WTH Tennessee, Against Pro-Life Voters?

Posted on April 27, 2016April 27, 2016 by Denise Simon

In Tennessee, a Federal Judge Disenfranchises Pro-Life Voters

DFrench/NRO: No one should ever doubt the Left’s commitment to abortion. For the sake of preserving the right to kill an unborn child, the Left will sacrifice democracy and even reason itself. Pro-life lawyers have a term for liberal judges’ tendency to twist the Constitution for the cause of death — the “abortion distortion.” The latest example comes from Nashville, Tenn., where an Obama-appointee federal judge just wrote perhaps the least credible judicial opinion I’ve ever read. But first, some background. Before the 2014 election, Tennessee, one of America’s most conservative and religious states, had become the South’s abortion supermarket, all because of a Tennessee Supreme Court ruling that declared that the Tennessee constitution protected the “right” to an abortion to a greater degree than did even Roe v. Wade or Planned Parenthood v. Casey. Consequently, even if a pro-life law would have passed federal constitutional muster, Tennessee state courts would strike it down.

KAGSTV

Tennessee voters responded by passing Amendment 1 — a pro-life constitutional amendment that reversed the state’s high court and unequivocally declared that “nothing in this Constitution secures or protects a right to abortion or requires the funding of an abortion.” Tennessee’s amendment process is arduous. First, a proposed amendment has to pass with a majority in both houses. Then, after the next legislative election, the amendment has to pass with a two-thirds majority. Finally, it comes before the people. But even there an amendment faces a double hurdle. It has to pass with a majority of the vote, and the “yes” votes have to equal a “majority of all the citizens of the state voting for Governor.” For decades, Tennessee officials have interpreted this rule as merely requiring that the total “yes” vote exceed half of the total gubernatorial vote. In other words, a person could vote yes on the amendment and still have their vote count even if they didn’t vote for governor. In fact, amendment proponents expressly told voters that they could pursue exactly this strategy — they didn’t have to vote for governor to have their vote count.

Related: Tennessee Judge Sides With Owners of Unlicensed Abortion Clinics Against Pro-Life Law

After their loss, pro-abortion leftists sued in federal court, making the astonishing claim that this process violated the Fourteenth Amendment. Why? Because it didn’t give the “no” side enough advantages in the fight against the amendment. They claimed that Tennessee’s process violated their right to “participate on an equal basis with other citizens in the jurisdiction.” They also claimed that the Tennessee Constitution required election officials to count only the votes of people who voted for governor. So if you wanted your vote to count for the amendment, you had to vote for governor.

On Friday, Judge Kevin Sharp did what liberal federal judges do: found a way to rule for abortion rights. He backed the plaintiffs, holding that the traditional manner of counting votes for constitutional amendments violated both the state and the federal constitutions. He then ordered a statewide recount, in which only the votes of those who voted in both the amendment contest and the gubernatorial race would be counted.

In an opinion full of insulting asides and other potshots at amendment supporters, Sharp claimed that the votes of those who voted in the governor’s race but against the amendment were “not given the same weight” as those who voted for Amendment 1 but did not vote in the governor’s race. In other words, he claimed that a voter who did not vote for governor but did vote for the amendment had more influence over the process than a voter who chose to vote in both elections. Yet that additional influence was the product not of discrimination but of voter choice, of deliberate voting strategy.

The judge’s solution to this fabricated problem was to give the votes of those who voted for the amendment but not for governor no weight at all. In other words, his concern for voting rights (he called the right to vote “precious” and “fundamental”) was so strong that he just went ahead and disenfranchised thousands of voters who relied on longstanding state-government interpretations of its own constitution. Moreover, he signaled that even if a recount shows that the amendment would still pass under his new, judicially created standard, he may still rule that the election itself should be voided.

When I was in law school, one of my radical leftist professors declared that the role of a judge was to first determine the “right” result, then to manipulate law and precedent to justify the pre-ordained outcome. He turned the process of judicial reasoning on its head, and my classmates loved it. Abortion jurisprudence is the product of exactly this ideology. Sexual revolutionaries aren’t just professors, activists, and lawmakers. Some are robed Robespierres, and you can always count on them to protect the culture of death. — David French is an attorney, and a staff writer at National Review.

