My observation of Japanese schooling is that it seems to no longer (if it did? I think it did, could be wrong) push everyone to go to university and become a salary(wo)man. I observe all sorts of school trips to construction sites, fields, forestry operations and the like. Now admittedly some of that is lot easier when you are in small town/rural Japan but it seems to be a thing. My nephew, for example, is now a few months into his first job working for a house-builder aged 18. No attempt to apply to university. His elder sister did go to university but she picked a course to make her a social worker and got that job as soon as she graduated last year, so her university education was potentially practical.
I think this type of lesson is extremely important. I think I also did get some training for it in elementary school at some point. This is the big problem is it not? Discerning between fact and opinion. Is it a fact that masks and respirators work? Let's see what we can infer by reading the accompanying documents with the mask/respirator and determine what the facts are.
This is also a great subject for a children's book, where you have the narrator, the main character of the story, making assertions about what is happening, and that is not what is happening in the story. It not only shows kids about reality vs. perception, but opinion vs. fact.
Very true. I'm involved in tax controversies and both sides have opposing opinions citing different case law. The judge rules in favor of one of the opinions, which is also an opinion. The case is then subject to reversal at appeal. It's all opinions. Generally, the only facts are the parties involved and the monetary calculations.
Yep. And I know in the legal profession, precedent has a lot of weight to it, like in similar fashion, the multitude of those sharing an opinion adds weight to it for some reason, but in the end it is just opinions all the way down.
Reading and writing these opinions is really terrible. I wish I would have picked something else. Demolition maybe? Thankfully, I am going on half retirement at the end of the year and full retirement in 25.
I have a friend who is a folk singer, but before that he was a tax attorney. He told me that I have no idea what "drink like a lawyer" means until you are a tax attorney. I don't doubt it.
No FATCA Cases. I read the substack wrote about the Moore case a couple of weeks ago. It compelled me to read the opinion. You are correct, corporate income is double taxed, but it always has been. The corporation is taxed directly by the source country and the shareholder is taxed when they receive a dividend. (same income taxed 2 times). Up until 2017 that is. In 2017 congress passed the mandatory repatriation act which taxed all the accumulated earnings of US controlled foreign corporations income as deemed dividends to the shareholders. Every year after that the foreign corporations income is taxable to the shareholder as a deemed dividend. Moore argued that the US can't tax income that has not been received. In most cases that is true. The government argued they have been taxing deemed dividends via Subpart F income since the Kennedy administration. That is also true. The court sided with the government. Then when the shareholder eventually receives an actual dividend payment they can offset the dividend income with the previously taxed income. So the foreign corporation's income is not taxed a third time. Still just double taxed. For the initial 2017 repatriation year the government allowed the shareholders of US controlled foreign corporations to pay the tax in installments over 8 years. The mandatory repatriation tax effected every US multinational corporation. All of them. 2018 was the craziest year ever for me until the panic hit. Another point, if the US shareholder is a resident of a foreign country and if the foreign country taxes the dividend income, the shareholder should be able to tax a foreign tax credit in the US. Anyway, that should make everything totally clear, right?
Not quite as simple as that. First, offsetting taxes paid to local, nonUS governments often depends upon the tax treaties in place between the countries involved. Treaties need not be updated to match new laws and generally aren’t updated until enough people adversely affected make enough of a stick for the tax treaty folks to place on their agenda for the next treaty conference, which I believe generally meet every 5 years. Then there is the ‘savings clause”.
The MRT also affects small corporations. Many use them for retirement funds outside the U.S. Exactly how, I do not know as I do not have my own incorporated business, but friends of mine do. My Canadian friend who does currently has no worries about this, but my American friends do.
For me personally, it has never been about having to pay any tax to the U.S., I do not earn enough. It is the tax of time, the reporting and especially the reporting on third parties’ finances to the U.S., which is in violation of Japanese law.
I learned sewing in school and it has been useful my entire life. Also, fact and opinion can be difficult. I now make a living writing legal papers and fact vs opinion is always an important issue.
I learned sewing through reenacting and fine tunes while in the navy. Very useful skill. Did you learn it in school in the U.S.? I have never heard of it taught in U.S. schools except in home ec.
IDK, 1 of my sons took cooking in middle school and that class did not include any sewing. I taught my sons to sew myself. I work with a woman that went to school in Russia and she learned sewing, outdoor survival skills and how to use and maintain an AK-47. Conversation with her is interesting.
Somewhat related
My observation of Japanese schooling is that it seems to no longer (if it did? I think it did, could be wrong) push everyone to go to university and become a salary(wo)man. I observe all sorts of school trips to construction sites, fields, forestry operations and the like. Now admittedly some of that is lot easier when you are in small town/rural Japan but it seems to be a thing. My nephew, for example, is now a few months into his first job working for a house-builder aged 18. No attempt to apply to university. His elder sister did go to university but she picked a course to make her a social worker and got that job as soon as she graduated last year, so her university education was potentially practical.
We live just outside Tokyo and the kids have gone on school trips to farms and industrial sites here too.
