The Dive With Jackson Hinkle Published originally on Rumble on December 16, 2022
The Ukraine is in deep trouble
MAJOR BLACKOUTS In Odessa, Ukraine
Category U. S. Uni-Party Insurrection
The Background What Mainstream Media Refuses to Report
January 1st, 2023 Tax on ETFs
Armstrong Economics Blog/The Hunt for Taxes Re-Posted Dec 16, 2022 by Martin Armstrong
QUESTION:
Hi Marty,
Please help as I invest in mostly ETFs from Australia.
I was getting USD exposure but now looks to be ending by Jan 1st, 2023.
I was Informed 2 days ago.
Could you do a post about this and any potential workarounds as I’d take a guess a lot of International clients would have a similar issue.
The US Internal Revenue Service (“IRS”) has issued a new provision under Section 1446(f) of the Internal Revenue Code (“IRC”) that primarily impacts non-US Persons who invest in US PTP Securities. With effect from 1 January 2023, non-US Persons will incur a 10% withholding tax on gross proceeds from sales or trading of US PTP Securities.
Regards Dean
ANSWER: This is once again the Biden Administration hunting every possible dime it can find while handing endless billion to Zelensky who may be on track to become the richest corrupt politician in the entire world. This is the notice going out to all foreigners investing in the once land of the free and home of the brave which has been downgraded to the land of the absolute fools without the hill. One bank has sent this to their clients trading in US ETFs.
Dear Customer,
Withholding Tax of 10% – Publicly Traded Partnership Interest (PTPs)
With effect from 1 January 2023, a 10% withholding will be imposed on sales and certain distributions associated with PTPs or exchange traded funds (ETFs).
PTPs trade like stocks on major U.S. and global exchanges and are often indistinguishable from equities, ETFs and other commonly traded instruments. It is critical that you understand these tax implications when you hold such PTPs and you should seek the appropriate professional advice if you are unsure of the contents of this email.
Background:
The Internal Revenue Code Section 1446(f) issued by the US Internal Revenue Service imposes rules relating to withholding of tax on transfers of Publicly Traded Partnership Interest (PTPs) and will take effect on 1 January 2023. The new rules consist of the following:
· All PTPs, including non-U.S. PTPs, are subject to the new requirements if they have gains that are effectively connected with a trade or business within the United States.
· 10% withholding will be applied to sales and certain distributions associated with PTPs. (Please note that where there is any existing withholding tax being applied today, for example to other distributions, those will continue to be applied with no change/ no reduction)
Please visit _____ official website > Notices for more details.
If you have any further questions, please email us or call our Customer Service line.
Section 1446 (see link) is part of a segment of the Code that governs withholding on nonresident aliens and foreign corporations.
Section 1446 itself deals with withholding on foreign partners who have income that is effectively connected with the US through a partnership. Section 1446(f) adds a withholding requirement that applies to the disposition of partnership interests, but it does not apply if the selling partner provides an appropriate affidavit:
“No person shall be required to deduct and withhold any amount under paragraph (1) with respect to any disposition if the transferor furnishes to the transferee an affidavit by the transferor stating, under penalty of perjury, the transferor’s United States taxpayer identification number and that the transferor is not a foreign person.”
I.R.C. § 1446(f)(2)(A).
I doubt that section 1446 applies here, as my understanding is that ETFs are taxed as registered investment companies, not as partnerships. But I am not an accountant or a tax lawyer. My reading on this text suggests that this turns on the definition of an ETF which is clearly not a partnership.
Those who are being harassed by various banks should contact their legal departments and demand their interpretation as to why suddenly an ETF is a partnership. I would love to see what explanation they have provided to apply this tax. If there is some other code they are overlapping or how they are coming up with this or are they acting out of sheer overcaution? If they will not provide an explanation, I suggest you close the account ASAP or wire out all funds until you find another firm.
Tucker Carlson Bids an Epic Farewell to Adam Kinzinger
Posted originally on the CTH on December 16, 2022 | Sundance
During his opening segment tonight, Tucker Carlson bid an epic farewell to Illinois Republican Adam Kinzinger. This is really, really funny.
I will obey grandmas rule for this one, saying only that Will Rogers never met Adam Kinzinger. WATCH:
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AOC Climate Change Documentary Flop
Armstrong Economics Blog/Climate Re-Posted Dec 16, 2022 by Martin Armstrong
AOC’s four year in the making Documentary of fighting for Climate Change was a complete flop. It debuted in movie theaters around the country and took in $10,000 averaging $80 per movie theater. Of course, the leftist media hail the film, and it was the worst debut of any film in history.Just maybe people are becoming WOKE – walking up to the real propaganda.
US to Hand Patriot Missiles to Ukraine? What Insanity!
