placnx

Israel is resisting the two-state solution, so any deal will be held up until after the US election, with the expectation that Trump will win. Then Netanyahu hopes to get a deal with meaningless gestures to the two-state solution and neutralization of the Saudi Peace Initiative of 2002. It's unlikely that Biden will do anything serious to stop the Gaza war, so Netanyahu will avoid getting ousted until the never-ending war is "over", and by that time Trump may already be in power again.

4 hours ago, TallGuyJohninBKK said:

Thailand hasn't had a national COVID vaccinations campaign for the general public since 2022...

 

So that means, the vast majority of people in the country with few exceptions are not up-to-date on COVID vaccinations and have not received the latest currently available vaccine version aimed at the more recent XBB variant.

 

In the west at least in places like the U.S. and UK, there will be new versions of the COVID vaccines released later this fall aimed at protecting against the latest KP.2 / JN.1 variants... But Thailand thus far has shown no signs of any plans to make those vaccines widely available to the public.

 

PS - It's not like COVID vaccinations offer some kind of magical permanent protection. The COVID virus keeps changing/mutating, and the vaccine versions typically protect well for about 6 months before the protection wanes substantially...

 

We're likely heading toward a similar situation as with the flu vaccines, where a new version is produced and given annually to reflect the latest strains of that virus, and to top-up the provided protection.

 

 

I read that 4 hospitals in Bangkok have the XBB vaccine, for what that's worth.

4 hours ago, TallGuyJohninBKK said:

 

 

Ahh, the good old Rupert Murdoch NY Post...

 

Fauci was wrong when he originally made that off-handed comment above, and he later clarified his remarks in subsequent testimony before a House subcommittee, which I'm suspecting you knew....

 

In his clarification, Fauci noted that he wasn't involved in the drafting of the U.S. social distancing policy, which in fact came from the CDC. And when he said not backed by scientific data, he meant and clarified, there had not been randomized clinical trials done.

 

"Fauci sought to clarify on Monday that the 6-foot guidance came from the CDC and was based on droplet research, telling lawmakers: "It had little to do with me since I didn't make the recommendation and my saying 'there was no science behind it' meant there was no clinical trial behind that."

 

Though asked if social distancing requirements and other public health measures to reduce transmission saves lives, Fauci said "definitely."

 

https://abcnews.go.com/Politics/republicans-poised-grill-anthony-fauci-covid-19-response/story?id=110677611

 

And of course, there had been much research done on social distancing policies for viruses long before COVID came along, as this 2020 report by the U.S. GAO recounts:

 

"A CDC guideline based on historical studies of selected infections says that the area of highest risk is within 3 feet of an infected person. Some studies suggest a buffer of 6 feet may further reduce risk.

 

Other studies examining droplet dispersion in sneezing and coughing found they can go more than 6 feet. Also, viral material may persist in the air within a room for up to 3 hours."

 

https://www.gao.gov/products/gao-20-545sp

 

Infections in a restaurant spread from one table to another because an air conditioner propelled the droplets 4 meters or so. This was an anecdotal observation rather than a study.

1 hour ago, Presto said:

The solution would be for Israel to go back to the pre-67 borders, and abandon all illegal settlements on the West Bank. But that will never happen.

It might happen if the World gets sufficiently agitated.

6 hours ago, hotchilli said:

At least he went out with a nice view.

The photo could not be anywhere near Somphet Market which is beside the moat. I am not sure where the mentioned fountain is either.

On 6/1/2024 at 11:37 AM, JimGant said:

Why they left re-sourcing out of the Thai-US DTA is a question researched by others. See page 19 of the below reference for a rationale that re-sourcing was a given, and not necessary to be specifically addressed:

https://nysba.org/NYSBA/Sections/Tax/Tax Section Reports/Tax Reports 2014/1313 Report.pdf

 

I'd cite Article 25(1) on my Form 8833:

This, along with an explanation in that two miles of space they give you -- should suffice, by addressing the forest, and not all those piddling re-sourcing trees.

 

The forest, of course, is the treaty to eliminate double taxation. And a treaty that gives Thailand primary taxation rights on certain US Income, namely private pensions and IRAs. But without a Form 8833 permission to trump the Internal Tax Code that says:

..... how can you eliminate double taxation if you can't take a tax credit on your US tax return -- for those taxes you paid Thailand for their taxation of your US private pension or IRA?

 

Obviously you can't, otherwise the treaty is worthless. Thus, the lack of a re-sourcing paragraph in the treaty, that you can cite on your Form 8833 -- is a non starter. The forest -- and common sense -- rule.

 

Note the last para in Article 25 of the Technical Explanation:

 

Written 26 years ago -- with no subsequent protocol to incorporate re-sourcing language. May be they figured the treaty wasn't broken -- and no protocol needed. Or, maybe they were just plain lazy. Anyway, I can't see a problem with any Form 8833 filings (other than they have to be mailed in, and can't be included with your electronic TurboTax filing. Oh well.

