“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 and in the long haul he’s gonna wipe the plate with you because he’ll have that ability to change things when you’re struggling to push elephants around.”
— Rich Hickey, Creator of the Clojure programming language
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 trigger. And more importantly, they cannot afford the opportunity cost—top management will spend too much time wrestling with tax problems, and not enough time running the business.
Let’s call these companies mini-multinationals. Multinational because they do business in more than one country, and mini because they aren’t huge, whatever your definition of “huge” may be. ... continue reading
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 = Subpart F
The first is of interest to tax lawyers only. When we say “Subpart F” we are wrong. The subject matter is actually contained in Subpart F and Subpart G. I never realized this until last night, while perusing a footnote.Start with a lie .... continue reading
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 to another.)
Back to tax policy and unintended consequences. This stuff is right up my alley because this type of tax planning is What We Do here at the Hodgen Law Group Tax Ranch & Rocket Factory.
Put this blog post under the heading of “Unintended Consequences of International Tax Policy.”
Apple Inc.... continue reading