Armstrong Economics Blog/Ukraine Re-Posted Dec 16, 2022 by Martin Armstrong
There is little doubt that NATO and the United States want war. I believe this insanity is being driven by the idea that they MUST destroy the Russian economy because it is 50% based on fossil fuels. The people writing the cue cards for Biden are determined to create World War III. Russia has warned that if the US goes ahead and sends Patriot Missiles to Ukraine, they warned that will lead to ‘unpredictable consequences’ and the US knows this will unleash widespread war.
Ukraine is NOT TO BE TRUSTED. They have killed their own people just to keep trying to create World War III where they want Russia utterly annihilated. I cannot stress this more. I have warned that the hatred in this region will engulf the world as it did when the Serbs assassinated the heir to the throne of Austria in 1914. There is NO solution for peace as long as NATO and the US keep supplying arms to Ukraine and instructing them NEVER to negotiate peace.
NATO is doubling its forces in some countries and uses the propaganda that they need to stop Russia’s “Imperistic” advance. The very FIRST Ukrainian coins are those issued by Nazi Germany. They joined the Natiz movement and supported the ethnic cleansing of Jews, Polish, and Russians. Never before was Ukraine a country and the Donbas has historically been occupied by Russians and both Kruschev grew up there as well as Brezhnev.
The very fact that there are NO coins ever issued by Ukraine demonstrates what I have been saying – it was never a country and now we are to engulf the entire world in destruction for the most corrupt country in Europe. There is another agenda here and it is not more truthful than the Weapons of Mass Destruction that Iraq never had.
Tucker Carlson Asks: Knowing What You Know Now – Do You Think the CIA Killed President Kennedy?
Posted originally on the CTH on December 15, 2022 | Sundance
Knowing what we know now about how the U.S. intelligence community operates to control just about everything, I think our nation is more awake than ever before.
Tonight, Tucker Carlson takes the context of the current revelations about the U.S. intelligence community and reopens the discussion about the CIA involvement in the assassination of President John F Kennedy. {Direct Rumble Link} – WATCH:
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Biden Will Pay African Union Additional $2.5 Billion to Stop Africa from Developing Domestic Farm Fertilizer
Posted originally on the CTH on December 15, 2022 | Sundance
The G7 leaders have been debating the problem of African farming for quite a while. The issue surrounds the conflicts between the G7 climate change agenda and the need for Africa to develop fertilizer production to enhance their farming and crop yields.
As noted in a Reuters article from June, “the European Union is divided on how to help poorer nations fight a growing food crisis and address shortages of fertilisers caused by the war in Ukraine, with some fearing a plan to invest in plants in Africa would clash with EU green goals.” As the argument unfolded, “the EU Commission explicitly opposed” any effort to enhance African fertilizer development, “warning that supporting fertilizer production in developing nations would be inconsistent with the EU energy and environment policies.”
The energy development corporations, the source industry needed to create the components for nitrogen-based fertilizer, have been waiting to invest in African energy production pending the approval of western government decisions. Addressing the issue today, Joe Biden told the African Union the United States would send an emergency $2.5 billion in food crisis aid to offset the inability of Africa to feed itself.
In essence, instead of Western government policy supporting energy production in Africa that would lead to a greater farm yield, and by extension a greater level of food independence, the Biden administration would rather restrict energy/food development in Africa and send them food subsidies; because, climate change.
(White House) – […] President Biden announced an additional $2.5 billion in emergency aid and medium to long-term food security assistance for resilient African food systems and supply markets, which builds upon over $11 billion in U.S. humanitarian and food security assistance for this year alone. President Biden also launched a new strategic partnership on food security between the United States and the African Union.
Together, we will leverage the public and private sectors, along with multilateral development banks and international financial institutions to accelerate transformational investments in sustainable and resilient food systems to prevent food shocks before they happen.
The compounding impacts of the global pandemic, the growing pressures of the deepening climate crisis, high energy and fertilizer costs, and protracted conflicts – including Russia’s war in Ukraine – have pushed weak supply chains to the brink and dramatically increased malnutrition and food insecurity — particularly for African countries. (read more)
The Biden administration would rather people starve than be able to feed themselves in order to retain the climate change agenda.
This is globalism and elitism in its full glory. Western politicians, along with multinational corporations, in control of global trade and finance are deciding who lives and who dies according to their climate change ideology. This is how important their Build Back Better scheme is to them.
Liberalism or modern totalitarian leftism is on display as the great global cleaving continues.
The elites in western government think they still have the power to control the rest of the world. However, the absence of food changes things and creates a risk to their agenda.
Many people are starting to realize -through the farming aspect- that western ideology, as manifest in modern globalism, is dangerous. The Davos crowd is willing to kill millions if that is what it takes to retain their climate change ideology.
Keep watching this closely. The multinational U.S. media will continue burying the issue protecting the ruling class.
June 2022, Reuters Article
June 2022 – CTH Outline
December 2022 – White House Announcement
Retail Sales Drop 0.6% in November
Posted originally on the conservative tree house on December 15, 2022 | Sundance
Friends, in the late summer and fall of 2021 CTH warned of massive waves of price increases that would push inflation to record highs. We watched as each wave arrived almost on schedule throughout 2022, and as a direct result of Joe Biden energy and economic policy, prices necessarily skyrocketed.
