Monthly Archives: June 2013

We are such stuff

27 Thursday Jun 2013

Posted by in Running

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….in dreaming,

The clouds methought would open and show riches

Ready to drop upon me; that, when I wak’d

I cried to dream again.

– William Shakespeare, The Tempest

My dream was slipping away as consciousness intruded upon the restful warmth of sleep. You know that feeling you sometimes have at dawn? The room begins to glow with the sunrise, and your mind slowly stirs. You waver between the comfort of a dream and the awakening routines of morning. Well, in my case, something was licking my cheek.

It was as if a shaggy, slightly moist towel was dragging across my face. Odd dream this…just the sensation of a good scrubbing, steadily increasing in pressure. Feeling like I ought to be getting on with the day, I opened my eyes and saw nothing but deep blue sky.

I don’t know about you, but when I wake, I usually see a ceiling, or perhaps the wall if I have been sleeping on my side. So the view of a cloudless, cerulean sky was mysterious.

My left eye sensed movement, and when I turned to look, the damp towel revealed itself to be a tongue connected to a medium sized dog. Like a Saint Bernard engaged in an alpine rescue, this dog was doing his canine best to rouse the spirit in me.

Then a voice spoke from out of the sky, or slightly stage right in relation to the dog…

“Are you alright?” Readers of my other running reports will recognize this as a frequent question and theme.

“I’m not sure,” seemed the proper assessment, since I was on my back lying on scattered pebbles at the top of a river levy on a beautiful summer day.

“Would you like me to call an ambulance?”

“Sounds like a good idea.”

That was on August 17, 2006, the first time I passed out while running (yes, there was a second time). I had no idea that almost seven years later, at 5:50 AM on April 6, 2013, I would be standing towards the back of the pack at the start of the American River 50 Mile Endurance Run, ready to begin my fourth fifty-mile run.

But here I was on a warm Sacramento morning. The excitement buzzed through the crowd as old stalwarts greeted each other and strangers made new acquaintances. There was Bob Halpenny, who was looking for Richard Hunter, a tremendously accomplished visually impaired athlete, whom Bob would be pacing over the second half of the course (please do read Richard’s inspiring account of his day here).

Another runner standing at my side served in the first Gulf War and told me he took up running to conquer the disabling headaches he suffered from an explosion which left shrapnel in his skull. The running worked better than all the medicine the VA had given him. He was hoping to finish by the cutoff time.

And then I remembered a woman I spoke with at last year’s AR 50. She ran in remembrance of her child who had been lost to cancer. Her tears of sadness at the memory were indistinguishable from her tears of joy at the finish. How do you begin to answer the daughter who met her at the end of the run and asked “why are you crying Mommy?”

“Mommy just accomplished something that was very hard” – an answer that worked on many levels.

My journey to this spot was relatively easy by comparison and has been guided by the most compassionate group of people you could hope for – the indispensably marvelous staff of Fleet Feet on J Street.

Perhaps I’ll plot the map of this adventure in another blog and take you around the  hidden shoals and exposed reefs of this ocean. But in truth, I fear it may be somewhat boring. The beginning is what matters. You draw the contours of your own map, and your destination is never certain. Only when you look back can you see that there has been a path. Which is deceptive, because the swells and storms that have brought you here can only be ridden, not conquered. They have their own mind and cannot be bent to your will.

We stumble, and we sometimes fall. We may even lose consciousness. But we also accomplish the worthwhile which tends to be hard. Such things are neither good nor bad. They are the stuff of life and are not to be feared. For in losing consciousness, we also dream.

We are such stuff

As dreams are made on, and our little life

Is rounded with a sleep.

– The Tempest

rw114235-04-409

Managing enthusiasm for the photographer.

…………………..

Although my time was similar to last year at 10 hours, 30 minutes, I surprisingly finished in the middle of the pack placing 417 out of 836 finishers. Next up – a rematch with the Dick Collins Fire Trails 50 on October 12, 2013, where the goal is to finish before the sun sets.

Dreams

That 70’s Show

14 Friday Jun 2013

Posted by in Political Commentary

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So, national intelligence chief James Clapper lied under oath to the U.S. Senate back in March when he said that the U.S government does not collect information on millions of Americans. Today’s Financial Times (Intelligence chief under scrutiny) reports that he qualified his answer by adding “not wittingly.” Perhaps he should have said “nit-wittingly.”

The FT quotes Clapper as saying he gave the answer “he considered to be ‘the least truthful.'” The Irish call this being economical with the truth. Lawyers call it equivocation.

One of the many jobs Clapper held prior to being tapped to be director of national intelligence, a post created after 9/11, was a stint with the Geospatial Intelligence Agency. Those who prefer an Orwellian bent to their paranoia will note that Geospatial is almost an anagram for Gestapo. But I digress…

As the Obama administration “pivots” towards Nixon (illegal bombings of countries we are not at war with, going to China, domestic spying on U.S. citizens, using the IRS to muck with your enemies, and health care reform – remember it was Ted Kenndey who helped defeat Nixon’s proposals for comprehensive and universal health care), and with the administration’s intent to ramp up the war in Syria, you have to wonder if the Nobel Foundation is thinking of asking for their Peace Prize back. Although Henry Kissinger was also a recipient of the Peace Prize, so perhaps the Swedish definition of “peace” loses something in translation to English.

