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The Passthrough Entity Tax Scandal
No full textThree dozen states have enacted laws since 2018 that are designed to provide passthrough entity owners with an unlimited federal tax deduction for state and local business income taxes. These “passthrough entity tax” regimes respond to the December 2017 federal tax law, which imposed a 10,000-per-individual cap. And the legislative history of the December 2017 law—read in context—aligns with the statutory text.
Surprisingly, the IRS has chosen to permit passthrough entity owners to utilize the workaround anyway. The IRS has not provided a plausible legal rationale for its position, but no one has standing to challenge the IRS’s position in court. Meanwhile, the IRS’s decision to allow the workaround is likely to cost the federal government more than 1 million or more.
In effect, the IRS has created a special tax preference—unauthorized by Congress—for hedge fund managers, law firm partners and other passthrough entity owners. And the Biden administration, notwithstanding its professed commitment to tax fairness, has acquiesced in this massive giveaway to the rich. The Biden administration and the IRS should reverse course immediately and apply the $10,000 state and local tax deduction cap to passthrough entity owners. As long as they permit passthrough entity owners to take advantage of the workaround, the Biden administration and the IRS will be abdicating their duty to enforce the law
A New Pillar to Address Tax Challenges Arising from Digitalization of the Economy: Consensus-Based Digital Services Taxes?
No full textTraditional international tax rules empower a source state to tax non-residents who have a strong physical connection to that state. Digitalized business models reduce, or even eliminate, the need for a physical presence to conduct economic activities in the state where customers are located. This change has created significant challenges for tax administrations, and many jurisdictions have adopted unilateral digital services taxes to increase collection from digitalized businesses. The OECD/G20 Inclusive Framework aims to reform the ‘outdated’ international tax rules by promoting the Pillar One project on the tax challenges of digitalization in order to enable greater taxing rights by market jurisdiction. However, Pillar One seems to foster uncertainty rather than reassurance. This article considers the possibility of coordinating digital services taxes among individual jurisdictions: instead of focusing on the uncertainty and complexity of Pillar One, the OECD could use the Inclusive Framework to provide guidance on the collection of digital services taxes to protect taxing rights of market states and prevent double taxation of multinational enterprises.
 
Trancendence Towards a New World: Translating the Work of German Salas
No full textGerman Salas was born on June 15, 1943, in San José, Costa Rica. Having published and self-published eight collections of poetry between the 1950s and 1980s, including A La luz del silencio (In the Light of Silence 1967), Árbol del universo (Tree of the Universe 1987), and Libro de oro (The Golden Book 1989), Salas has an insatiable thirst for the written word. According to Costa Rican Professor, Dr. Gabriel Vargas, Salas was an assiduous member of El Círculo de poetas costarricenses (1960), one of the “most serious literarygroups of the century” (personal correspondence 2023). Though German Salas published three times with El Editorial Costa Rica—as did many other authors of this group—his name is not mentioned in any of the catalogues or anthologies of the era in which he wrote. These facts lead to the question of why he has suffered relative obscurity in Costa Rican letters
La sorella dell'Ave: The Story of Two Sisters by Ludovica Ripa di Meana
No full textThis article seeks to give visibility in the Anglophone world to poet Ludovica Ripa di Meana (Rome, 1933–), a writer who has inhabited the twentieth and twenty-first century of Italian culture with a uniquely multifaceted presence. The author of three novels in verse and several works for the stage (in addition to a long career as a journalist, in TV and film production), Ripa di Meana’s poetic work has won prizes and drawn praise from critics like Cesare Segre and Cesare Garboli. At the same time, she remains relatively unknown in Italy and abroad—certainly not as well-known as her unique voice and style deserve.