In essence in 2021 we were warning about the expenditure side of the ledger that all working-class and fixed income families would experience. We advised to take every proactive measure possible to avoid future price increases.
Now, unfortunately, we begin moving those same warnings to the other side of the ledger; because as a natural consequence of consumer checkbook pain, the financial pressure always transfers to the income and employment side of the economic dynamic.
Keep in mind, retail sales are calculated in dollars spent by consumers. November 2022 retail sales as reported by the commerce department today [DATA pdf], reflect a 0.6% decrease in spending vs October. November data includes Thanksgiving, Black Friday and the traditional early holiday shopping. 0.6% less dollars were spent, despite prices being double digits higher than the prior year.
When the prices you are charging for goods and/or services are 10, 20, even as high as 60 percent more than prior year, yet your sales are running flat to negative – that means consumer purchases of those goods/services are substantially lower.
If you were selling 100 widgets for $1 each in 2021, you gross $100. If your widgets now sell for $1.25 and you gross $94 in 2022 sales, you have sold 75 widgets.
In 2021 you sold 100 widgets, in 2022 you sold 75 widgets, a difference of 25 widgets.
Everything attached to the raw material, creation, manufacturing, distribution and sale of those 25 missing widgets is no longer part of the economic activity associated with your widget business. You are now telling your suppliers you don’t need as many widgets, because they are not selling. You have lost 25% of your business in this scenario.
Everything associated with the drop in consumer spending now begins to downsize. Downsizing means less labor needed. This process triggers the economic impact shifting from the consumer sales side of the ledger to the income side of the ledger for employers, employees and workers.
If this consumer spending trend continues, and there is absolutely no reason to think it will reverse, we are entering a phase of serious financial instability for the American worker, at a scale that will dwarf the 2006/’07 and ’08 recession.
I am not a doomsayer pundit on economic matters. I am a proactive planner on economic forecasts. With consumer credit costing more, with fed interest rates climbing, with import orders cancelled, with shipping costs dropping, with consumer spending contracting, with fewer units moving, with inventories climbing, all of the data only points in one direction.
Serious consumer defaults are looming.
Government policy has been hammering the demand side of the economy, proclaiming -falsely- that excessive consumer demand was the cause of inflation. This game of economic pretending is about to get very serious.
Consumer spending, as measured in actual units created and purchased in the economy, has been contracting since the third quarter of 2021 (started June, July, August ’21). Simultaneously, consumer spending as measured in actual dollars spent to purchase food, fuel and energy, has been skyrocketing. This is a supply side inflationary cycle with no soft landing.
(Wall Street Journal) – U.S. retail spending and manufacturing weakened in November, signs of a slowing economy as the Federal Reserve continues its battle against high inflation.
November retail sales fell 0.6% from the prior month for the biggest decline this year, the Commerce Department said Thursday. Budget-conscious shoppers pulled back sharply on holiday-related purchases, home projects and autos. Manufacturing output declined 0.6%, the first drop since June, the Fed said in a separate report.
The Fed on Wednesday raised its benchmark interest rate 0.5 percentage point to a 15-year high and signaled plans to continue lifting rates through the spring. Fed officials have increased rates at the fastest pace since the 1980s to cool the economy and bring down inflation, which is running near a 40-year high.
“Most households are acting strategically, planning for a road ahead that may be more difficult to traverse, with higher interest rates, the housing slump, and ongoing inflation—and the very real possibility of a recession,” said Craig Johnson, president of the retail consulting firm Customer Growth Partners. (read more)
Businesses are going to start cutting expenses in order to survive.
The number one expense for almost all businesses is the labor cost.
Non-essential and high wage labor is going to get removed first.
President Trump Announces Plan to Protect Free Speech and Digital Bill of Rights
Posted originally on the CTH on December 15, 2022 | Sundance
This afternoon President Donald Trump released a video outlining a campaign platform position around free speech. {Direct Rumble Link}
Referencing the latest revelations about various political groups, campaigns and government agencies instructing social media platforms on the removal of content, President Trump notes his position would be to dismantle the government systems that facilitate the censorship. President Trump notes he would sign an executive order banning any federal agency from censoring or limiting the free speech of American citizens.
Additionally, President Trump noted he would ban federal money from being used to label domestic speech as misinformation or disinformation, along with firing any bureaucrat who has previously engaged in the domestic censorship, directly or indirectly, including within all agencies of the DHS, FBI or DOJ who have targeted the free speech rights of Americans. WATCH:
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Among other initiatives, President Trump called for the federal government to break ties with any nonprofits and academic programs that are aimed at tacking mis- and disinformation.
“If any U.S. university is discovered to have engaged in censorship activities or election interferences in the past, such as flagging social media content for removal of blacklisting, those universities should lose federal research dollars and federal student loan support for a period of five years, and maybe more,” he said.
Centinel2012 