A Judge Issued a Gag Order, Preventing Speech

Posted on April 27, 2016April 27, 2016 by Denise Simon

Oregon Bakers Continue Legal Fight, Challenging ‘Gag Order’

Harkness/DailySignal

The Oregon bakers who were ordered to pay $135,000 for refusing to bake a cake for a same-sex wedding filed a brief with the Oregon Court of Appeals on Monday, arguing the ruling against them was biased and violates both the Oregon and U.S. constitutions.

“In America, you’re innocent until proven guilty,” said Kelly Shackelford, president and CEO of First Liberty Institute, the group representing Aaron and Melissa Klein in their legal fight. “Commissioner Brad Avakian decided the Kleins were guilty before he even heard their case. This is an egregious violation of the Kleins’ rights to due process. We hope the Oregon Court of Appeals will remedy this by dismissing the government’s case against the Kleins.”

Brad Avakian, commissioner of the Oregon Bureau of Labor and Industries, was responsible for issuing the final ruling on the case. On July 2, 2015, he ruled that in declining to bake a cake for a same-sex wedding due to their religious beliefs, the Kleins violated an Oregon law that prohibits discrimination in places of public accommodation against people based on their sexual orientation.

Avakian ordered the Kleins to pay $135,000 in mental, physical, and emotional damages to the couple whom they denied service.

Rachel and Laurel Bowman-Cryer (who have since married) filed a complaint against Sweet Cakes by Melissa in Gresham, Ore., in February 2013, a month after the Kleins refused to make a cake for the same-sex couple’s wedding.

The Bureau of Labor and Industries opened its investigation into Sweet Cakes by Melissa in August 2013, six months after the agency received the initial complaint from Rachel and Laurel Bowman-Cryer alleging the bakery owners discriminated against them.

Yet, in the appeal brief filed Monday, lawyers for the Kleins argued that Avakian had publicly declared the Kleins guilty before even waiting for an investigation to take place, citing a Feb. 5, 2013, Facebook post.

In that post, Avakian writes, “Everyone has a right to their religious beliefs, but that doesn’t mean they can disobey laws that are already in place. Having one set of rules for everybody ensures that people are treated fairly as they go about their daily lives.”

In August 2013, after the Oregon Bureau of Labor and Industries announced it was opening an investigation to determine whether the Kleins had discriminated against the same-sex couple, Avakian also commented about the case, suggesting he had already decided that the Kleins were guilty. “Everybody is entitled to their own beliefs,” he said in an interview with The Oregonian, “but that doesn’t mean that folks have the right to discriminate.”

“The goal is never to shut down a business. The goal is to rehabilitate,” Avakian added.

Ken Klukowski, an attorney at First Liberty, told The Daily Signal that “it’s clear” Avakian demonstrated bias “that rises to the level of violating due process.”

In addition to ruling the Kleins must pay $135,000, Avakian also ordered the former bakery owners to “cease and desist” from speaking publicly about not wanting to bake cakes for same-sex weddings based on their Christian beliefs.

“The Commissioner of the Bureau of Labor and Industries hereby orders [Aaron and Melissa Klein] to cease and desist from publishing, circulating, issuing or displaying, or causing to be published … any communication … to the effect that any of the accommodations … will be refused, withheld from or denied to, or that any discrimination be made against, any person on account of their sexual orientation,” Avakian wrote in the final order.

The justification for this part of his final order originates from an interview Aaron and Melissa Klein participated in with Family Research Council’s Tony Perkins in 2014. During the interview, Aaron said that they, “don’t do same-sex weddings,” and “This fight is not over. We will continue to stand strong.”

Avakian wrote those statements demonstrate a “prospective intent to discriminate.”

“This gag order that they’re under right now, where they have been ordered by the government that they can’t even discuss these things with the media,” Klukowski said, “is shockingly overbroad.”

“There are aspects of their beliefs and of this case, including aspects of their religious beliefs about marriage, that if they were to share these things publicly, that the government could punish them, saying that it amounts to the equivalent of advertising their intention to continue engaging in illegal discrimination,” Klukowski said.

“That censors so much protected speech.”

The punishment for violating the order is “notoriously unspecific,” Klukowski added. Because of that, lawyers for the Kleins are treading carefully on what they allow their clients to do and say in public.

“This is a couple with young children and where the law does not specify what the most severe penalty could be where as far as we know, the sky could be the limit, that’s where we owe it to our clients to err on the side of caution and try to shield them from additional exposure that could have consequences of unspecified severity,” he said.

