionario del cinema italiano: Volume 5. Gremese Editore, 1991.

External links

1982 films
Italian comedy films
1982 comedy films
1980s Italian-language films
Films directed by Stefano Vanzina
Films scored by Detto Mariano
1980s Italian films

redpajama_set_name: RedPajamaWikipedia


In order to fit piping into smaller spaces, the use of pipe fittings is necessary. However, there are often mistakes made when choosing the proper fittings. Because these mistakes can cause delays and add to the cost of the project, double checking all of these components will help to ensure a proper fit.
One of the big mistakes that ares made when ordering Pipe Fittings is to order the wrong type of metal. It is relatively easy to confuse the colors of stainless steel and steel or brass with copper. Because the materials have different expansion and contraction properties, the wrong metal can cause leakages to develop, a rapid deterioration of the piping around it or could cause a complete blowout of the piping. The metal used for the piping must be the same as the metal used for the fittings in order to preserve the integrity of the system.
Another big mistake made is not ordering the proper angle for the fittings. Since fittings are used to maneuver piping around objects, getting the angle degree right is critical. If a weird angle is needed, the piping itself may have to be reworked to accommodate one of the common angle fittings. Ninety degrees and forty-five are the most common angles used in piping systems. The angle that is needed will depend on the space for the piping and the overall configuration.
Picking the Pipe Fittings with the wrong connectors is another mistake that is made when ordering. The connections on both sides of the fitting have to be the opposite of what is on the piping. This is so that the fittings will attach to each other. If the fitting connections are exactly the same as the piping connections, you will be unable to hook the two pieces together.
These are a few common mistakes made when ordering fittings. These mistakes can cost time as new parts are ordered. It can also cause delays since it can take time for the parts to come in. To help avoid these common mistakes, contact Ameriflex Hose and Accessories for advice on the type of fittings that are needed.


After years of using rheological testing to engineer better products for our customers, SNP now offers services that allow our customers to do the same. Through our Rheological Testing Solutions, we can provide any testing for any of your material or formulating needs.
We have extensive experience testing a wide variety of polymers, plastics, pseudo plastics and composites. Our rheologists can also reengineer and reformulate your materials to improve their rheological performance. At SNP Inc., we value our client relationships and work hard to be a beneficial partner in their research endeavors. All work is strictly confidential, and we are fully prepared to perform your rheological tests under a signed secrecy agreement.
Rheology is the study and characterization of the flow of materials. Most people think of fluids in terms of viscosity but some fluids are viscoelastic. Viscoelastic materials exhibit both viscous and elastic behavior when experiencing deformation.
How Can Rheology Testing Help?
Whenever elastic materials are placed under stress, the strain is exhibited instantaneously as is the recovery when the stress is removed. Because viscoelastic materials have both elastic and viscous properties they exhibit time dependent strain. By analyzing both the fluid and elastic properties of a material, we can predict the reaction of these materials when subjected to these external forces. While some materials will flow when subjected to force, others will resist or will experience deformation then recovery.


text:
Habitus and Social Science: a Virtual Roundtable
habitus beyond sociology
Following our ground-breaking special section on the habitus beyond sociology, published in February this year, we invited some of the contributors to undertake a dialogue for our blog. Elizabeth B. Silva, Helene Aarseth, Sam Friedman, Lynne Layton and Muriel Darmon discuss some of the key issues addressed in the special section.
Why is the habitus an important concept for the social sciences?
Elizabeth: The concept of habitus offers guidance for social theory to historicize and denaturalize the social world. It refers to how the past – of an individual, or of a field – shapes the present and how this conditions future possibilities.
Habitus is a highly debatable concept, the current debate showing lots of ambiguities originating from Bourdieu's own imprecise and shifting uses of the notion. I map this out in my paper 'Unity and Fragmentation of the Habitus'. From this mapping I show two key features of the notion of habitus which are elaborated about in this Special Section: (1) that subjectivity, and ways of accounting for its relationality with the social world, occupied large space in Bourdieu's theorizing (e.g. in Pascalian Mediations), and in his empirical investigation (e.g. in The Weight of the World); (2) that social change is accounted for in recognition of the passing of time and shifts in diverse field engagements both at individual level and in how fields connect over time.
