CP - Offsets Supplement - Michigan 7 2023 BEJJP

Competition
Mechanics
Quantification---2NC
The unit of redistribution is the money allocated towards it.
Blim ‘5 [Michael; 2005; Associate Professor of Anthropology at the Graduate Center in the City University of New York, Ph.D. from Temple University; Equality and Economy: The Global Challenge, “Equality at Home,” Ch. 10]
As an initial step, we need to establish a baseline of support. Let us suppose that our unit of redistribution is the amount of money it takes annually to support the subsistence needs of one person in a household living at the level of the national median. We can calculate the necessary amount in the roughest sense for illustrative purposes if we take US $43,000, the 2003 median income of a U.S. family,27 and, assuming the household is composed of four persons, divide that amount by four, yielding US $10,750. This sum becomes what can be called a redistribution unit—the basic annual income guaranteed to every person living in the United States. Though this figure can be adjusted or calculated anew when a proposal of this nature begins its trek toward becoming a law, the principle of providing an adequate income guarantee must be retained if we are to meet the general imperative of providing economic equality. Since every person will now have an income, and thus either filing an income tax form or being part of a household filing, we can assure that each person receives the total amount of the minimum guaranteed by raising the standard deduction to US$10,750, thus rendering the income tax-free. Tax refunds can serve as the device for delivering the guaranteed income. So that we do not re-create inequality by giving every person the same amount, and thereby providing well-off persons with an additional income subsidy, we need to assume that income above the minimum level is taxed progressively. This means that the federal government will tax higher incomes at higher rates, not simply as a means of financing government expenditures, but as a social policy designed to redistribute the national income more equally.
The scope of redistribution is net tax or expenditure.
Miron ’11 [Jeffrey; Winter 2011; Senior Lecturer and Director of Undergraduate Studies in the Department of Economics at Harvard University, Ph.D. in Economics from the Massachusetts Institute of Technology; National Affairs, “Rethinking Redistribution,” https://www.nationalaffairs.com/publications/detail/rethinking-redistribution]
The scope of income redistribution in America is truly immense. In 2007, the last year not significantly affected by the Great Recession, the federal government spent about $1.45 trillion (roughly half of its total spending) on programs aimed at redistributing income from more wealthy Americans to the less wealthy. These ranged from means-tested entitlement programs like Medicaid, housing assistance, unemployment compensation, and food stamps to broader entitlements like Medicare and Social Security (which are not means-tested, but nonetheless transfer income on a mass scale and are generally justified on the grounds that they reduce poverty among the elderly).
Beyond these direct anti-poverty initiatives, the progressive federal income tax redistributes income even further. Progressive taxation means that the tax rate increases along with a taxpayer's income; a person earning $50,000 per year, for example, might pay $10,000 in taxes while a person earning $100,000 per year might pay $30,000. The higher-income person not only pays more taxes in total: He also pays a larger portion of his income (30% versus 20% in the preceding example). The wealthier give up a greater share of their earnings so that the less wealthy can forfeit a smaller portion of theirs; in this way, our progressive tax code is redistributive. The table below displays the effective tax rate (defined as total federal taxes paid — including payroll taxes to fund Social Security and Medicare — divided by total income earned) for different segments of the income distribution. It also shows the share of the nation's total federal tax burden shouldered by each income group.
Redistributive taxes are an amount of money.
Lima ’22 [Hugo, Allan Vieira, and Celia Anteneodo; Department of Physics at PUC-Rio in Brazil; National Institute of Science and Technology for Complex Systems; Chaos, Solitons, and Fractals, “Nonlinear redistribution of wealth from a stochastic approach,” vol. 163]
We investigate the effect of applying nonlinear redistributive taxes to the yard-sale dynamics of assets. An amount of money is collected from each individual (tax) and distributed back equally. We consider (i) a piecewise linear tax, exempting those with wealth below a threshold W0, and taxing the excess wealth otherwise, and (ii) a power-law tax with exponent a>0, which allows embracing regressive, proportional and progressive rules. The distribution of wealth obtained from numerical simulations of the agent-based dynamics is compared with the solution of its associated Fokker–Planck equation for the probability density function P (w, t) of wealth w at time t, in good agreement. Based on these solutions, we analyze how the different rules modify the distribution of wealth across the population, quantifying the level of inequality through the Gini coefficient. We note that the introduction of an exemption threshold does not always diminish inequality, depending on the implementation details. Moreover, nonlinearity brings new stylized facts in the distribution of wealth compared to the linear case, e.g., negative skewness, bimodality, indicating stratification, or a flat shape meaning equality populated wealth layers.
