The Crazy Years

From DIE in the Air - Taki's Magazine

From the lawsuit against the FAA filed by the Mountain States Legal Foundation:

…a candidate could be awarded 15 points, the highest possible for any question, if they indicated that their lowest grades in high school were in science…. In contrast, an applicant was awarded only 2 points if they had a pilot’s certificate and no points were awarded for having a Control Tower Operator rating or having Instrument Flight Rules experience…. In addition, one question on the Biographical Questionnaire awarded an applicant 10 points, the most available for that question, if the applicant answered s/he had not been employed in the prior three years. Another question awarded 4 or 8 points if the applicant had been unemployed five or more months in the prior three years.

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It’s been dragging on for over seven years.

https://www.courtlistener.com/docket/4542755/brigida-v-united-states-department-of-transportation/?filed_after=&filed_before=&entry_gte=&entry_lte=&order_by=desc

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It’s a good thing we know from experience there will we absolutely NO unintended consequences of this (and thousands of other) anti-rational state policy… . At least none for which the perpetrators will likely be held accountable. This this is a particularly instructive case, though; good records are kept in the aviation field. It affords an opportunity to gather statistical evidence, comparing aviation accidents and near-misses before and after implementation of this anti-rational policy.

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It kills two birds with one stone. DEI goals and you don’t have to implement what will be a very unpopular lifetime carbon credit for air travel. A few spectacular collisions and people will rightfully fear air travel.

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A nearly six-month standoff between the Universities of Wisconsin and the Republican-led state Legislature over diversity, equity and inclusion spending seemed poised to end Saturday morning. The Board of Regents had agreed to vote on a deal between system leaders and Assembly Speaker Robin Vos that would freeze and cap DEI hiring in exchange for funding held up by the Legislature.

But in a shocking turn of events, the board rejected the proposal 9 to 8 , leaving over $800 million on the table and the future of the system’s DEI offices in limbo. The board also voted not to table the vote for further discussion, effectively killing the deal.

On Friday, UW system president Jay Rothman and UW Madison chancellor Jennifer Mnookin announced they’d reached a deal with Vos after weeks of secret negotiations. The system would make significant concessions on DEI initiatives and staffing in exchange for a release on much-needed funding for pay raises, utilities and construction projects—including a new engineering building at UW Madison—which the Legislature rejected last month.

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The public university isn’t responsible to the public. The unelected bureaucrats will do as they please and you will fund it.

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US$ 440 million fat finger: “The Knight Capital Disaster”.

On August 1, 2012, Knight Capital fell on its sword. It experienced a software glitch that literally bankrupted the company. Between 9:30 am and 10:15 am EST, the employees of Knight capital watched in disbelief and scrambled to figure out what went wrong as the company acquired massive long and short positions, largely concentrated in 154 stocks, totaling 397 million shares and $7.65 billion. At 10:15, the kill switch was flipped, stopping the company’s trading operations for the day. By early afternoon, many of Knight Capital’s employees had already sent out resumes, expecting to be unemployed by the end of the week.

Unbeknownst to the team, the deployment script had a small bug: when it failed to open an SSH connection to a machine, it would fail silently, continue to update the other machines, and report success. It was never tested or checked in like a piece of software because it’s a script that one person wrote for convenience.

That day, one of ten SMARS machines was down for maintenance during the software upgrade, and rejected an SSH connection. After its planned maintenance, the server came back up with an old version of SMARS.

From debug logs, engineers later narrowed down the problem to a bug in SMARS: orders were leaving trading servers correctly, but somehow the firm was starting to accrue large positions on these orders, filling them many times over. Noticing the flaw, engineers decided to roll back SMARS to its previous version, hoping to continue trading with a known-good version.

After the rollback, the abnormal behavior accelerated and spread to seemingly every stock on the market. The losses accelerated, and the SMARS software kept acquiring massive positions that were not allocated to any trading strategy. Trading algorithms also continued to be rolled back, as bugs in those machines could have caused the same issue, but none of this helped. Unknown to the operations department, they hadn’t rolled back to a good version of SMARS—they had rolled back to the same bad version that had been the cause of their problems.

When the dust settled, Knight was able to close its positions at a $440 million loss. On August 5, 2012, Knight received $400 million of rescue financing that allowed them to continue operations. They rebranded as “KCG,” and were acquired in 2013 by GETCO, another algorithmic trading company, to form KCG Holdings. They were later acquired by Virtu Financial in 2017.

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“It’s a collaborative effort,” Godfrey, a British citizen who has spent more than 30 years in government roles — first in the United Kingdom, then in Hong Kong, and finally in Ireland since 2013 — told POLITICO at the agency’s headquarters, located next to rundown terraced housing and a children’s playground in the eastern part of Dublin.

Faced with this uncertainty, the Irish regulator is staffing up, thanks to €7.5 million earmarked from the country’s government.

Since March, the agency has almost doubled, to approximately 75 individuals, with a goal of doubling that figure again, to 160 regulators, by the end of the first quarter of next year. By the end of 2024, Godfrey said he wanted up to 250 personnel on his books, although not everyone would be focused on social media. In comparison, the European Commission has about 120 people in its content enforcement team.