In reviewing the appeal, the Oregon Appeal Court will determine whether or not the Oregon Bureau of Labor and Industries violated the Kleins’ constitutional rights to religious freedom, free speech, and due process.

The Kleins maintain that they did not decline the same-sex couple due to their sexual orientation—stating in the brief that they have served one of the women who filed the complaint against them in the past. Instead, they maintain they were only declining to participate in an event that they disagree with because of their Christian beliefs about marriage.

Avakian ruled there is “no distinction” between the two situations.

Klukowski said he expects oral arguments to take place later this year. If the Oregon Court of Appeals rules against the Kleins, the next step would be appealing to the Oregon Supreme Court.

A New Scheme for Syrian Refugees?

Posted on April 26, 2016April 26, 2016 by Denise Simon

Infographic: The screening process for refugee entry into the U.S.
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Refugees Welcome graphic — **By the numbers: What you need to know about Syrian refugees in the U.S.**
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“Alternative Safe Pathways” for Syrian Refugees – Resettlement in Disguise?

By Nayla Rush

CIS.org: With the Syrian crisis entering its sixth year, the United Nations High Commissioner for Refugees (UNHCR) is thinking of “innovative approaches” to organize Syrian admissions, alongside the refugee resettlement program, to countries willing to welcome them. UNHCR’s target for resettlement is 480,000 places over the next three years; it is not sure how many additional admissions into the U.S. and elsewhere these new “alternative safe pathways” will ensure. Refugees who are not resettled could be “legally admitted” using various routes described below.

The legitimacy and transparency of these new “alternative pathways,” aimed at admitting increasing numbers of Syrian refugees into the United States without calling them “refugees,” remain to be seen. They might even amount to convenient admissions detours at a time when the U.S. refugee resettlement program is under tight scrutiny.

In a panel discussion on The Global Refugee Crisis: Moral Dimensions and Practical Solutions organized by the Brookings Institution earlier this year, Beth Ferris, Research Professor at Georgetown University and adviser to the United Nations Secretary General on humanitarian refugee policy, talked about the need to find different solutions to the ongoing humanitarian Syrian crisis. The refugee resettlement program was no longer sufficient to admit Syrian refugees she said; “alternative safe pathways” are needed:

Refugees and government officials are expecting this crisis to last 10 or 15 years. It’s time that we no longer work as business as usual … UNHCR next month [March 2016] is convening a meeting to look at what are being called “alternative safe pathways” for Syrian refugees. Maybe it’s hard for the U.S. to go from 2,000 to 200,000 refugees resettled in a year, but maybe there are ways we can ask our universities to offer scholarships to Syrian students. Maybe we can tweak some of our immigration policies to enable Syrian-Americans who have lived here to bring not only their kids and spouses but their uncles and their grandmothers. There may be ways that we could encourage Syrians to come to the U.S. without going through this laborious, time-consuming process of refugee resettlement.” (Emphasis added.)

The UNHCR conference Ferris was referring to took place in Geneva this March 30. It is one of a series of initiatives aimed at comprehensively addressing the Syrian crisis in 2016. The Geneva “High-level meeting on global responsibility sharing through pathways for admission of Syrian refugees” focused on the need for a substantial increase in resettlement numbers and for “innovative approaches” to admit Syrian refugees. It followed February’s London Conference on Syria, which stressed the financial aspect of this humanitarian crisis ($12 billion pledged in humanitarian aid) and precedes a September 2016 high-level plenary meeting of the United Nations General Assembly in New York. Worthy of note here, President Obama will host a global refugee summit this September 20 on the margins of this upcoming General Assembly meeting.

The focus of the Geneva meeting was to introduce “other forms of humanitarian admissions” since “[r]esettlement is not the only aim”, explained UNHCR’s spokesperson. UN High Commissioner for Refugees Filippo Grandi appealed to the international community in his opening statement, calling for “alternative avenues” for the admission of Syrian refugees:

These pathways can take many forms: not only resettlement, but also more flexible mechanisms for family reunification, including extended family members, labour mobility schemes, student visa and scholarships, as well as visa for medical reasons. Resettlement needs vastly outstrip the places that have been made available so far… But humanitarian and student visa, job permits and family reunification would represent safe avenues of admission for many other refugees as well.