Redundancy---2NC
Redundant provisions are void.
Agathocleous ’13 [Alexis; Spring 2013; Staff Attorney at the Center for Constitutional Rights; Loyola Journal of Public Interest Law, “When Power Yields to Justice: Doe v. Jindal and the Campaign to Dismantle Louisiana’s Crime Against Nature Statute,” vol. 14]
These questions coalesced into a powerful campaign against the CANS law. Led by fearless community members and groups, the campaign mobilized advocacy, lobbying, litigation, public education, and a press strategy to challenge the discrimination faced by those convicted of CANS. And in two short years, despite the state's strenuous effort to defend this law, a coalition of community advocates, lawyers and activists systematically and comprehensively dismantled its most pernicious effects, rendering the law truly redundant and functionally void.
Perms
Increase---2NC
‘Increase by’ controls the means of increasing.
Lange ’60 [Oskar; April 1960; Renowned Polish economist and diplomat, studied law and economics at Poznan and Cracow; Econometrica, “The Output-Investment Ratio and Input-Output Analysis,” vol. 28]
The investment coefficients are related to the coefficients of production in the following way.5 In producing a unit of the jth sector's output (per year) an amount ai; of the ith sector's output is used up in the process (per year). An additional amount of asj must be used up next year if next year's output is to increase by one unit. The stock of the means of production must increase accordingly. The needed increase in stock, i.e., investment, depends on the rate of use-up of the means of production. Let, for instance, the means of production (e.g., machines, buildings, or other equipment), in which the output of the ith sector is embodied in the jth sector, last for 10 years and their rate of use-up be uniformly 1/10 per year. Then in order to increase the use-up of each year by aij, a stock of additional means of production equal to 1 0ai must be provided. Thus, bi1 lOaij. In view of the durable character of the means of production, it is not possible to provide less, for then the use-up could not be kept up at as; per year.
The perm excludes part of the mandated increase.
Sanga ’20 [Sarath; February 2020; Professor of Law at Northwestern University, Ph.D. in Economics from the University of California at Berkeley, J.D. from Yale University; Journal of Law and Economics, “Network Effects in Corporate Governance,” vol. 63]
The proof is given in Section A4 in the Appendix. Intuitively, the legal quality estimator uses the first postshock cohort to measure the immediate change in Delaware's share of new firms. However, that cohort responds not only to the increase in Delaware's legal quality but also to the (expected) increase in its future network size. Delaware's share of the first postshock cohort is therefore greater than what the quality effect alone would have induced. Similarly, the network effect estimator uses firms from the second postshock cohort and onward to measure subsequent changes in Delaware's share of new firms. This estimator is a lower bound because it excludes the part of the increase in Delaware's share of the first postshock cohort that was due to the expected increase in network size. Note that this logic does not depend on the accuracy of firms' predictions, the ability of firms to reincorporate, or the total number of firms; the validity of the bounds depends only on firms' beliefs that a positive quality shock will (weakly) increase Delaware's network size. The bounds are thus valid even if firms systematically underestimate Delaware's future network size.
Decrease---2NC
‘Decrease’ is defined as the net difference between the previous and current level.
