The IRS War on Medical Marijuana Providers [FEATURE]

special to Drug War Chronicle by investigative reporter Clarence Walker, [email protected]

Dispensaries providing marijuana to doctor-approved patients operate in a number of states, but they are under assault by the federal government. SWAT-style raids by the DEA and finger-wagging press conferences by grim-faced federal prosecutors may garner greater attention, but the assault on medical marijuana providers extends to other branches of the government as well, and moves by the Internal Revenue Service (IRS) to eliminate dispensaries' ability to take standard business deduction are another very painful arrow in the federal quiver.

The IRS employs Section 280E, a 1982 addition to the tax code that was a response to a drug dealer's successful effort to claim his yacht, weapons purchases, and even illicit bribes as business expenses. Under 280E, individuals involved in the illicit sale of controlled substances -- including marijuana, even medical marijuana in states where it is legal -- cannot claim standard business expenses on their federal taxes.

"The 280E provision which requires certain businesses to pay taxes on their gross income, as opposed to their net income, is aimed at shutting down illicit drug operations, not state-legal medical marijuana dispensaries," said Kris Hermes, spokesman for the medical marijuana defense group Americans for Safe Access." Nonetheless, the Obama Administration is using Section 280E to push these local and state licensed facilities out of business."

The provision can be used to great effect. Oakland's Harborside Health Center was hit with a $2 million IRS assessment in 2011 after the tax agency employed Section 280E against. Harborside is fighting that assessment, even as it continues to try to fend off federal prosecutors' attempts to shut it down by seizing the properties it leases. Similarly, when the feds raided Richard Lee's Oaksterdam University that same year, it wasn't just DEA, but also IRS agents who stormed the premises. Lee said it was because of a 280E-related audit.

The attacks on Harborside and Oaksterdam were part of an IRS campaign of aggressive audits using 280E to deny legitimate business expenses, such as rent, payroll, and all other necessary business expenses. These denials result in astronomical back tax bills for the affected dispensaries, threatening their viability -- and patients' access to their medicine.

"Should the IRS campaign be successful; it will throw millions of patients back in to the hands of street dealers; eliminate tens of thousands of well paying jobs, destroy hundreds of millions of dollars of tax revenue; enrich the criminal underground; and endanger the safety of communities in the 17 medical cannabis states," said Harborside's Steve DeAngelo as he announced the 280E Reform Project to begin to fight back.

It's going to be an uphill battle. In the last Congress, Rep. Pete Stark (D-CA) introduced House Bill 1985, the Small Business Tax Equity Act, designed to end the 280E problem for medical marijuana businesses, but it went to the Republican-controlled House Ways and Means Committee, where it was never heard from again.

Still, something needs to happen, said Betty Aldworth, deputy director of the National Cannabis Industry Association, which this year is working with members of Congress to try to find a fix for the 280E problem.

"When Section 280E was created in the 1980s, no one imagined state-legal marijuana providers," Aldworth told the Chronicle. "Whether or not it is part of a larger effort to curtail the development of regulated models for providing marijuana, which is a model that is clearly preferable to leaving this popular and relatively safe medicine (or adult product) in the underground market, these onerous tax rates have severely hampered the development of the regulated market."

It's a brake on the overall economy, Aldworth said.

"Not only has it resulted in stymieing job development, but it also curtails other economic activity such as reinvestment in business and the rippling positive effects of that spending," she argued. "And in many cases, it has created a tax burden that is simply unbearable: many providers have had to close their doors and lay off their staffs because the tax burden was simply too great."

Because of this unintended application of 280E, medical marijuana providers are paying overall taxes at a rate two to three times those of other small businesses, Aldworth said.

"It's important to note that just as they want to apply for licenses, follow regulations, and otherwise participate in the legal business community, state-legal marijuana providers also want to pay their fair share of taxes," she pointed out. "Most small businesses pay an effective tax rate of between 13% and 27% on net income, according to the Small Business Administration. State-legal marijuana providers pay an average effective tax rate of 65-80%. An industry that can provide thousands of jobs is being held back by these crazy tax rates."

While the lobbyists look to Congress for a fix, one academic tax law expert thinks he has hit upon a novel solution, but not everyone agrees.

Benjamin Leff, a professor at American University's Washington College of Law, raised eyebrows at a Harvard University seminar this spring when he presented his report,Tax Planning For Marijuana Dealers, where he suggested that dispensaries get around 280E by registering with the IRS as tax-exempt social welfare organizations, known as 501(c)(3)s or 501(c)(4)s.