Note that this keeper of the regimen morum Hiberniæ is not, himself, Irish, but is, in fact, a citizen of the United Kingdom, which is not a member of European Union.

Imagine what the Irish of 1923 would have thought of a Brit being appointed to police their speech.

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(Click the image to read the whole thread, including additional side-by-side comparisons of text, on 𝕏.)

Meanwhile, from April 2022:


Veritas”—right.

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Might there be a common thread in those two Crazy Years stories?
UW Madison chancellor Jennifer Mnookin
Harvard President Claudine Gay

I am not suggesting that women are incapable of filling those positions. I am suggesting that those women are unfit to fill those positions. I would also hypothesize that the reason those particular women are in those positions has more to do with their chromosomes than with their capabilities.

Woke will kill us yet.

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Screenshot 2023-12-11 at 10.29.31 AM

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Public Health departments or schools within universities have long been the repositories of the most self-certain, arrogant, leftist statists. I suspect there was much - masked (in both senses of the word) - rejoicing during the “one size fits none” diktats of the state’s Covid juggernaut.

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Screenshot 2023-12-11 at 12.09.22 PM

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Besides, the eye-popping value of the contract is somewhat misleading. The Dodgers are going to pay Ohtani $700 million, but the present-day value of the contract will be markedly lower. The details matter. How much of the money is deferred (“a majority,” said a source) and how long the deferrals last will give a better sense of how good of a deal this might be for the Dodgers, minutiae that will offer a better understanding when the deal is official sometime midweek. Major League Baseball discounts deferrals when calculating the amount teams are charged in the competitive balance tax accounting system, and rather than the $70 million a year a straight contract would cost, Ohtani’s deal is expected to wind up somewhere in the range of $40 million to $50 million a year.

USA Today says:

According to ESPN’s Jeff Passan, Ohtani’s salary will be almost entirely deferred until after the 10 years with the Dodgers are done. Basically, Ohtani will make $2 million per season over the next 10 years, and when the contract ends, he’ll receive the remaining $680 million in deferred payments ($68 million per year for 10 years).

Now, a lot of the commentary about this is about how it’s a way to get around the Major League Baseball “Competitive Balance Tax” (CBT), also called the “baseball luxury tax”, but the consequences for U.S. income tax for Ohtani are also interesting. If his actual taxable income is around US$ 2 million for each of the ten years, then he would pay tax on that based upon his residency status, which (not knowing what it is) would probably be the same as a citizen or green card holder simply based upon the substantial presence test. But unless the IRS can figure out some way to tax his deferred compensation (which probably has all kinds of conditions associated to its payment) as current income, he would have no tax liability until it was actually paid at the end of the ten years.

But he is Japanese citizen, and could give up his U.S. residence before it was paid. If he moved to a country with low or no taxes which had a double taxation treaty with the U.S. (so the U.S. would not withhold taxes on the U.S.-situs income paid to him), he could avoid a large part or all of the U.S. tax on the US$ 680 million jackpot at the end of the contract. Japan (like all serious countries other than the U.S.) does not tax non-resident citizens.

Setting all of this up and dodging the landmines in the tax system would take some very high octane tax lawyering, but when US$ 680 million is at stake, I guess you can afford it.

Ohtani may not just be a great pitcher and hitter, but a financial genius as well.

Update: More from ESPN (2023-12-12 00:05 UTC).

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This assumes that, say, 15 years from now, bread isn’t $6million/loaf and the marginal tax rate isn’t 99%. Given the debt trajectory, who knows?

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It would be very surprising if he can dodge the US exit tax. Even as a non-citizen, being a long-term resident, with the income like his, he is likely to qualify as a “covered expatriate”:

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The expatriation tax is a “mark to market” of worldwide assets, with tax payable as if they were sold on the date of expatration (with vast complexity for illiquid assets). But the question is how is a deferred compensation contract valued. If he gives up his residency before the strike date on the contract, its mark to market value at that date is zero unless they impute some kind of proportional vesting which isn’t in the contract. Since he would receive the income after expatriation, it would not be taxable on the date of payment and, depending on his country of residence when paid, not subject to withholding.

The exit tax replaced the old 26 USC 877 (prior to the enactment of 877A), under which former citizens (but not, as I recall, green card holders) were subject to U.S. taxation for ten years after they escaped as if they were still residents.

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Hmm… may be there is a chance, as vaguely implied here:

Advice for would-be U.S. residents Because of the expatriation process and the potential for taxation if you leave the country, I am now recommending to would-be immigrants that they NOT enter the United States with an eye to permanent resident visa status unless there is a good reason for doing so. Choose an alternate visa status if you want to come to the United States to live.

Even if there is a loophole now, this may change in 10 years.

In any case, even with all tax that he may pay, the remainder is well beyond what a human can consume. As Elon Musk says that beyond some point it is no longer about consumption, but rather about capital allocation.

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That depends on the definition of “serious countries”. I have worked in various countries with citizens from the UK & Canada. While nominally their overseas income was free from home-country tax, in reality there were quite intrusive rules about what they had to do to avoid being liable for home country tax on global income – and it was easy to fall foul of those rules.

Governments everywhere need the money. If they can’t get it one way, they will try other ways. Even the super-wealthy no-income-tax UAE government has imposed a Value Added Tax on its residents.

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