IRS ’19 [Internal Revenue Service; March 26; Revenue service for the United States federal government, responsible for the internal revenue code and taxation; Rules and Regulations, “TD 9853, 84 FR 11217,” vol. 84]
The comment addressed two different issues, the first being the definition of “decrease in tax” provided in § 301.6707A-1(d)(1)(i) of the proposed regulations. Section 6707A(b)(1) provides that, subject to certain minimum and maximum amounts, the amount of the penalty under subsection (a) of section 6707A with respect to any reportable transaction shall be 75 percent of the decrease in tax shown on the return as a result of such transaction (or which would have resulted from such transaction if such transaction were respected for federal tax purposes). Section 301.6707A-1(d)(1)(i) of the proposed regulations defines a “decrease in tax” generally as the difference between the amount of tax reported on the return as filed and the amount of tax that would be reported on a hypothetical return where the taxpayer did not participate in the reportable transaction. The definition in § 301.6707A-1(d)(1)(i) also encompasses situations where a taxpayer's participation in a reportable transaction creates a liability for a tax that would not exist absent participation in the transaction. For example, a taxpayer engaging in a listed transaction involving a Roth IRA may be subject to an excise tax on excess IRA contributions. If the taxpayer fails to report the excise tax on the taxpayer's excess IRA contributions, this amount of tax would not appear on the return filed by the taxpayer that reflected the taxpayer's participation in the reportable transaction. The excise tax would also not appear on a return filed by the taxpayer if the taxpayer had not engaged in the transaction, because there would be no excess contribution on which the excise tax would be imposed. Therefore, the difference between these two returns would result in no decrease in tax attributable to the abusive Roth IRA transaction. To account for this type of situation, § 301.6707A-1(d)(1)(i)(B) of the proposed regulations includes in the definition of decrease in tax “any other tax that results from participation in the reportable transaction but was not reported on the taxpayer's return.” Example 1 in § 301.6707A-1(d)(3)(i) illustrates this rule.
The commenter noted that the proposed regulation includes tax that should have been shown on the return, but was not, in the definition of “decrease in tax” described in § 301.6707A-1(d)(1)(i)(B) of the proposed regulations. The decrease in tax described in § 301.6707A-1(d)(1)(i)(B) of the proposed regulations will only exist if the taxpayer's reporting position is invalid. If the taxpayer's reporting position were determined to be correct, there would be no additional tax resulting from the participation in the reportable transaction that the taxpayer was required to, but did not, report on the taxpayer's return. The commenter contended that including this unreported tax as part of the decrease in tax used to calculate the penalty conflicts with the common understanding that the section 6707A penalty is intended to apply even if the taxpayer's reporting position is determined to be correct. In this situation, the Service will not be able to impose the penalty without first determining the merits of the reporting position. The commenter expressed concerns about whether Congress intended for the penalty to apply in such circumstances, absent adjudication on the merits of the underlying reporting position. The commenter noted that, in contrast, § 301.6707A-1(d)(1)(i)(A) of the proposed regulations defines “decrease in tax” by comparing the amount reported on the taxpayer's return (reflecting participation in the reportable transaction) with the tax liability that would be reported on a hypothetical return that did not reflect participation in the reportable transaction. This portion of the definition is not affected by the assumption that the taxpayer's reporting position is invalid.
‘Decrease’ is net.
CC ’23 [The Clorox Company; May 2; American global manufacturer and marketer of consumer and professional products; The Clorox Company, “Ex. 99.2 - Supplemental Information Regarding Final Results dated May 2, 2023,” https://s21.q4cdn.com/507168367/files/doc_financials/FY23/Q3/Q3FY23-Supplemental-Financial-Schedules.pdf]
(2) Organic sales growth / (decrease) is defined as net sales growth / (decrease) excluding the effect of any acquisitions and divestitures and foreign exchange rate changes. See “Non-GAAP Financial Information” below for reconciliation of organic sales growth / (decrease) to net sales growth / (decrease), the most directly comparable GAAP financial information.
It’s the entire baseline, on net.
Cote ’15 [Denise; February 13; District Judge for the United States in the New York Southern District; Lexis, “Fed. Hous. Fin. Agency v. Nomura Holding Am., Inc., 2015 U.S. Dist.,” 11cv6201]
"The FSP defines OTT impairments as any decrease in expected cash flows that results in the holder not expecting to recover the entire amortized cost basis of the securities, whether or not that decrease is probable. This definition should increase the frequency of OTT impairments."
At the same time,
[t]he FSP reduces the losses that holders of OTT-impaired securities must record in net income if they do not intend to sell the securities and more likely than not will not be required to sell the securities before recovery of the amortized cost basis less the portion of the current period OTT loss that is recorded in net income (hereafter, "the amortized cost basis less the current period OTT credit loss"). For securities that the holder intends to sell or more likely than not would be required to sell before such recovery, the FSP retains the previously required accounting under FAS 115, as issued . . . .