I was not aware that the stopped pushing for college but am glad if they are.
That's WONDERFUL!! Very heartening.
It was and is. Quite unexpected on my part.
Those are the best ones - shows you you're still open and still learning. xo ❤️
True.
I think this type of lesson is extremely important. I think I also did get some training for it in elementary school at some point. This is the big problem is it not? Discerning between fact and opinion. Is it a fact that masks and respirators work? Let's see what we can infer by reading the accompanying documents with the mask/respirator and determine what the facts are.
This is also a great subject for a children's book, where you have the narrator, the main character of the story, making assertions about what is happening, and that is not what is happening in the story. It not only shows kids about reality vs. perception, but opinion vs. fact.
Very true. I'm involved in tax controversies and both sides have opposing opinions citing different case law. The judge rules in favor of one of the opinions, which is also an opinion. The case is then subject to reversal at appeal. It's all opinions. Generally, the only facts are the parties involved and the monetary calculations.
Yep. And I know in the legal profession, precedent has a lot of weight to it, like in similar fashion, the multitude of those sharing an opinion adds weight to it for some reason, but in the end it is just opinions all the way down.
Reading and writing these opinions is really terrible. I wish I would have picked something else. Demolition maybe? Thankfully, I am going on half retirement at the end of the year and full retirement in 25.
I have a friend who is a folk singer, but before that he was a tax attorney. He told me that I have no idea what "drink like a lawyer" means until you are a tax attorney. I don't doubt it.
I did for the money, wasn't worth it.
Oh, that's funny, I get it!
Precisely!
At least they call them opinions.
You ever work on FATCA cases?
No FATCA Cases. I read the substack wrote about the Moore case a couple of weeks ago. It compelled me to read the opinion. You are correct, corporate income is double taxed, but it always has been. The corporation is taxed directly by the source country and the shareholder is taxed when they receive a dividend. (same income taxed 2 times). Up until 2017 that is. In 2017 congress passed the mandatory repatriation act which taxed all the accumulated earnings of US controlled foreign corporations income as deemed dividends to the shareholders. Every year after that the foreign corporations income is taxable to the shareholder as a deemed dividend. Moore argued that the US can't tax income that has not been received. In most cases that is true. The government argued they have been taxing deemed dividends via Subpart F income since the Kennedy administration. That is also true. The court sided with the government. Then when the shareholder eventually receives an actual dividend payment they can offset the dividend income with the previously taxed income. So the foreign corporation's income is not taxed a third time. Still just double taxed. For the initial 2017 repatriation year the government allowed the shareholders of US controlled foreign corporations to pay the tax in installments over 8 years. The mandatory repatriation tax effected every US multinational corporation. All of them. 2018 was the craziest year ever for me until the panic hit. Another point, if the US shareholder is a resident of a foreign country and if the foreign country taxes the dividend income, the shareholder should be able to tax a foreign tax credit in the US. Anyway, that should make everything totally clear, right?
Not quite as simple as that. First, offsetting taxes paid to local, nonUS governments often depends upon the tax treaties in place between the countries involved. Treaties need not be updated to match new laws and generally aren’t updated until enough people adversely affected make enough of a stick for the tax treaty folks to place on their agenda for the next treaty conference, which I believe generally meet every 5 years. Then there is the ‘savings clause”.
The MRT also affects small corporations. Many use them for retirement funds outside the U.S. Exactly how, I do not know as I do not have my own incorporated business, but friends of mine do. My Canadian friend who does currently has no worries about this, but my American friends do.
For me personally, it has never been about having to pay any tax to the U.S., I do not earn enough. It is the tax of time, the reporting and especially the reporting on third parties’ finances to the U.S., which is in violation of Japanese law.
And, in the example you give, it gives a lesson on reporting too.
I learned sewing in school and it has been useful my entire life. Also, fact and opinion can be difficult. I now make a living writing legal papers and fact vs opinion is always an important issue.
I learned sewing through reenacting and fine tunes while in the navy. Very useful skill. Did you learn it in school in the U.S.? I have never heard of it taught in U.S. schools except in home ec.
Yes, in the US. I was part of Home Economics. It was the only part of my entire education that was easy, fun and useful.
Ah, well there you go.
I surprised sewing machine manufacturers haven't tried to sell machines to school districts. Seems like it would be a profitable business plan.
I’m sure they did in the past. Is home ec even allowed to be taught stateside these days?
IDK, 1 of my sons took cooking in middle school and that class did not include any sewing. I taught my sons to sew myself. I work with a woman that went to school in Russia and she learned sewing, outdoor survival skills and how to use and maintain an AK-47. Conversation with her is interesting.
I am blown away by this info!
Next, they will endorse Donald Trump! (Naw, couldn't go that far, could it?)
The school or the Japanese public? I take it you know of the rallies they held in Japan for Trump back in 2020?
https://www.youtube.com/watch?v=FWnF8t3lzuY
https://www.youtube.com/watch?v=3XF5M2Jn3p0
Yes, it is a public school.
I know that there have been rallies for T here, but exactly when and where I don’t know.