It is difficult, however, if not impossible, to explore the notion of the habitus with no reference to the other strongly related notions of field and capital. Habitus provides both an account of what one does within a field in a context of values and valuation (which are intrinsic to the notion of capital) and also an account of the limits/constraints within this field/value/valuation context.
Lynne: Habitus, as described by Bourdieu, is one of very few key concepts in sociology that can illustrate the complexity of the synchronic and diachronic links among the psychological, historical, and sociological. It is also one of the few sociological concepts to acknowledge and respect the power of unconscious process. As shown in our contribution, 'Conflicts in the habitus: the emotional work of becoming modern', a generation's habitus can be passed down even in dramatically changing social circumstances. Thus, the concept captures the hold that embodied conscious and unconscious practices and feelings have on the psychosocial character of later generations. Our extension of Bourdieu's recognition of the conflicted nature of one's habitus shows, too, that emotionally based conflict, combined with broad socio-cultural changes, can contribute both to changes in habitus and to its reproduction.
Sam: I am particularly interested in exploring how habitus may be a useful concept for social mobility researchers. This largely quantitative research community has largely ignored the work of Bourdieu, with influential proponents like John Goldthorpe writing off concepts like habitus as deterministic and almost antithetical to social mobility. However, as I and others in this volume note, Bourdieu's conception of social space was constructed along three dimensions – volume of capital, composition of capital and'change in these properties over time'. Thus he did have a theoretical conception of social mobility in the habitus – as a 'band of more or less probable trajectories' based on one's 'volume of inherited capital'. Indeed there are two key ways in which habitus can enhance existing sociological understandings of social mobility. First, habitus allows for a much more sensitive understanding of the relationship between time and social mobility. Standard quantitative mobility research usually involves inspecting standard mobility tables, comparing origin and destinations taken from two points in time, and measured with a single occupation-based variable. This approach has obvious merits, notably in allowing a form of standardisation which permits comparative analysis. However, there are fundamental limitations to rendering time in this linear way, not least the fact that it conflates occupational 'access' with class 'destination' and fundamentally elides the stickiness of one's class origin. In contrast, habitus represents a much more temporally-sensitive tool – allowing us to conceptualise how the capitals that flow from class origin can shape mobility trajectories well beyond occupational entry. I have explored this in recent work that has highlighted the existence of significant class-origin pay gaps in top occupations. Second, and linked to this, habitus allows for a more fruitful integration of the objective and subjective features of social mobility. In this way, habitus allows us to understand the long shadow of class origin not just in terms of material outcomes but also in terms of identity. Here, as my article probes, the identities of the mobile tend to always carry – at least in some form—the symbolic baggage of the past, and this historical imprint often has important consequences for how they act and feel in the present. My analysis thus illustrates the struggles the long-range upwardly mobile face in gaining acceptance in their 'destination' social group, but also the emotional labour required to marry this with maintaining connections to their 'roots'.
How can our theorisation of the habitus be extended?
Elizabeth: Because habitus combines the idea of action guided by unconscious, invisible, mechanisms, and guidance by common rules linked to autonomous and conscious decisions, I think that attention to how the unconscious is patterned socially and how rules are devised and followed – with attention to general principles and historical changes – can productively assist our theorization of the habitus.
Helene: Bourdieu's concept of habitus offers a notion of a subject that escapes autonomous and transcendent conceptualizations, yet without resorting to the de-corporealization evident in much constructivist and deconstructivist approaches. Also, habitus may provide a conception of libidinal attachments that does not resort to a notion of affect as a non-signifying force or intensity, as is the case in some strands of affect theory. Bourdieu's habitus is 'socialized subjectivity' that emerges in praxis, as a product of the interaction between body and environment and as a way of responding to and investing in these environments. I am particularly inspired by feminist interpretations and developments of Bourdieu's concept, such as for instance Diane Reay's and Lois McNay's. McNay provides a reading that emphasises the hermeneutic dimension involved in the habitus and field-interaction, arguing that the dialectic of subjective and objective structures must involve interpretations and intentional dimensions. If the sedimentations of practices and experience that in Bourdieu's conception hold together and drive the socialized subject involve interpretations and intentionality, then 'socialized subjectivity' is something more than effects of processes of subjection.
