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To: nigel bates who wrote (8768)1/26/2012 9:33:55 AM
From: mopgcw
of 9449
 
as always nigel, you find the insight that I really do enjoy...

hope all is well.

Geo

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To: tuck who wrote (8563)1/26/2012 12:50:19 PM
From: scaram(o)uche
of 9449
 
Message 27907782

>> had peeled out of all my trading position and 25% of my core position a few days ago <<

As my kids used to say..... "goods"!

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To: IRWIN JAMES FRANKEL who wrote (8767)1/26/2012 6:23:56 PM
From: Biomaven
of 9449
 
Under partnership law, the agreements can allocate the income distribution to the partners in a fashion different from the asset share ownership.

But there is also a general principle of tax law that any payment for services is ordinary income. So I personally would characterize this as a loophole.

I think you are incorrect that closing this loophole would not increase taxes - if we assume the managers still get their same return (as is likely) and pay ordinary income rates on it, then the overall tax rate for investors plus managers will now be higher.

Not also that the way things are structured now there is a lot of room for tax planning - take losses and delay profits, something not usually available for ordinary income. Prior to the reforms of 2008 there was also a lot of abuse using offshore management companies that elected a cash basis of accounting while the onshore fund used accrual for the 2% management fee. (I think some of these may be grandfathered in, and so it is quite possible that Romney is still taking advantage of this old loophole).

Peter

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To: Biomaven who wrote (8773)1/27/2012 9:17:36 AM
From: IRWIN JAMES FRANKEL
of 9449
 
>> I think you are incorrect that closing this loophole would not increase taxes - if we assume the managers still get their same return (as is likely) and pay ordinary income rates on it, then the overall tax rate for investors plus managers will now be higher.


But it is not the closing of the loophole that creates more tax revenue - it would be the increase in fees. And while I agree that is certainly possible, may even be likely, it is not a certainty. I think I read that hedge fund fee structures were coming under pressure.


BTW - I am fine with closing this "loophole".


However, implementation of tax policy is more complex than is generally recognized, and characterization in labels like "loophole" color the debate without aiding the understanding.


Jim

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To: IRWIN JAMES FRANKEL who wrote (8774)1/27/2012 10:28:58 AM
From: Biomaven
of 9449
 
labels like "loophole" color the debate without aiding the understanding

In this case I concede. But the more egregious strategy (now blocked) that allowed the fixed 2% income to be indefinitely deferred I would indeed characterize as a loophole.

I do agree that sometimes you see inflammatory and uninformed commentary on tax policy - for example the criticisms of allowing companies to deduct the spread on option exercises that didn't point out there was corresponding income (at a higher rate) to the employee.

Peter

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To: pgo-neil who wrote (8759)1/29/2012 2:50:54 PM
From: scaram(o)uche
of 9449
 
Hey, congrats on your fast start in the contest. Hoping that you own a few of the suckers, real world.

Best! Rick

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To: scaram(o)uche who wrote (8776)1/30/2012 4:51:55 PM
From: Ian@SI
of 9449
 
Only 27 women in the trial, but this sounds impressive to me. But then, I'm easily impressed... :)


Public Release: 30-Jan-2012
Journal of Immunotherapy
4-week vaccination regimen knocks out early breast cancer tumors, Penn researchers report
Researchers at the Perelman School of Medicine at the University of Pennsylvania report that a short course of vaccination with an anti-HER2 dendritic cell vaccine made partly from the patient's own cells triggers a complete tumor eradication in nearly 20 percent of women with ductal carcinoma in situ, an early breast cancer.
National Institutes of Health, Harrington Foundation, Pennies-in-action.org, Mistler Foundation
Contact: Holly Auer
holly.auer@uphs.upenn.edu
215-200-2313
University of Pennsylvania School of Medicine




From: uphs.upenn.edu

...

Czerniecki and colleagues enrolled 27 women with HER2-positive DCIS. They isolated specialized white cells from the patients’ blood using standard apheresis techniques similar to the blood donation process. Once isolated, the researchers activated the dendritic cells, which are key regulators of the immune system, and primed them with small pieces of the HER2/neu protein in Penn’s Clinical Cell and Vaccine Production Facility. Each patient then received four shots, one week apart, of their personalized anti-HER2 vaccine. And two weeks later patients had surgery to remove any remaining disease, which is standard care for DCIS patients.


...

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From: scaram(o)uche2/1/2012 2:30:45 PM
of 9449
 
Cynthia seems like my type......

lastwordonnothing.com

"Science says the first word on everything, and the last word on nothing" – Victor Hugo

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To: scaram(o)uche who wrote (8692)2/2/2012 3:22:53 PM
From: scaram(o)uche
of 9449
 
An all-day climber, news under appreciated at open. exel too, through presentation...... should be an effort to sell the meeting, but recent attempts to sell big-science biotechs have burned the sellers.

Anyway.... given a benign market or better and news, might be good to place bets.

Where does one go to invest in today's world? U.S. stocks! And where should you invest, among U.S. stocks?

Message 27907467

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From: scaram(o)uche2/3/2012 3:53:18 PM
of 9449
 
Lots of Twits are calling for a sector correction.

Looks like a JPM to ASCO year to me, and I don't see anything over-valued in my portfolio.

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