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  1. Re:Double Irish on Obama Proposes One-Time Tax On $2 Trillion US Companies Hold Overseas · · Score: 5, Informative

    The problem is that this money is not exclusively earned abroad. Large companies can easily setup shell "holding" companies that own their IP licensing and use transfer pricing to pull fund legitimately earned in countries where they would owe tax out to the tax havens by use of internal licensing fees. And since the US corporate taxes are on profits and not revenue, this internal transfer of funds is heavily abused by anyone with a half-way competent accounting department.

    Overly Simplified Example:
    Revenue: $100M
    Fictitious Licensing Cost of already developed internal system: $80M
    Staffing Costs: $10M
    =============
    Taxable Income: $10M instead of $90M
    Effective Tax: $3.5M instead of $31.5M
    Evaded Tax: $28M

  2. Re:No general consensus on Nanoscale Terahertz Optical Switch Breaks Miniaturization Barrier · · Score: 1

    "There is a general consensus that ultimately photons will replace electrons running through wires in most of our microelectronic devices."

    No there isn't.

    We know that for silicon CMOS, Moore's law is starting to slow down and further miniaturisation is becoming much more expensive. We know that if the complexity and efficiency of microelectronics is to continue improving at its current or past pace, we'll probably have to move to something other than silicon. There are multiple possibilities, including carbon (graphene or nanotubes), semiconductors other than silicon, titanium dioxide memristors and other more exotic things. Maybe one of these technologies will enable us to push computing closer to its physical limits. Maybe more than one. Maybe none of them will, and eventually we'll just have to be satisfied with gradually refining and optimising silicon CMOS techniques even further. Optical computing has attracted some criticism about its prospects: http://www.nature.com/nphoton/... (sorry for the paywall).

    There is no consensus at this point that any particular technology, optical or otherwise, is one of the next major steps in microelectronics.

    I think the point that was being made is that optical will eventually replace all electrical connections. It was not saying the only jump to be from Silicon -> Optical, but rather will ultimately be replaced by Optical as a faster medium just like the advances we saw by deploying Fiber Optic cables (and the more recent push for optical-based network switches to replace existing electrical). Realistically the full Optical transition is still years away and you are likely correct that we will move to on of the other transitional architectures that are still electrical-based in the mean time.

  3. Re:Different jobs, different needs on iRobot CEO: Humanoid Robots Too Expensive To Be the Norm · · Score: 1

    I would gladly pay $10k or even $50k for a robot that could prepare dinner, clear the table, wash the dishes, do laundry, vacuum, babysitting, etc.

    Starting off the You must embrace your robotic overlord indoctrination early on?

  4. Re:historically inaccurate on Why Is US Broadband So Slow? · · Score: 1

    My internet is never gridlocked like the government roads are.

    Really? My internet through Comcast is great and I get the speeds I pay for, but only during non-peak times much like non-rush hour traffic on the roads. However, the speeds are abysmal on nights and weekends much like rush hour traffic to and from work.

    We can add as many lanes as we would like to the expressways (internet backbones, e.g. cogent) to try and ease congestion, but at the end of the day it is the exit ramps (ATT/Verizon/Comcast/TWC/etc cross-carrier connections) and the local "last mile" roads (ISP to home) that still trigger contention within the system. Unless we improve the infrastructure at all levels, we will always encounter a bottleneck.

  5. Re:So much for competition on Backdoor Discovered In Netgear and Linkys Routers · · Score: 1

    "Linksys (...) devices are made by Sercomm, meaning that Cisco, Watchguard, Belkin (...)"

    It reminds me that scary graph where half a dozen companies control almost all the stuff you see on supermarket shelves. I remember reading nice fairy tales in school about open markets, and fair and diverse competition being paramount to the western economic model...

    Sorta like these conglomerates? Just to name a few :)

  6. Re:Someone important *should* take the blame on How Healthcare.gov Changed the Software Testing Conversation · · Score: 1

    Bullshit. The President doesn't write code.

    His staff was saying, in the week before the website went live, that everything would be great. That's on him, for not knowing (or lying?) about the state of the website.

    Perhaps that was in part due to CGI Federal SVP in charge of the Healthcare.gov project, Cheryl Campbell, testifying before the House of Representatives September 10, 2013 that the project was still on track [video - Testimony starting around 36m20s.] & [pdf]. While some of the other organizations present during this testimony were flagging issues, the primary contracting organization was communicating that the project was still on track and would be ready for the October 1, 2013 launch.

    If the key players in the project are communicating an "all clear" up the chain, it is difficult for anyone outside of these organizations to ascertain possible issues as they are not receiving information about the regular day-to-day. The Government's response (contracting Google/Redhat/Oracle) to the situation once they learned the truth was a management-base response to them finally receiving real information. Had Middle Management (Read: CGI Federal) properly communicated the issues earlier, the Government may have been able to enact a gauged response earlier that could have avoided the debacle.

  7. Re:Good. on UK Court Orders Two Sisters Must Receive MMR Vaccine · · Score: 4, Insightful

    Pregnancy isn't an illness.

    Exactly. It's just a parasitic relationship.

  8. Re:YOLD! on Battlefield Director: Linux Only Needs One 'Killer' Game To Explode · · Score: 2

    I'm thinking SteamOS is going to have some problems running on a PowerPC device. :)

    Well, I suppose it's good that Apple switched to Intel and the x86 architecture in 2005 and dropped support for PPC chips in 2009...

  9. Re:Obamaphone on Obama Administration Refuses To Overturn Import Ban On Samsung Products · · Score: 5, Informative

    Apple will be quick to inform you that all profits are made by their Irish subsidiary and are not subject to US corporate taxes.