Exempt---2NC
It exempts all income.
U.S. Code ’19 [United States Code; last references December 2019; Section 512 of Title 26 of United States Code; Legal Information Institute, “26 U.S. Code § 512 - Unrelated business taxable income,” https://www.law.cornell.edu/uscode/text/26/512#a_3]
(B) Exempt function income—
For purposes of subparagraph (A), the term “exempt function income” means the gross income from dues, fees, charges, or similar amounts paid by members of the organization as consideration for providing such members or their dependents or guests goods, facilities, or services in furtherance of the purposes constituting the basis for the exemption of the organization to which such income is paid. Such term also means all income (other than an amount equal to the gross income derived from any unrelated trade or business regularly carried on by such organization computed as if the organization were subject to paragraph (1)), which is set aside—
It covers everything that follows.
Ohio.gov ’22 [Beaver Creek; 2022; Government of Beaver Creek, Ohio; Ohio.gov, “39.03 Definitions,” https://beavercreekohio.gov/DocumentCenter/View/3668/2022-Exempt-Income-Definitions]
39.03 Definitions.
(13) "Exempt Income" means all of the following:
Net Benefit---Innovation
Mechanics
Innovation---Yes Offset---2NC
Exemptions cover trillions in corporate activity.
Gross ’20 [Terry, interviewing Jesse Drucker; April 30; Interviewer, M.Ed. from the State University of New York at Buffalo, Honorary Doctorates from Princeton University, Haverford College, and Drexel University; NPR, “How the CARES Act Became a Tax-Break Bonanza for The Rich, Explained,” https://www.npr.org/2020/04/30/848321204/how-the-cares-act-became-a-tax-break-bonanza-for-the-rich-explained]
GROSS: So you report that some of the tax cut provisions in the new stimulus bill - and the stimulus bill is designed to help companies and individuals suffering as a result of the pandemic. But you report that some of the cuts in here for wealthy individuals and rich corporations, these were cuts that were being lobbied for for a couple of years - ever since the 2017 tax cut package that was passed.
And some corporations, lobbyists didn't want those restrictions. They've been working against those restrictions ever since. So do you see this current stimulus package as a kind of opportunity just to give lobbyists and corporations what they've been asking for for a couple of years under the cover of the pandemic?
DRUCKER: If you go back just over two years, the end of 2017, the Republicans in Congress passed, really, kind of landmark tax legislation, which was then signed by President Trump, that was very beneficial, you know, that handed out basically trillions of dollars in tax cuts to big companies and to wealthy individuals. And to some degree, those trillions of dollars in tax cuts were offset, in part, by some new restrictions and new taxes that the Congress put in place.
What we've seen since then is that some of the new taxes that Congress passed to offset some of the big tax cuts that companies were given - that in reality, what is happening is those taxes have been undercut by regulations that have been slowly coming out of the Treasury Department. And now what we're having is, in the CARES Act, as part of a relief package to help companies and people hit by the pandemic, even more of the restrictions that were put in place in 2017 are kind of being whittled away.
And so it's almost like you kind of have this sort of gradual process over the last two years where you gave corporate America and wealthy individuals some big tax cuts. In exchange, there had to be some stuff to offset those cuts. And those offsets have been gradually whittled away by the Treasury Department through the regulatory process over the last couple of years. And now we're seeing even more of those restrictions being eroded in the stimulus package. So the tax cuts, which were once offset by some new taxes and some new restrictions, are gradually being whittled away so that it is potentially going to be only benefits for big companies and wealthy individuals.
It can be scaled to swell by trillions.
Hughes ’23 [Joe; April 3; Federal policy analyst, M.A. in Applied Economics from George Washington University; Just Taxes Blog, “It’s the Revenue Shortfall, Stupid,” https://itep.org/budget-deficit-revenue-shortfall-caused-by-tax-cuts-for-wealthy/]
Republicans in Congress argue that federal spending has grown so out of control and created such a severe budget deficit that we should default on the national debt accumulated under previous Congresses of both parties i

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