The interview and selected translation we present here bring attention to Ripa Di Meana’s poetry and personality in an international perspective. We include the interview with Ludovica that Jess Beasley and Silvia Valisa conducted in January and February 2024, together with excerpts from her first novel in verse, La sorella dell’Ave—The Story of Two Sisters (that is being currently cotranslated by Beasley and Valisa), with the goal of making her unique voice accessible to an Anglophone audience for the first time
The Helmet: Relflections on Ismail Kadare's "The General of the Dead Army"
No full textIn The General of the Dead Army (1963), Ismail Kadare narrates, in fictional form, a search for the bones/remains of Italian soldiers killed near Albania’s southern border during Italy’s invasion of Greece during WWII. They lie in quickly constructed mass graves at the sites of battle. In Kadare’s novel, an Italian general has the burdensome task of finding these remains; without adequate records of identification, he discovers to his frustration that the ‘bones” he finds overlap with those of other nations’ soldiers. But the familiesin Italy want the bones back home. Finding a WWII Italian Army helmet at a street market, collected by a veteran of the Balkan wars near where the battles were fought, I am inspired to connect Kadare’s story to the real-life repatriation of Italian soldiers back to Italy in the early 1960s. Traveling through the southern Albanian mountains to locate the soldier of the helmet’s possible resting place, I discover, as does Kadare’s general, the absurd confusion in recovering remains at battle sites: who are the remains recovered for? Would Italian soldiers lying in the graves prefer to remain with their comrades? To whom do the remains belong? My own story, interwoven with Kadare’s, posits questions of belonging and return, reflected in my own search for home and place, as well as consideration of other global mass grave sites—often of noncombatants and victims of genocide—where remains are never found, let alone identified or returned
Preface
No full textWe are delighted to introduce the latest issue of Delos, with Gabriele Belletti stepping in as the new Editor-in-Chief. This transition ensures continuity, as Benjamin Hebblethwaite, our former Editor-in-Chief, will remain as Coeditor, bringing his dedication and infectious enthusiasm to the role. Our journal continues to blend academic rigor with a welcoming spirit of innovation. This rigor is maintained through double peer-reviewed contributions, complemented by comprehensive introductions and critical analyses and thanks to teamwork in collaboration with the Managing Editor, Richard Gray, the Journals Manager Lauren Phillips, and the entire University of Florida Press. Innovation is reflected in our embrace of diverse cultures and languages, as well as various modes of translation across poetry, prose, and other artistic forms, fostering a welcoming attitude towards different perspectives
The People Don’t Give Up! : Afrodiasporic Social Movements in Buenaventura, Colombia and the 2017 Paro Cívico
No full textIn 2017 images of demonstrations, riot police, and tanks filled social media worldwide. Most of the videos and media coverage reported on the first wave of #BlackLivesMatter uprisings were catalyzed by police brutality in Ferguson, New York, and Baltimore. In June of that year, similar footage came from Buenaventura, on the Pacific coast of Colombia. This predominantly Afro-descendantpo rt city is responsible for the transit of about 60 percent of the country’s commerce, while unemployment and inequality are rampant, and the infrastructure is on the brink of collapse. The affected local communities responded to these conditions of structural racism with a direct action named Paro Civico: a general strike planned for years by a coalition of grass-rootsAfro-Colombi an organizations demanding clean drinking water, health care, education, and policies to combat drug trafficking-related violence. Resisting police attacks while negotiating with a high-ranked delegation from the Colombian government, the months-long general strike achieved the majority of its goals and, most importantly, galvanized the momentum into the election of one of the movement’s leaders as mayor of Buenaventura. However, the leaders of the Paro Cívico’s Executive Committee have been emphatic in naming this a multiethnic movement and rejecting any specific racial discourses as organizing guiding principles for the direct action. In addition to contextualizing Paro Cívico, this article uses Tianna Paschel’s concept of “organizing while black,” to explain this omission in a racial context determined by the politics of mestizaje in Colombia. It also explains how Paro Cívico strategically exhibited the political power of the communities of the African diaspora without verbalizing it, becoming one of multiple factors that ushered in a new chapter of racial politics in the nation
The Ambivalence of Revolutionary Cleaning in Mona Prince's "Revolution is My Name"
No full textEgyptian writer Mona Prince’s self-published 2012 memoir Revolution is My Name abounds with descriptions of transferring Tahrir Square into a domestic space during the 2011 Revolution: people nurturing fellow visitors and protestors; sharing of blankets, warm clothing and mattresses; cooking and eating; distributing Coca-Cola, endless cups of tea, cigarettes; and nursing the injured who clashed with the police. In one point in her chronicling of her political participation, she describes moving one of her friend’s mattresses out into the square and accepting food from whoever is offering it to her. She also details the square being cleaned by women of the elite class, heralding, in Prince’s imaginings, “a new people.” Focusing on descriptions of the cleaning of the square, this article argues that Prince expands domesticity’s political function while overlooking class and religious biases and blindness that undergird her theorizations of it. This blindness, I argue ultimately undermines the revolution’s attempt at total rupture from the unjust state regime of the past and extends insights into the entanglement of power, oppression and political resistance. Given that theorizations of cleanliness have been mobilized by the colonial project as an alibi for the gendered and racialized inequality of colonialism (and neocolonialism), cleaning here raises the specter of colonialism and highlights its mobility to function as a tool to measure complex class ambivalences.
Beneath the Camouflage: Mimicry and Settler False Consciousness in the Fiction of Murray Bail
No full text"Beneath the Camouflage: Mimicry and Settler False Consciousness in the Fiction of Murray Bail" by SettingsMichael Acklan