The problem is that as both the treaty and the technical explanation make clear, the credit is allowed but limited by US law to foreign tax paid on foreign-source income. I have yet to discover how someone without foreign-source income can override US law when the treaty states after article 25(3): "Notwithstanding the preceding sentence, the determination of the source of income for purposes of this Article shall be subject to such source rules in the domestic laws of the Contracting States as apply for
the purpose of limiting the foreign tax credit."

These are links for the 1996 US Model Tax Treaty and its Technical Explanation:

https://home.treasury.gov/system/files/131/Treaty-US-Model-1996.pdf

https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-1996.pdf

These can be compared to the specific versions for Thailand. I have not done this comparison yet.

Anyway, you should read page 31 of the NY Bar report 1313 which addresses the specifics of the Thai and Indian treaties with the US regarding allowable credit.

On 6/1/2024 at 11:37 AM, JimGant said:

Why they left re-sourcing out of the Thai-US DTA is a question researched by others. See page 19 of the below reference for a rationale that re-sourcing was a given, and not necessary to be specifically addressed:

https://nysba.org/NYSBA/Sections/Tax/Tax Section Reports/Tax Reports 2014/1313 Report.pdf

 

I'd cite Article 25(1) on my Form 8833:

This, along with an explanation in that two miles of space they give you -- should suffice, by addressing the forest, and not all those piddling re-sourcing trees.

 

The forest, of course, is the treaty to eliminate double taxation. And a treaty that gives Thailand primary taxation rights on certain US Income, namely private pensions and IRAs. But without a Form 8833 permission to trump the Internal Tax Code that says:

..... how can you eliminate double taxation if you can't take a tax credit on your US tax return -- for those taxes you paid Thailand for their taxation of your US private pension or IRA?

 

Obviously you can't, otherwise the treaty is worthless. Thus, the lack of a re-sourcing paragraph in the treaty, that you can cite on your Form 8833 -- is a non starter. The forest -- and common sense -- rule.

 

Note the last para in Article 25 of the Technical Explanation:

 

Written 26 years ago -- with no subsequent protocol to incorporate re-sourcing language. May be they figured the treaty wasn't broken -- and no protocol needed. Or, maybe they were just plain lazy. Anyway, I can't see a problem with any Form 8833 filings (other than they have to be mailed in, and can't be included with your electronic TurboTax filing. Oh well.

The problem is that as both the treaty and the technical explanation make clear, the credit is allowed but limited by US law to foreign tax paid on foreign-source income. I have yet to discover how someone without foreign-source income can override US law when the treaty states after article 25(3): "Notwithstanding the preceding sentence, the determination of the source of income for purposes of this Article shall be subject to such source rules in the domestic laws of the Contracting States as apply for
the purpose of limiting the foreign tax credit."

These are links for the 1996 US Model Tax Treaty and its Technical Explanation:

https://home.treasury.gov/system/files/131/Treaty-US-Model-1996.pdf

https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-1996.pdf

These can be compared to the specific versions for Thailand. I have not done this comparison yet.

Anyway, you should read page 31 of the NY Bar report 1313 which addresses the specifics of the Thai and Indian treaties with the US regarding allowable credit.

On 6/5/2024 at 6:04 PM, Presnock said:

Yes the US taxes on worldwide income but if you earn a salary overseas, the US govt allows a deduction on the taxes for that salary if I am not mistaken...Called foreign earned income reduction!

https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion

You can deduct up to $120K of foreign earned income from total income on US taxes. So if you earned that in Arabia for example, then that could be taxable in Thailand besides the other income reported (and taxed) in the US.

On 6/5/2024 at 5:15 PM, timendres said:

An article on Bangkok Post clearly shows that they are discussing taxing worldwide income.

Currently, only two countries on the planet do this. The USA and Eritrea.

This is a desperate act by the Thai government, and demonstrates that things are not good.

France also taxes on worldwide income of residents.

On 5/30/2024 at 2:13 PM, JimGant said:

Good catch. And, yes, the US-Thai DTA does not have a re-sourcing clause. But, that omission is not critical to allowing a tax credit for Thai taxes on US income. This is all accomplished by attaching a Form 8833, along with your Form 1116 (tax credit form), to your tax return. 

 

What the Form 8833 explains away is that, per tax treaty, the Internal Revenue Code that says tax credits are only allowed on foreign income, not US income -- is overridden by the tax treaty -- specifically, that tax credits are a major part of the treaty, precluding double taxation. And, yes, this means a credit for Thai tax on US income taxable by Thailand. Here from the Form 8833 instructions:

 

 That the Thai-US DTA doesn't have a re-sourcing clause is a minor oversight -- and not one that would preclude the Form 8833 from allowing a tax credit for Thai taxes on US income specifically allowed to be taxed primarily by Thailand.