At the end of the meeting, Grandi highlighted several commitments made by a number of participants in his closing remarks. Promises were made to:

Increase the number of resettlement and humanitarian admission places.

Ease family reunification and increase possibilities for family reunion.

Give scholarships and student visas for Syrian refugees.

Remove administrative barriers and simplify processes to facilitate and expedite the admission of Syrian refugees.

Use resources provided by the private sector in order to create labor mobility schemes for Syrian refugees.

The Geneva meeting was attended by representatives of 92 countries, including the United States. Heather Higginbottom, Deputy Secretary of State for Management and Resources, reiterated in her remarks the U.S. commitment to refugees: “President Obama has made assisting displaced people a top priority for the U.S. government.” Last year alone the U.S. contributed more than $6 billion to humanitarian causes. So far this year, the United States has provided nearly $2.3 billion in humanitarian assistance worldwide. She also announced additional measures: “We are further increasing our support of Syrian refugees, and we will make additional contributions to the global displacement effort through September, and beyond”, while reminding the participants of President Obama’s role in hosting a high-level refugee summit this September.

The U.S. State Department released a Media Note following the Geneva meeting. It confirmed the goal of resettling at least 10,000 Syrians in FY 2016 and of 100,000 refugees from around the world by the end of FY 2017 – an increase of more that 40 percent since FY 2015. It also announced the following:

“The United States pledged an additional $10 million to UNHCR to strengthen its efforts to identify and refer vulnerable refugees, including Syrians, for resettlement.”

“The United States joins UNHCR in calling for new ways nations, civil society, the private sector, and individuals can together address the global refugee challenge.”

“Additionally, the United States has created a program to allow U.S. citizens and permanent residents to file refugee applications for their Syrian family member.” [Emphasis added.]

On this last note, why create a family reunification program for Syrian refugees when refugees in the U.S. are already entitled to ask for their spouse and unmarried children under 21 to join them? Unless of course, the aim is to widen family circles to include aunts and uncles, brothers and sisters, grandmothers and grandfathers.

Let’s see if we got this right: More Syrian refugees are to be resettled in the United States; administrative barriers (including security checks?) are to be removed to expedite admissions. Come to think of it, this is exactly what we witnessed with the “Surge Operation” in Jordan, where refugee resettlement processes were reduced from 18-24 months to three months in order to meet the target of 10,000 Syrian refugees this year.

Moreover, the United States government, by its own admission, “joins UNHCR in calling for new ways” to move more Syrians to other countries. With the U.S. Refugee Resettlement program under close scrutiny, other routes for “legal admissions” (not “resettlement”) of Syrian refugees into the United States seem more appropriate. Those routes may vary from private sponsorships, labor schemes, expanded family reunification programs, humanitarian visas, medical evacuation, to academic scholarships and apprenticeships, etc.

What remains to be determined is how transparent these “alternative pathways” will be. Will we be given details about numbers, profiles, locations, screening, or costs? Also, what additional measures are we to expect from this administration as it prepares to host a Global Refugee Summit this September 20?

Meanwhile, we are left to wonder: aren’t these “pathways” for refugees nothing more than disguised resettlement routes? Akin to “pathways to citizenship” in lieu of amnesty…

Classified Obamacare Documents?

Posted on April 26, 2016April 26, 2016 by Denise Simon

The House Oversight and Government Reform Committee, filed the subpoenas in 2013, see the announcement here. In part:

The Committee initially requested information on the CO-OP program in October 2012 and again in March 2013. A June 7, 2013 letter to Secretary Sebelius stated, “[T]his delay is unacceptable and your lack of transparency is troubling.”

The Obamacare CO-OP program used taxpayer money to loan $2 billion to companies establishing non-profit health insurance issuers. However, the Office of Management and Budget estimated the taxpayer losses for the loans at 43.2 percent. Moreover, several companies have experienced legal or financial troubles. For instance, the Vermont Health Co-op, which received a $34 million taxpayer-backed loan, was last month denied an insurance license by the state of Vermont. In letters to HHS, the Committee expressed concern that the process used to select loan recipients was flawed and lacked transparency.