Lynne: Bourdieu only occasionally recognizes the dynamic nature of the unconscious, that is, the centrality of conflict in motivating not only the reproduction but the evolution of habitus. His relation to psychoanalysis was ambivalent, possibly because, in his day, the dominant psychoanalysis in France was Lacanian. Our paper draws on relational and object relational psychoanalytic theory, which we think is a better fit with the concept of habitus than other versions of psychoanalysis. We explore relational dynamics in families, socially and idiosyncratically produced conflicts that have to do with class, gender, and other social norms.
What resources can we find outside of sociology to provide for this extension?
Elizabeth: Because other disciplines have developed more resources to understand these matters of the invisible and the unnoticed, I think that learning from specific branches and theoreticians in psychology and psychoanalysis (about the unconscious) and also from philosophy (on rules and ordering) could be productive to sociology to extend the understanding of the habitus both in theory and empirically. This doesn't mean that the sociological stance would be abandoned at all. I'd think about using these resources sociologically. For instance, with questions about the social nature of the unconscious. This is about drawing from various resources to make social matters visible.
Helene: In my efforts to develop a practice-theoretical notion of emotional investments, I suggest that Bourdieu's notion of 'investment in the psychoanalytic sense' could be developed further by taking inspiration from non-antagonist notions of desire and culture, evident for instance in Donald Winnicott's idea of transitional experience as a motivational force, and developed by Christopher Bollas' idea about the transformational object that the subject are attracted to because it represents a potential for self-transformation. In one of the articles in the Special Section, 'Eros in the field? Bourdieu's double account of socialized desire', I suggest that Hans Loewald, perhaps less well-known in the UK, is particularly interesting to consider. To Loewald, the motivational force evident in the transitional experience is not limited to the child's urge to seek relief from helplessness and dependence, but constitutive of our way to perceive and relate to the world. In Jonathan Lear's formulation, Loewald's transitional experience is an erotic force 'by which ego strives to keep itself connected to the world from which it is differentiating itself'. It is this romantic notion of the relationship between subject and the world, evident in the German tradition and most often linked to the early Marxist notion of praxis, what I wanted to retrieve – although such romantic notions would probably be problematic to Bourdieu himself.
Lynne: As mentioned above, we believe that the concept of habitus can be extended by rethinking it through such psychoanalytic concepts as the unthought known, enigmatic signifiers, and the intergenerational transmission of trauma and of other emotional ways of being. Habitus can also become alive via psychoanalytic understandings of how inequalities of class, race, gender, and sexuality are lived, consciously and unconsciously, how they mark the body, mind, and ways of interacting with others in defences such as disavowal and identification/disidentification. Basic psychoanalytic concepts of repetition compulsion and resistance are central to understanding the hold of habitus.
Muriel: In my view we should be cautious not to jump too early 'outside of sociology', even to explain things that seem to lie beyond sociology's traditional scope! Don't sociologists have an epistemological duty, and even a right to be sociologists? Such a stance dates back to Durkheim and his Suicide, and I try to show in my article that it is still the epistemological backbone of Bourdieu's position towards psychoanalysis, even if other interpretations may go in the exact opposite direction.
How can the habitus be captured empirically: challenges and ways of doing it (in your own work and other suggestions?)?
Elizabeth: The empirical engagement with the concept of the habitus is a challenge for the ways in which we do sociology. It's interesting that Bourdieu conceived of a sociology that strongly combines theory and the empirical. The development of concepts only make sense when directed to understand the social world. Research sensitivity is required to capture habitus. While it is possible to ask direct questions in a questionnaire about tastes and practices, their origins and developments, in order to sketch a habitus within some field, by a particular social group, the resulting knowledge would best be expanded by an ethnographic or biographical narrative sort of research engagement within a temporal exploration. Multi method explorations are always to be preferred when addressing matters of great social complexity as this one of the habitus.