Then what article of the tax treaty allows me to allocate US-source income to foreign-source income in form 1116? I looked through the whole treaty and don't see any clause to cite in form 8833. The quote from the 8833 instructions (see original post) means a tax treaty with a provision for overriding IRS rules, and that would be for example re-sourcing. Other treaty provisions might give the country where the US citizen resides the power to tax some kind of income that would normally be taxed in the US under IRS rules. That is the purpose of form 8833, to cite the relevant provision in the particular treaty in question.

It could be that IRS being understaffed does not check back to see whether re-sourcing is provided in the Thai-US tax treaty and thus an 8833 claim is not challenged. Most treaties provide re-sourcing.

4 hours ago, Emdog said:

If conservation was practiced seriously, wouldn't need a reactor or other power source

Australia considered nukes, but studies show it costs twice as much as renewables and wouldn't be ready til 2040, if then

Would you trust Thai business to build, let alone run, a reactor? I wouldn't

Small modular reactors would be a good solution for Thailand. As of 2020 there were many ideas. Some are small enough to fit the modules in shipping containers. There is some construction to prepare the site, of course, but the complications of a major reactor are avoided.

SMR_Book_2020 table of contents.pdf SMR_Book_2020.pdf

5 hours ago, WingFat said:

It occurs to me that there are only two countries that tax worldwide income; the USA and Eritrea of east Africa.

 

Americans get a foreign tax credit on their US taxes for taxes paid in a foreign country, so no change for them. I don't know about how it will work out for Eritreans.

 

For the expats that hail from countries that do not tax their citizens if they are out of the country for a specified time (usually it's 180 days or more) in a calendar year, they have been enjoying tax-free living while expatting in the LOS, in many cases, for decades.

 

While I sympathize with those who will find this a challenge to pay Thai taxes, the saying of "there's no free lunch" comes to mind. And the argument that these people contribute to the Thai economy in other ways, well, so does everyone else.

 

Whatever the case, nobody should have to be double-taxed on the same income. I surely hope that if this issue arises, it gets ironed out such there is no double taxation.

Americans cannot get a tax credit in the US if they have no foreign income. For them, the alternative would be to get a credit in Thailand for taxes paid in the US. Then Thailand may get nothing.

Credit on US taxes is complicated because the Thai-US tax treaty does not contain a provision for what is called re-sourcing, unlike other US treaties negotiated in the same time frame. Strange, since over the years there were model treaties containing these rules. It seems like it is time for overhaul of the Thai-US treaty.

Under many US tax treaties this re-sourcing means that for income tax paid to the foreign country under its rules, the income reported on that foreign tax return can be considered foreign income for the purposes of calculating the US foreign tax credit, even though in reality the US taxpayer did not have any income in that country or any other foreign country.

6 hours ago, impulse said:

So what do they call it when tens of thousands of Israeli citizens protest their own gub'ment's actions?  In Israel.

 

Is that anti-Semitism, too?

 

Maybe "unpatriotic". If there were just a few, they would be called "self-hating Jews".

7 hours ago, milesinnz said:

Australia like other regions of largely Caucasian descent brought it on themselves by allowing mass immigration from regions of different cultural and religious values. I somehow don't think it is a problem in places like Poland - they wont allow those of different values to settle in their country.

Australia is an example of settler-colonialism. After years of maltreating the aboriginal population, It seems that they are making an effort to make amends.

Let's hope that Israel wakes up and puts Smotrich and Ben Gvir and many others in prison for life. Actually, Smotrich should get multiple life sentences and the body should be kept in lockup until all sentences have expired.

10 hours ago, Social Media said:

University leaders, for instance, have equivocated instead of acting. They wrote to the Attorney-General seeking legal advice on the phrase “Palestine will be free from the river to the sea,” a call for the abolition of the State of Israel. Australia’s foremost intelligence and security expert, Dennis Richardson, described it as a “very violent statement,” a sentiment echoed by the Prime Minister.

“Palestine will be free from the river to the sea” has a non-violent meaning. Many in the movement for Palestinian rights had given up on the two-state solution because there are so many settlers in the West Bank and East Jerusalem. For them, the answer is to end apartheid in Israel and the Occupied Territories and to accept the one-state solution. I think that this is naive. Perhaps they should be saying “Palestine will be free from the river to the sea. End Apartheid Now”, so that Australians and others do not mix this up with true anti-semitism. The founder of Human Rights Watch made an important comment about the anti-semitiam issue in discussing Gaza yesterday:

https://edition.cnn.com/videos/world/2024/05/26/gps-0526-icc-charges-against-israel.cnn

https://en.wikipedia.org/wiki/Aryeh_Neier

9 hours ago, Chomper Higgot said:

Those pesky  colonists, never have liked paying their taxes to the crown.