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The Obamacare co-ops are tax-funded non-profit entities that were supposed to compete with private insurance companies. In this, they have failed spectacularly. In the last couple of years, 12 of the co-ops have shut their doors, costing doctors and hospitals million of dollars in losses. This year, some experts are predicting that up to 8 of the 11 remaining co-ops will go under as well. More here from AmericanThinker.
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IBD: Being the “most transparent administration” in history apparently doesn’t mean complying with a congressional subpoena to find out why more than half of the ObamaCare co-ops have failed.

That’s what the House Oversight and Government Reform Committee is learning, at least. It has subpoenaed information relating to the 23 nonprofit co-op insurance companies that ObamaCare established with $2.5 billion in government loans.

The co-ops were supposed to provide price competition against commercial insurers, but last year many pushed for and got huge, double-digit rate hikes. Even so, more than half of the 23 set up have failed already, and it’s likely that eight more will collapse this year.

Given that taxpayers are on the hook for billions in loans that might never get repaid, it is only fitting that Congress should find out what went wrong and why.

But instead of providing answers, the Obama administration is stonewalling.

Oversight Committee Chairman Jason Chaffetz said at a hearing this week, “Health and Human Services has not provided any valid legal reason for withholding information from this committee.”

The committee demanded documents back in November that would shed light on how the administration picked these co-ops, how much money has been spent and what plans the administration has to get federal loan money back from failed co-ops.

Chaffetz says that Obama officials merely “assert that if certain information was released publicly, it could cause consumers to think twice before enrolling in co-op insurance plans.”

That makes absolutely no sense. If other co-ops are likely to fail, then consumers should be aware of it, so they can avoid having their coverage disrupted midyear, which could mean changing doctors, paying higher out-of-pocket costs and so on.

This is hardly the first time that the administration has stonewalled congressional inquiries. If anything, it seems to be the unstated policy of the Obama administration.

In addition to the ObamaCare documents, for example, the Oversight Committee is battling to get documents related to the EPA’s massively expensive water regulations, the Department of Homeland Security’s policy on airport credentialing, the massive hack of government employee records and so on.

Obama officials get away with concealing anything and everything that might prove embarrassing or controversial because the “speaking truth to power” mainstream press largely ignores the stonewalling. So the White House doesn’t suffer any consequences or feel any pressure to change.

You can bet the media’s lackadaisical attitude about government transparency will suddenly change if a Republican ends up in the White House next year. But in the meantime, we may never get a clear answer to why the Obama administration flushed $2.5 billion in taxpayer money down the drain.

Why Trump Refuses to Release Tax Returns?

Posted on April 26, 2016April 26, 2016 by Denise Simon

The Panama Papers scandal led to many wealthy elites across the world being exposed for in many cases illicit financial transactions. Further, continued investigations by journalists have exposed the likes of John Kerry and the Hillary campaign leaders, a little known obscure address in Delaware. While tax havens are not illegal due to loopholes in the tax code, those that exploit them call into question how and why the tax havens are used in the first place. Humm….Trump will not release his tax returns until after the convention.

Enter the Clintons and oh…Donald Trump.

Trump and Clinton share Delaware tax ‘loophole’ address with 285,000 firms

1209 North Orange Street in Wilmington is a nondescript two-storey building yet is home to Apple, American Airlines, Walmart and presidential candidates

TheGuardian: There aren’t many things upon which Hillary Clinton and Donald Trump agree, especially as they court very different Delaware voters ahead of a primary on Tuesday. But the candidates for president share an affinity for the same nondescript two-storey office building in Wilmington. A building that has become famous for helping tens of thousands of companies avoid hundreds of millions of dollars in tax through the so-called “Delaware loophole”.

The receptionist at 1209 North Orange Street isn’t surprised that a journalist has turned up unannounced on a sunny weekday afternoon.

“You know I can’t speak to you,” she says. A yellow post-it note on her computer screen reads “MEDIA: Chuck Miller” with the phone number of the company’s director of corporate communications. Miller can’t answer many questions either, except to say that the company does not advise clients on their tax affairs.

The Guardian is not the first media organisation to turn up at the offices of Corporation Trust Centre, and it’s unlikely to be the last.

This squat, yellow brick office building just north of Wilmington’s rundown downtown is the registered address of more than 285,000 companies. That’s more than any other known address in the world, and 15 times more than the 18,000 registered in Ugland House, a five-storey building in the Cayman Islands that Barack Obama called “either the biggest building in the world, or the biggest tax scam on record”.