The IRS has already ruled that medical marijuana providers can be exempt under 501(c)(3) because its "public policy doctrine" does not allow charitable organizations to have purposes contrary to law, but in the paper, Leff argued that "a state-sanctioned marijuana seller could qualify as tax-exempt under 501(c)(4), since the public policy doctrine only applies to charities, and 501(c)(4) organizations are not charities."

The organization would have to be operated to improve the social and economic conditions of a neighborhood blighted by crime or poverty, by providing job training, employment opportunities, and improved business conditions for commercial development in the neighborhood, just like many existing community economic development corporations that run businesses.

"When taxes get too high, you can drive compliant dispensaries out of business," Leff told the Chronicle.

Americans for Safe Access' Hermes would agree with that, but he's not so sure about Leff's idea.

"The concept of medical marijuana dispensaries registering with the federal government as a 501(c)(4) in order to sidestep section 280E is novel and may be hypothetically valid," he said. "However, the IRS will refuse to grant tax-exempt status to a business that the agency believes is violating federal law. Perhaps, it would be possible for a dispensary to obtain 501(c)(4) status under false pretenses, but such status would not very likely withstand an IRS audit."

There are better ways, he said.

"A much more realistic and sensible approach -- pending a change to the federal classification of marijuana for medical use -- is to amend the tax code to exclude state-lawful medical marijuana businesses from Section 280E," Hermes recommended. "This is the kind of legislation that Congress should pass in order to allow states to implement their own medical marijuana laws, without undue interference by the federal government."

"I agree with everything he said," Leff replied. "But it's not just the Obama administration that is using 280E this way. The Supreme Court has held that there is no exception to the Controlled Substances Act for state-level legal marijuana sales, and since 280E makes references to Schedule I controlled substances, it applies to legal marijuana unless Congress changes the law. I totally agree that Congress should amend 280E to exempt marijuana selling that is legal under state law. Congress could also amend the Controlled Substances Act to remove marijuana from it, which would probably also make sense," he added.

Whether it is by act of Congress, internal policy shifts, or creative thinking by law school professors, some way has to be found to exempt state-permitted medical marijuana providers from the clutches of 280E and its punitive tax burden aimed at dope dealers, or there may not be any medical marijuana providers.

Permission to Reprint: This article is licensed under a modified Creative Commons Attribution license.
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Karachi has always been a commercial hub and is known for its thriving economy. It is also home to world-class hotels, shopping malls, restaurants and other entertainment venues. Karachi SPA provides a wide range of massage services in Karachi including full body massage, happy ending massage, body to body massage etc. The spa also offers different packages for its customers depending on the type of service they are looking for. For example, the day package includes one hour of service from 11 am to 12 pm whereas the evening package includes one hour of service from 6 pm to 7 pm. Karachi is one of the most populous cities in Pakistan. It is also the country’s largest city, and the world’s 4th largest city with a population of 25 million.

There are many massage centers in Karachi that offer full body massage, happy ending massage and body to body massage. We provide you with a list of some of the best SPA in Karachi that offer all types of massages at affordable rates. The Karachi Massage Center is one of the most popular massage centers in Karachi. It offers full body massage, happy ending massage, and body to body massage services to its customers. They have a team of skilled masseurs who are experts in their respective fields and can provide a therapeutic or sensual experience depending on what the customer needs. They offer a wide range of massages including Swedish, Thai, Aromatherapy and Ayurveda Massages.

Karachi is one of the most populous city in Pakistan. It is not only a commercial hub but also a tourist attraction. Karachi is also known for its nightlife and SPA centers. Karachi, being the largest port city in Pakistan, has an amazing coastline with many beaches that are available for public use. The beaches in Karachi are not only clean but also well maintained. Karachi SPA provide a variety of massage services that cater to all kinds of needs and requirements. We provide the best massage services in Karachi at reasonable prices so our clients can enjoy their stay in this beautiful city to the fullest.

The SPA in Karachi is the best massage center in Karachi. The spa provides a wide range of services for both men and women. They offer different types of massage including full body, body to body, and happy endings.