Muriel: This is certainly a tricky question. Habitus is an 'unobservable': a scientific construct that can't be observed directly and which is the supposed matrix of phenomena we actually can spot, like practices, behaviours, attitudes, representations, etc. How can we offer evidence of the existence of something that we can't see?
What I have tried to do (for example in my research on anorexia) is to 'grasp' the habitus by analysing cases where it is transformed, or worked upon. It therefore becomes more visible than when it just 'exists' or 'actualizes' itself. The construction of an anorexic habitus during the anorexic career becomes visible through the work on dispositions displayed and described by the interviewees (the way they write the rules and reflexes of the diet into their very bodies, the way they work at getting a taste for certain food and for certain physical sensations). It also becomes visible through the counterwork on the anorexic habitus that takes place in the hospital, as I show in my article 'Bourdieu and psychoanalysis: an empirical and textual study of a pas de deux'.
I do think it is possible to capture empirically the habitus through interviews. They are a good method to observe ethos and dispositions regarding self-presentation, but also to cautiously collect accounts of practices. Repeated interviews over time – longitudinal work – with the same participants are an even better method to grasp transformation and reproduction of habituses and dispositions. But to me the best method is probably to use observation (combined with interviews), to notice dispositions in context and come the closest to actually observe habituses at work.
Lynne: Our paper attempts precisely to trace the ways habitus changes and stays the same over time, and we have done this via analysis of qualitative multi-generational interviews that take up such questions as what relations are like with mothers, fathers, peers, husbands, wives; what emotional conflicts are worked through in ways that challenge a passed down habitus, and what emotional conflicts contribute to its repetition/reproduction.
Is the conception of the habitus shaped by psychological and psychoanalytical influences?
Elizabeth: The richness of the concept of the habitus is in linking individual/personal ways of doing things with social matters, cultural issues. In a nutshell: in what ways is our free will implicated in our choices about how we live our lives. In truth, there is a lot we do not know about what we do, and this not knowing gives a larger meaning to our actions.
There have been explorations by sociologists about the influences of psychology and psychoanalysis in Bourdieu's development of the concept. I map these out in my paper 'Habitus Beyond Sociology'. I identify three main legacies from my investigation about sociologists' explorations of the issue. These are from Jean Piaget, from Lev Vygotsky and also from Jacques Lacan. From my reading and discussion of these influences I found the two latter ones more plausible, although Bourdieu has not made explicit his allegiance to any of these theories.
In the SS I discuss these legacies, but more importantly, my fellow colleagues Helene Aarseth, Lynne Leyton, Harriett Nielsen and I, in three of the papers, engage with a proposal to extend the trajectory in Bourdieu's theory of the habitus by considering the 'intangibles' in the habitus in relation to the work of two other psychoanalysts: Hans Loewald and Christopher Bollas.
From Loewald, for instance, a fresher way of understanding the integration between outer and inner worlds is worked out in relation to increasing complexity of experience – in this, psychic change is fundamental for personal growth, for making connections between past and present, conscious and unconscious encounters with culture. Desire, or what we like, is at the centre of the choices we make, the encounters we have. The question thus is what is it that we come to desire? Interestingly, the appreciation of desire is orientated by the field. Desires that matter in some fields may not matter in others.
From Bollas some rich qualifiers to the notion of the habitus appear. He refers to our existence being in a high proportion determined by a 'not-cognitively apprehended' 'unthought known'. This refers to the articulation of internal and external realities that become part of our ways of living, from which and through which we sense, feel, observe, make sense of things… This implies an aesthetic sense, a mode of being. This unthought known is implicated in desire for change and in anxiety about change.
Originally posted 9th June 2016.
Bev Skeggs Discusses the Contemporary Sociological Imagination with Les Back
The Sociology of Love
Working Life Coaching and the Individualization of Class


Are you a member of the Ulster Heritage DNA project?