 

 

The Home Office should get creative and tow their vehicles. If they don't want to pay, then why don't they use the Underground. But of course they wouldn't want to pay the "tax", must ride for free. Those arrogant colonial scofflaws!! 

9 hours ago, Chomper Higgot said:

Those pesky  colonists, never have liked paying their taxes to the crown.

 

 

The Home Office should get creative and tow their vehicles. If they don't want to pay, then why don't they use the Underground. But of course they wouldn't want to pay the "tax", must ride for free. Those arrogant colonials!  

6 hours ago, cjinchiangrai said:

Nope. The TM30 has been around for ages. Even a house book does not supersede it, even though it should. Out of district refile. If you are in a more modern place they have it more automated now though. For the OP, definitely on a new entry.

Maybe the TM30 dates to 1979, but before it only practically concerned hotels. There was no enforced requirement for foreigners living at home to report themselves until after the last coup.

7 hours ago, CMBob said:

CM in general follows the June 2020 police order and as long as you return to your TM30 registered address from either (1) abroad presuming you enter with a re-entry permit or (2) from a hotel/whatever within Thailand that has filed the usual TM30 for you, then you don't need to do anything; however, that being said, when you have stayed at a hotel/whatever in Thailand that has filed the usual TM30 for you, it's hit or miss whether a 90-day online filing will be rejected (even in that case, you can still file the TM47 in person without messing with the TM30 routine).

Living in Chiang Mai, I found that the practical solution is to set up online filing for TM30, then file whenever staying overnight in a hotel or returning from abroad. Online filing is quite easy once you get the hang of it

10 hours ago, PETERTHEEATER said:

British Airways did not make the list? How sad is that....🤔

British Airways is IAG, #23 on the list.

4 hours ago, new2here said:

IMHO, if this is a economy booking , to me the differences between CI and BR are somewhat small.. Neither is, again, in my experience, far better nor far worse than the other.. Of course, individual flights can vary as does the fleet you happen to be on.. but in totality, I think for a economy class booking, they are remarkably similar — and that being very very solid 

 

Taipei airport - it’s not the most modern nor does it have all the “amenities” that a Singapore or even Incheon has.. but.. what I DO think it does “right” is because a very large percentage of people fly into TPE on either China (CI) or EVA (BR) are making same-day onward international connections- the process to do so is pretty well managed and executed… 

 

One added perk of flying either airlines is that SOME of their US departures leave the US very very late night or early early morning -US time.. that means your arrival in TPE is early morning (+1 or even +2) .. the upside here is that IF for any reason you miss your onward connection (say you leave the US law or your connection flight has cancelled) — you’ve essentially now got all day to find a rebooking… 

Compared to most other US-Asia flights - they tend to leave the US either late morning to midday- and that makes for a late afternoon or every evening arrival in Asia.. the problem here is, again, IF you miss that onward connection, there is a lower probability to finding a same-day rebooking alternative given the late hour. 

 

to me, while I would agree that on the whole (Singapore) SQ, (Cathay) CX or even (All Nippon) NH might be better carriers, I would be perfectly happy to book and fly either China or EVA, and I’d be happy to send an inexperienced unaccompanied adult with either as well.

There is a new airline called Starlux. It flies from Chiang Mai and Bangkok to LAX, SFO, SEA. They have a deal with Alaska Airlines for onward flights from Seattle.

https://en.wikipedia.org/wiki/Starlux_Airlines

Connection time may depend on the days selected. I didn't check RT, OW was Bht 20000 for economy and 40000 for premium economy. The planes are new Airbuses.

On 5/3/2024 at 3:03 PM, Bkk Brian said:

You carry on with false information, from Nov:

 

https://www.bbc.com/news/av/world-middle-east-67333418

As you say, this is from November. Today there's a BBC News program "Eye Investigations: My War". At the end of the program the reporter for BBC Arabic Adnan El Bursh and his team are leaving Gaza on February 10th. This program will run again at 18:30 today. Excellent.

The journalist in your clip left Gaza on December 5th, https://www.bbc.com/news/world-middle-east-67592794

He posted this after leaving, in memory: 

This journalist, Samer al Daqqa, working for al Jazeera, and his team was bombed on December 15th.

https://en.wikipedia.org/wiki/Samer_Abu_Daqqa

I will now stop reading and commenting on these Gaza war threads until something signficant happens, for example, an indictment of war criminals or a significant ceasefire. The readership of these threads is just too small, and the abusive posting of propaganda makes rational discussion impossible. 

2 minutes ago, Bkk Brian said:

BBC Was there reporting right from the beginning

From outside Gaza.

14 minutes ago, Bkk Brian said:

Can you provide a link to say this is untrue?

 

 

Go to the original link.