Cross-border corporate

Non-U.S. Software Company, U.S. Customer, and Withholding Tax

I received an email via Hackernews and figured I would answer it here, because this is a common question. This is likely to be the first of many discussions of this topic. For what it is worth, my username on HN is philiphodgen. Question Lightly edited (and ignoring the “how much would it cost to […]


“Simplicity is hard work. But, there’s a huge payoff. The person who has a genuinely simpler system – a system made out of genuinely simple parts, is going to be able to affect the greatest change with the least work. He’s going to kick your ass. He’s gonna spend more time simplifying things up front […]

International Tax Planning Comes Third

Tax planning across borders is complicated.  A massive public company has the budget to deal with complex international tax problems.  Privately-held businesses must deal with the same tax rules that Apple, Google, and Ford face.  But they don’t have the budget to deal with the legal and accounting costs that those highly complex rules will […]

Oh, what a tangled web we weave (Subpart F edition)

Oh what a tangled web we weave, When first we practise to deceive! Sir Walter Scott, Marmion, Canto vi. Stanza 17 I have been doing cite-checking and editing for a friend’s international tax treatise and as a result I have been living in Subpart F recently. Two interesting points here. Subpart F + Subpart G […]

Apple, $82 Billion of Cash, and Tax Policy

Via Glenn Reynolds I was pointed to a TUAW article that referenced a SeekingAlpha article about Apple, its mythical mountain of cash, and the Law of Unintended Consequences.  (That, by the way, is a demonstration of the fabulosity of the interwebs.  Hyperlinks and attributions back to the source.  The internet is just one person talking […]

List of international tax forms (first draft)

  Upcoming speech I am going to be giving a one-hour high speed presentation at the 2011 Tax Update and Planning Conference sponsored by the California Society of CPAs. It will be presented in Universal City, San Francisco, and on the web. My hour is intended to give practitioners a checklist approach to the various […]

Foreign startup, US venture capital, and taxation

I like Hacker News.  Let’s just say that I spend too much time there.  Shout-out to Ronnie Roller and his iHackernews site, because mostly I look at HN on my iPhone.  I lurk mostly, and comment infrequently.  It’s recreational for me.  I am username = philiphodgen there, FWIW. I got an email overnight from a […]