DNA Day Sale has begun! Below is a list of pricing for the sale. DNA Day Sale ends Thursday, 4/25/19. Important: The upgrades that are discounted are from Y-STR testing to Big Y-700 or from Big Y-500 to Big Y-700. The prices below are for new kits or for add-ons to existing kits, not for upgrading STRs or mtDNA.
Jack McCauley has a question!
While perusing a large published reference book (much like a history of a family history) concerning one of my direct family lines, I came across entries for two families with direct ties to Northern Ireland. As far as I know, these two families are NOT in my direct line, but thought they might possibly connect with others on this site. With the caveat that I cannot confirm the veracity of the information, I will post exactly as is written in the book. Family #1: JOHN McCUE of Ireland. John McCue, Jr. born Ulster, Ireland ca. 1680 -1690; m. SARAH MCDOWELL John was son of JOHN McCUE, Sr. (b. ca 1650 - 1660), who married MARY MOFFETT, and according to tradition, being of the Covenanter Stock, joined the tide of immigration that flowed into Northern Ireland. Issue John Jr. and Sarah McDowell McCue: John McCue b. ca. 1715-1720. Moses McCue, Sr. his descendants are in Ohio and Kentucky. Sarah McCue b. Ulster, Ireland m. James McElroy. David McCue b. Ulster, Ireland, settled in Pennsylvania. Mary McCue. JOHN McCUE b. ca. 1715 - 1720 d. Virginia 27 Oct 1798 , m. ca. 1750 ELEANOR MATHEWS, after he landed on American shores. John McCue left Prince of Wales, Northern Ireland and settled in Lancaster Co., PA in 1731. Because the jealousies rising in the minds of the original settlers, restrictions were made so oppressive on the Scots-Irish that many moved up the Great Valley of Virginia and settled in Goochland Co., afterwards called Albemarle, then Amherst and now Nelson.
Family #2: WILLIAM MONTFORD of Ireland and Wise County, Texas. WILLIAM MONTFORD b. County Antrim, Ireland 1851; d. 1932; buried Old Town Cem., Bridgeport, TX; m. in Ireland 1875 JANE HOLDEN b. County Antrim 1860, d. 1935, buried Old Town Cem. It is said that William Montford was the eldest of seven sons and one daughter. He and Jane Holden attended the same social gatherings and worshiped in the same 200 year-old Presbyterian Church near Broughshane in County Antrim. She was 15 years old when they married, and that same year William emigrated to America, where a relative name McALLISTER was living in Chicago. When Jane joined her husband, she left behind her father, who was at one time a member of the Irish Regiment of the Queen's Royal Guard, her mother, three sisters, and four brothers. William and Jane had a second marriage ceremony in Chicago, possibly to satisfy immigration officials. They settled first in Illinois before moving by wagon to Kansas, where they built a sod house and William worked for the railroad. They soon moved to Blossom Prairie, Lamar County, TX. They soon ventured on to Wise Co., Texas where William and Jane settled in the Pleasant Valley community where they bought land in 1893 and a second tract in 1902. He was a skilled farmer and Jane an excellent homemaker. In 1975, the Montford homestead of 179 acres was still held by descendants.
Well, All I can tell you is there are some Aiken's in Transylvania County, North Carolina and Greenville and Pickens South Carolina that came here from Pennsylvania. Also a Gowan family in North Greenville County, SC some of my ancestors.
We have picked up on William Aiken and Martha Burnside as being a part of a particularly devout group of Presbyterian Conventers.
We are still on the assumption that William is a brother or First Cousin of Adam McGowan's biological father.
