Transcript of the above video: 

As the title of this video suggests, we are discussing, well it's a direct quote out of a citation I'm going to get into here in a moment, but basically the purpose of this video is, I made a recent article about Trump pulling the United States out of the OECD and I don't think I quite drew out the analysis, so I wanted to draw it out further. I thought of making this video after reading a recent article from Zero Hedge, that is zerohedge.com. Now before everybody gets on me, "oh, who cites Zero Hedge?" Well first of all, it's like saying, 'who uses Twitter or X for the news?' Well that's the way it is now. and by the way, Zero Hedge is one of the better platforms for actual information that's in, I don't know, reality, compared to virtually anything else that's out there. Again it's not perfect, but whatever. 

Meanwhile, they are actually quoting the Wall Street Journal, okay? So I found it through Zero Hedge, the article is titled: Wave goodbye to Biden's Minimum Global Effective Tax Rate of 15% Deal, under the subheading within that article: The end of the Global Tax Affair. They are quoting directly from a Wall Street Journal source here. I think it's worth noting, but the big thing to take away from this video is what Trump has done effectively in rescinding OECD and turning all this around is this pie in the sky or maybe mushroom induced notion of Janet Yellen's that we all have some set 15% Global Minimum Tax by dint of the fact that we're all born etc., etc. This is all done, okay? This is effectively a dead letter, and I expect though it might not have immediate effect outside of the United States. As a practical matter, yeah, it's going to have the effect that all of this nonsensical Globalized Tax Policy, all of this, is going to fall by the wayside. Now where is there an analogy to what this was like and where is there an analogy to what this was like that pertains to Trump? Well, honestly, the best analogy I have yet to find is the TPP, the Trans-Pacific Partnership. That thing was being basically negotiated completely in secret by Federal Authorities; they were trying to impose it, or trying to get it create it during the Obama Administration - they were trying to fast-track it and basically impose it on the American people without really any type of substantial review or understanding by the American people as to how this thing actually was going to work. It ultimately died. Trump came in and basically the first day just said we're not doing that because it's not in the interest of the American people. It's not in much of an anybody's interest other than the people who run these supranational "grifts" - I don't even know what the right term is for these things - but that said, we have TPP, Trump just pulled us out the minute he came in and it fell by the wayside, and we never had to deal with that. What that framework would have looked like probably was not good. OECD is very similar. 

That said, quoting from Zero Hedge which is quoting from The Wall Street Journal: "Mr. Trump is taking aim at a tax scheme cooked up at the Organization for Economic Cooperation and Development (OECD). The first part of the deal, known as pillar one, imposes a surtax on the world's largest companies and is aimed primarily at American tech and pharma firms." Well if Thailand adopts this, what? Now our companies are going to have to be put under some egregious surtax? Whatever surtax means. Quoting further: "Pillar two creates a Minimum Global effective tax rate of 15%" - who in Thailand voted for that? Who wants this? As we have discussed before, they have talked about OECD as if it's a foregone conclusion, it is not. We have not promulgated this in Thailand; I don’t think it's good for Thailand; I don't think Thailand should have anything to do with this, as evidenced by the fact that the Americans have just said, "yeah we're out!" Quoting further: "Governments such as France and Germany could impose "top-up" taxes on US Companies whose tax bills at home are too low. Now think of that. That's another country (correction) saying your home taxes are too low." So what, if we have a corporation here in Thailand, has a branch office in France or some other country that's involved in this Ponzi, this grift, this con, what if Thailand has a branch office and they say, 'oh well in Thailand you don't impose enough tax so therefore we're just going to arbitrarily impose more on you.' It's nonsense. OECD is terrible; it's terrible for Thailand; it infringes on the sovereignty of the country as noted by Mr. Trump in the announcement I read when he pulled us out by noting extraterritoriality. It's a terrible idea, it's terrible for Thailand, it's Neo-colonialism in another disguise is basically what it is. Quoting further: "And here we are. Mr. Trump's Executive Order instructs incoming Treasury Secretary Scott Bessent to warn the OECD that Ms. Yellen's promises don't stand (don't stand!) unless Congress passes legislation."

Yes and that's exactly the situation here in Thailand. I am sick and tired of the foreign, interloping stamp-pimps coming into this country illegally in violation of the restricted occupations and telling people how Thai Tax Law is in this vein of OECD. We haven't even passed this here and beyond even that these foreign charlatans have no business talking about Thai Law let alone unpromulgated legislation. Quoting further: "The order asks Treasury and US Trade Representatives to propose ways to retaliate against Government's that impose taxes that violate existing Tax Treaties." Again, interesting there because as we have discussed in other videos, the US-Thai Treaty of Amity provides its own set of special benefits to Americans doing business in Thailand, and how that interacts with our double tax agreement with Thailand results in a situation where - and I have discussed this at length -  these corporations are domestic non-resident corporations and therefore do not interact with the American Tax System in the same way that other corporations do. And moreover, under the provisions of the Treaty of Amity, Americans are granted so called "National Treatment", i.e. they are treated as if they are Thais for purposes of doing business in Thailand. 

My question posed, as I have posed in other videos, where is the Codified Law that requires a Thai National to file tax returns simply by dint of the fact that they have been physically present in Thailand for a certain period of time? Where is the Codified Parliamentary statute to that effect? Not some nonsense interpretive dance by a bunch of bureaucrats or a bunch of hullabaloo spewed forth by a bunch of interloping tax stamp-pimps here in Thailand, who have no business being here anyway, and I cannot figure out for the life of me why they're not under arrest. Quoting further: "The Global Tax Deal also gets a veiled mention in a separate Executive Order on trade. That order instructs Officials to examine whether other Governments impose "discriminatory or extra territorial" taxes on US citizens or companies - followed by a menacing mention of section 891 of the Tax code. That provision allows the US to double the tax bills of foreign companies or individuals whose Governments single out American companies for heavier taxation. It's the nuclear option of global tax policy." and Trump is using it against OECD.

Thailand with regard to the Americans at least, it looks to me like the best and most prudent idea right now is to just simply fall back on the US-Thai Treaty of Amity and the Double Tax Treaty and just continue operating as we have always operated out here in Thailand. It's time to ignore these nonsense people who are out there trying to push a false narrative that somehow there's this new Global Tax regime, when there is not. Nobody has passed any legislation to this effect. Trump has affirmatively pulled America out of everything having to do with that. Thailand has never gone into OECD; I don't think it's a good idea for them to do so and frankly, I am sick and tired of this false narrative being pushed here in Thailand that this is all legitimate. It is not; it is over. This is over, okay? That's what people need to understand about all of this tax nonsense. We are basically back to where we have ever been here in the Kingdom of Thailand with respect to expats and taxation at least from the standpoint of the Americans, and again presuming Thailand doesn't actually promulgate OECD, then again, we are still at the status quo we have ever been with regard to tax policy here in the Kingdom of Thailand.