KARACHI SPA - THE BEST MASSAGE CENTER IN KARACHI

Karachi Spa is a premier therapeutic massage center in Karachi that offers a range of services for both men and women. They offer different types of massages including full body, body to body, and happy endings in order to provide the best experience to their clients. Karachi is the capital city of Sindh province in Pakistan. It is the country's largest city, and serves as the country's economic and cultural hub. The massage therapy industry has been booming in Karachi with a lot of people looking for relaxation. With so many people looking for a good massage, there are a lot of spas that have been popping up to cater to this need. karachivipspa.com is the best place for you to have a massage and experience the most amazing relaxation. Karachi SPA offers full body massage, body to body massage, happy ending massage and much more.

The Dhaspakrachi.com is a massage center in Karachi, Pakistan. They are famous for their Full Body Massages, Happy Ending Massages and Body to Body Massages. Karachi is the capital of Sindh Province and one of the most populous cities in Pakistan. Karachi is a cosmopolitan city where you can find anything, from a traditional Pakistani bazaar to modern shopping malls. There are many massage centers in Karachi that offer a variety of services, such as Full Body Massage, Happy Ending Massage, and Body-to-Body Massage. A massage center can be found on every street corner in Karachi. If you want to find out more about these services and prices then contact 03255993523 SPA in Karachi.

Karachi, being the largest city of Pakistan, has a lot to offer in terms of entertainment. One of the most popular things to do is to go for a massage. The best massage service providers are found in Karachi. They provide services at affordable prices and with excellent customer satisfaction. Massage in Karachi is a massage center in Karachi that offers multiple types of massage services. Their services include Full Body Massage, Happy Ending Massage, Body to Body Massage and more. They offer a variety of packages for their customers and provide different facilities like a Jacuzzi and steam room.

Full body massage in Karachi helps in relaxation, injury recovery, and weight loss. It also improves blood circulation and reduces stress levels. The Happy Ending massage is the most popular service among all the other ones because it offers sexual release to the customer after completing their session.

A massage is a manual therapy that uses pressure on the body to relieve stress and promote relaxation. It also reduces muscle tension, improves blood circulation, and promotes general well-being. Massage Services in Karachi are one of the most popular massage centers in Karachi. They offer a wide range of services including Full Body Massage, Happy Ending Massage in Karachi, Body to Body Massage, Swedish Massage and more.

The SPA in Karachi offers professional massage therapists who are skilled in various techniques like Swedish massage which is a type of massage that focuses on long strokes. The spa is an oasis of relaxation and tranquility. It offers a range of services to clients, including the traditional massage, body treatments, and beauty treatments. Some of the most popular services at the spa are full body massage, happy ending massage, and body to body massage.

Karachi SPA is a massage center in Karachi. It provides full body massages, happy endings and body to body massages. pk.vipkarachigirls.net is the best massage center in Karachi. It has the most experienced masseuses and offers all kinds of services at affordable prices. A massage is a manual therapy for the purpose of improving the health and well-being of an individual. It can also be used to improve circulation, relieve pain, and help with stress relief.

The Karachi SPA 03255993523 provides some of the best massage services in Karachi. They offer a variety of different massages such as full body massage, happy ending massage and body to body massage in Karachi. Karachi is a city in Pakistan. It is the most populous city in the country and has an estimated population of over 18 million people. Karachi is a major port on the Arabian Sea and is one of the largest cities in Asia. The following are some of the best spas and massage centers in Karachi for relaxation, rejuvenation, and other personal care services.

The Karachi spa offers different types of massages for all types of customers including full body massage, happy ending massage, body to body massage, etc. The prices are very affordable ranging from PKR 7400 to PKR 12000 depending on what type of service you want to get done. Karachi is the city of lights and it is also known for its nightlife. People from all over the country come to Karachi for work, entertainment or just to visit the city. But with all the hectic lifestyle and busy schedules, one must find time for themselves. Massages are a great way to relax after a long day at work or after a party night.

Karachi SPA offers a variety of massage services in Karachi including Full Body Massage, Happy Ending Massage and Body-to-Body Massage. All these massage services are available at affordable rates so you can enjoy them anytime you want without worrying about your budget. So why not book an appointment now?

The services are available in the following areas of Karachi:

Karachi is a city with a lot of people who are stressed out and tense. It is the city with the most traffic in Pakistan. The pollution, heat and the noise can take a toll on your mental health if you don't have time to relax. That is why there are many massage center Karachi that offer massage services to help you relieve stress and tension. Karachi has many spas that offer different types of massages. You can get a full body massage, body-to-body massage, happy ending massage or foot massage at any of these spas in Karachi.

Incredible Performance from World Cup day 8 matches yesterday

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