Officially, 1209 North Orange is home to Apple, American Airlines, Coca-Cola, Walmart and dozens of other companies in the Fortune 500 list of America’s biggest companies. Being registered in Delaware lets companies take advantage of strict corporate secrecy rules, business-friendly courts and the “Delaware loophole”, which can allow companies to legally shift earnings from other states to Delaware, where they are not taxed on non-physical incomes generated outside of the state.

The loophole is said to have cost other states more than $9bn in lost taxes over the past decade and led to Delaware to be described as “one of the world’s biggest havens for tax avoidance and evasion”.

But it’s not just big corporations that have chosen to make 1209 North Orange their official home.

Both the leading candidates for president – Hillary Clinton and Donald Trump – have companies registered at 1209 North Orange, and have refused to explain why.

Clinton, who has repeatedly promised that as president she will crack down on “outrageous tax havens and loopholes that super-rich people across the world are exploiting in Panama and elsewhere”, collected more than $16m in public speaking fees and book royalties in 2014 through the doors of 1209, according to the Clintons’ tax return.

Just eight days after stepping down as secretary of state in February 2013, Clinton registered ZFS Holdings LLC at CTC’s offices. Bill Clinton set up WJC LLC, a vehicle to collect his consultation fees, at the same address in 2008.

A spokesman for Clinton said: “ZFS was set up when Secretary Clinton left the State Department as an entity to manage her book and speaking income. No federal, state, or local taxes were saved by the Clintons as a result of this structure.”

The Clintons’ companies share the office with several of Trump’s companies. They include Trump International Management Corp and several companies that form part of Hudson Waterfront Associates, a Trump partnership to develop more than $1bn worth of luxury condos on the west side of Manhattan.

Of the 515 companies on Trump’s official Federal Election Commission (FEC) filing, 378 are registered in Delaware, he revealed, after being questioned by the Guardian about why so many of his New York-based companies are incorporated in Delaware.

He said he asked his staff to find out how many entities he has in Delaware. “I figured they’d maybe say two or three, right?” Trump said at a rally in Harrington, Delaware, on Friday. “We have 378 entities registered in the state of Delaware, meaning I pay you a lot of money, folks. I don’t feel at all guilty, OK?”

Among them are 40 Wall Street Corporation, Trump’s 72-storey downtown tower that was the tallest building in the world for two months in 1930, and the Trump Carousel in Central Park.

The Trump campaign did not respond to questions about whether Trump was using Delaware in order to avoid taxes in New York.

It is not unusual for rich individuals and companies to register their business in Delaware due to the ease of company formation in the state, but the Clintons’ and Trump’s companies in the state are likely to come under greater scrutiny as the US presidential primary roadshow rolls into the state on Tuesday. A poll by research firm Gravis Marketing last week showed Trump had a 37-point lead over John Kasich; Clinton polled 45%, ahead of Sanders on 38% in the same poll.

A report by the Institute on Taxation and Economic Policy, titled Delaware: An Onshore Tax Haven, said the state’s tax code made it “a magnet for people looking to create anonymous shell companies, which individuals and corporations can use to evade an inestimable amount in federal and foreign taxes”.

Several accounting experts said there are many legitimate reasons why US and foreign companies incorporate in Delaware, particularly because of its highly respected Court of Chancery and business-friendly state government. The process of setting up a company in the state can be completed in just a few hours and requires less paperwork than registering for a library card in the state. There are more than 1m companies registered in the state – more than Delaware’s population of 935,000.

In the US presidential election, Clinton’s rival Bernie Sanders has led the charge to counter corporate greed, and highlighted the tax havens revealed by the Panama Papers as evidence that “the wealthiest people and largest corporations must start paying their fair share of taxes”.

Clinton has called offshore tax havens “a perversion” of the legal code, and Obama called for reform of the international system earlier this month. Even Trump has said he supports raising taxes on the wealthiest Americans, “including myself”, though his tax plan offers cuts.

The Guardian Media Group, owner of theguardian.com, is registered in Dover, Delaware. “Guardian Media Group has business operations in the UK, US and Australia,” a Guardian spokesperson said. “The group’s assets are held entirely by companies in these countries and are fully subject to prevailing tax laws and regulations. The group also has a UK endowment fund which holds a mixture of UK and non-UK assets and is fully subject to UK tax laws and regulations.”