Gedmatch is currently automatically transitioning everyone to their Genesis system. Their original software was not compatible with newer DNA formats. Your IDs should have been automatically moved over. For starters do the "One-To-Many DNA Comparison Result". Try to isolate your results into your Fathers side and your mother's side. You can do the "People who match both, or 1 of 2 kits" to help isolate this. You will need two IDs to do this: first your ID and then the ID you want to compare with. The results will show you who matches both of you. Here it gets more detailed. You check the check boxes of the people you want to compare. Next page I usually select Visualization options.. Next page I usually select Seg-Srch. You will now see colored bars representing positions on chromosomes you match at and the length in cM (centimorgan) of the match. Every one of your matches inherits cM from each parent on one or more chromosomes. If you isolate your father from your mothers matches then you can try to isolate your father's father from your father's mother. Very close relatives will match on more then one Chromosome for a longer length. Most people out at the 4th generation or greater will match on only one chromosome for a length greater then 7. The concept is to organize family groups by chromosome. Gedmatch originally showed matches who had a family tree called Gedcom. They haven't migrated Gedcom into their matching for Genesis yet. The new privacy rules introduced at the end of last year required them to automatically mark parts of the Gedcom family trees as private. A lot of this data was not private before. I'm not sure if Gedmatch is working to improve their handling of privacy or not? It seems it was easier to instill more privacy then required to keep the system running. So Gedmatch is playing catchup with new DNA types through Genesis and new privacy concerns in their handling of Gedcoms. There is also now law enforcement activity and other activity. I.e. I have matches which pop up one day then disappear 12 hours later. I think Gedmatch has referred to these as some kind of research activity. I have used the compare two person match with these and found theses IDs have 1000s of 1st cousins. I think someone is hand coding raw data files and running them against Gedmatch. The best thing is to start basic and try something more complex a little at a time as you gain comfort using the tools.
I have also uploaded my FTDNA raw data to www.myheritage.com (for free) which seems more user friendly. However they keep trying to sell you various genealogy upgrades. One advantage of this site is that I appear to get quite a few matches outside the USA. You can search for matches filtered by country (Ireland, Scotland, England, Australia etc).
Thanks Richard - I noticed the migration to Genesis from Gedmatch, and I still need to explore the site more to get an understanding of how it works. I have done some comparisons, but for some reason I am not comfortable reaching out to users. I was contacted by one person trying to find information because they were adopted, I really felt badly because I couldn't offer much information to them that was helpful. I haven't uploaded my FTDNA results to myheritage.com, I wonder how it will affect the results they already have. Did you upload just the YDNA or also the mtDNA results? I will have to look into that, thank you.
MyHeritage upload is just the FTDNA family finder or other autosomal DNA data. I believe MyHeritage is soon going to quit giving ethenisity analysis from free uploaded data but will still give free DNA matching. Also if you upload a Gedcom type family tree they will separately match you against other Gedcom family trees uploaded into their network. It surprises me how many family tree matches I get who haven't gotten a DNA test (either at their site or uploaded free from another site like FTDNA). I usually only email people who I have a very strong match with or I know the relationship. I've actually gotten photos of my ancestors from contacts (photos of my great grandparents and my grandfather and his brothers and sister's on my father's side). I did get one match who emailed me about a pre 1740 match. His Bourland family is documented in a book "Bourlands of America". My Bourland family from Augusta County Virginia is listed as possibly connected to theirs in the back of the book. Since I match him on the same Chromosome and location as other known Bourlands there is a high probability we are related. I have a good paper trail from my ancestor who was shot and killed in 1761 as Sheriff of Augusta County Va. The Bourland book written in the 1800s documents the Bourland family to Ireland and Scotland.
My DNA tests confirm that two branches of my family are from Northern Ireland (Davidson and Drake). I have had no luck finding any birth or death records from my GGF Patrick Drake, other than his marriage certificate from Downpatrick in 1853. I am not sure where he was born in NI. Any suggestions are appreciated.
Have you tried the Ros Davies website? Lots of information about County Down families.
Thanks, I did see the site and found it helpful.
Thanks, John. I wasn't aware of the site.
While it doesn't appear that we are related, we sure do have a lot of common surnames: Adams Baker Craig Evans Harmon Lewis Miller Mitchell Parker Wallace Wilson Wright If you click on my name you will see all of our common surnames in our trees. I have a great great grandmother Wright born in 1879 in PA who's father Henry Wright was born in 1843 in England. He then at some point came over to Pennsylvania.