Just as Richard Nixon had his Daniel Ellsberg, Barack Obama has his Edward Snowden. Ellsberg worked for the RAND Corporation and leaked the famous Pentagon Papers. Snowden worked for Booz Allen Hamilton and now resides in Hong Kong. His fame is as yet undecided, but he leaked what may one day be called the Prism Papers.

To stretch the 70’s analogy further, we even have hunger strikers. Although it was actually in 1980 that IRA members began their hunger strikes at the notorious Maze Prison in Northern Ireland. Detainees at the notorious Guantanamo have been on hunger strikes since 2005 (different detainees at different times, obviously). But now the world hardly takes notice.

Allow me one more digression here, because words matter. The British called the IRA paramilitary prisoners “internees,” as if they were gaining valuable on the job experience. Which in a way they were. The U.S. calls the prisoners at Guantanamo “detainees,” as if one is temporarily inconvenienced. Like when the Captain of the airplane comes on speaker and says your flight will be slightly delayed while they offload some luggage, for something like ten years.

But to close this rant, I would like to repeat the language used by a very different and much wiser Supreme Court than the current incarnation. From its ruling on the publication of the Pentagon Papers, 403 U.S. 713 (1971):

…the Executive Branch seems to have forgotten the essential purpose and history of the First Amendment. When the Constitution was adopted, many people strongly opposed it because the document contained no Bill of Rights to safeguard certain basic freedoms. They especially feared that the new powers granted to a central government might be interpreted to permit the government to curtail freedom of religion, press, assembly, and speech..The Bill of Rights changed the original Constitution into a new charter under which no branch of government could abridge the people’s freedoms…

The word “security” is a broad, vague generality whose contours should not be invoked to abrogate the fundamental law embodied in the First Amendment. The guarding of military and diplomatic secrets at the expense of informed representative government provides no real security for our Republic…The greater the importance of safeguarding the community from incitements to the overthrow of our institutions by force and violence, the more imperative is the need to preserve inviolate the constitutional rights of free speech, free press and free assembly in order to maintain the opportunity for free political discussion…Therein lies the security of the Republic, the very foundation of constitutional government.

upper class twit

Upper class twits or nitwits?

A Duck Walks Into a Starbucks…

08 Saturday Jun 2013

Posted by in Economics and Taxation

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A man walks into a Starbucks and orders a Double Irish with a Dutch Sandwich and proceeds to open his Apple MacBook Pro and Googles “a man walks into a bar jokes…”

A rabbi, a priest, and a Lutheran minister walk into a bar. The bartender looks up and says, “Is this some kind of joke?”

Not really…it is more an elaborate multinational tax strategy that allowed Google to avoid $2 billion in tax in 2011 by moving income to a subsidiary in Bermuda; Apple to avoid paying tax on $44 billion in income; and GE to hold $108 billion in offshore profits, among others. And all because the U.S. Treasury Department wished to simplify the tax code back in 1996 with something called “check the box.” Simplicity, however, can be overwhelmed with complexity.

“Check the box” seems an innocent enough phrase. The idea is that U.S. firms can decide how to classify a subsidiary for tax purposes. Like a magic trick, a company checks a box on a form and makes a subsidiary disappear – as if it never existed. In tax parlance, the subsidiary becomes a “disregarded entity.”

After setting up the “check the box” rule, the Treasury realized it had a problem, because there was an increase in cross-border financing. The Commerce Department estimates that U.S. companies keep some $1.8 trillion in earnings abroad.

Here is where simplicity gets complex…

A Double Irish requires two Irish corporations. The first company, which we’ll call “Pat,” is tax resident in Ireland – that is, Pat pays Irish income tax. Pat pays a second Irish company, which we’ll call “Mike,” a royalty for the use of intellectual property. This allows Pat to reduce its Irish tax bill for the expense of the royalty payment to Mike. This is why so many software companies love the Double Irish. Software is considered intellectual property.

The second Irish company, Mike, owns Pat and is not tax resident in Ireland (under Irish tax law, a company is tax resident where its central management and control is located, not where it is incorporated). Mike actually collects the royalties in someplace like Bermuda, which has no corporate income tax. Plus, Mike usually charges Pat above-market rates.

A guy walks into a bar. The guy behind him ducks.

This is where “check the box” reenters the picture. If Mike makes an entity classification election for Pat to be “disregarded” by checking the box, the payments between Pat and Mike are ignored for U.S. tax purposes – as if they never existed. Of course, if money is repatriated back to the U.S. it will be taxed. Before being hauled before the U.S. Senate to explain themselves, Apple was lobbying Congress to allow tax free repatriation of overseas funds.

The final item on the lunch buffet is the Dutch Sandwich. Because as you know, without bread, the sandwich falls apart. To avoid Irish withholding tax, a Dutch subsidiary is used because Ireland does not levy withholding on royalty receipts from European Union members. So, the money starts off on the books in the Netherlands, flows through Ireland and then on to Bermuda. A rather nice, virtually tax-free holiday.

There are approximately 1,000 multinationals with operations in Ireland.

A man walks into a bar and orders a drink, then discovers he has to go to the bathroom. To stop anyone stealing his drink he puts a note on it saying, ‘I spat in this beer.’ When he returns he finds another note saying, ‘So did I!’

ducks

A duck walks into a bar…