    So why do they pay so much in US taxes?

    Umm... they don't. According to their 2012 10-K Annual report Apple paid $12.2B in Federal taxes, this was most at a 35% rate applied to securities that their foreign-based subsidiaries (e.g. ireland-based) owned in the US since these values are not considered revenue. These were cashflows that occurred in the US and could not be avoided. Apple also paid $1.2B in foreign taxes at a lower rate (which lowers their effective US tax rate) and avoided $6B in US taxes all together by keeping funds in foreign subsidiaries. So if it were not for their subsidiary, they would be on the line for almost 50% more in taxes than what they are actually paying into the system.

  10. Re:Sure, it's good today on EU Committee Votes To Make All Smartphone Vendors Utilize a Standard Charger · · Score: 2

    Eventually? The sooner the better, if you ask me.

    I currently have several devices that are nothing more than paper weights now as they are no longer chargeable due to broken micro USB ports.

    It's not a terrible design for something like an external hard disk or other device that generally just sits there. On a device that is designed to be handled constantly, however, it falls flat on its face. The connection is simply too fragile.

    If the EU really wants to reduce waste, they would mandate a connector that didn't break so easily, thus bricking the device. This is less of a problem nowadays with laptops, but they too have suffered this problem long enough that at this point the only reason you would keep releasing devices with fragile power connectors is that you are engineering obsolescence.

    There are micro-soldering repair shops that can reseat the ports with new connections to the board that will fix that issue. A friend of mine needed it done for his Galaxy S3, I think the total cost was around $45 including shipping and guarantees on the work being done.

  11. Re:Is there really any point to this? on Tech In the Hot Seat For Oct. 1st Obamacare Launch · · Score: 3, Funny

    Here's the facts. I am a resident of British Columbia. I pay about $127 per month in Medical Services Premiums. For that I won't be given a bill at any hospital or any doctor if I have a medical issue. If I need a scan or some other diagnostic test, I will not be billed. Furthermore, if I end up needing healthcare in Prince Edward Island, I will still be protected.

    Shoot, that sounds fantastic! Why can't we get something like that here in the U.S.?

    Because we got FREEDOMS!!!!

    Especially the freedom to bend over and take it...

  12. Re:some are more equal than others on 9th Circuit Court Elevates Celebrity Privacy Rights Over Video Game Portrayals · · Score: 2

    Isn't that Animal Farm

    To be fair, I don't recall Animal Farm specifying in what year it took place. Maybe it also took place in the year 1984, albeit in an alternative dimension where animals talked and Oceana wasn't at war with Eastasia.

    Pretty sure he meant the quote, "Some are more equal than others," was from Animal Farm, not the year that Animal Farm took place.

  13. Re:Outraged! on The Pentagon's Seven Million Lines of Cobol · · Score: 1

    Why the fuck don't they do what any reasonable company does... contract out that stuff to someone who is good at it... like ADP.

    As a taxpayer, I am outraged.

    I really hope that was sarcasm... ADP is one of the most incompetent companies I have ever had the displeasure of working with.

  14. Re:Perhaps your looking at the wrong OS. on Windows Blue 9364 Screenshots Show Feature Enhancements · · Score: 2, Insightful

    The Chromebook Pixel is a laptop that brings together the best in hardware, software, and design to inspire future innovation.

    While using an Intel 4000 integrated graphics chipset... pass.

  15. Re:Just kick him out. on Dad Hires In-Game 'Assassins' To Get His Son To Stop Gaming · · Score: 1

    Given the complete crap my company's Dev team has pushed out over the past 2 years... it's definitely not a requirement here.

  16. Re:Tax avoidance on Facebook Paid 0.3% Taxes On $1.34 Billion Profits · · Score: 2

    Example: Halliburton rebuilding the Middle East

    PEOPLE in charge of Haliburton profit from it

    a healthy population has a DIRECT correlation to higher productivity from your workforce, ergo higher profits

    PEOPLE are using the healthcare services ad PEOPLE realize the profits

    Roads and other public infrastructures allow your employees to come to work and customers to purchase your product/service.

    true, both employees and customers pay for their right to use the infrastructure with their taxes plus property taxes dependent on value dependent on quality of infrastructure are paid on company's real estate

    Police and Fire departments help to protect corporate assets from theft and destruction.

    property taxes cover that

    Legally Corporations are defined as people, only they officially lack the capacity to vote aside from lobbying. However, if you are really going to push the people ticket, then Capital Gains tax needs to be raised to 35% across the board instead of the 15% cap as the investors have the most to gain by corporate operations. The normal workers are actually producing and already paying full income tax on their wages while investors merely front capital with no additional effort.

  17. Re:FB tax avoidance on Facebook Paid 0.3% Taxes On $1.34 Billion Profits · · Score: 2

    Home Country (Country A): Effective Tax Rate of 35%
    Foreign Country (Country B): Effective Tax Rate of 10%

    The company's operations grossed $100,000,000 (Home currency) in income (before taxes) while operating abroad in Country B. Based on the tax rates, the company would pay $10,000,000 to Country B for taxes. From there, that $10,000,000 is normally deducted from Country A's tax rate to avoid double taxing the income, so what would have been $35,000,000 becomes only $25,000,000 taken in by Country A.

    The Tax holidays in the Goldman article are playing off the above. In a tax holiday, Country A would not receive any tax revenue from foreign operations under the hope that the company would then reinvest that $25,000,000 as capital within Country A. While that works once in awhile, there is no way to guarantee where those funds will wind up. In the meantime, Country A has $25,000,000 less in tax revenue (not accounting for any taxation on funds that somehow make it back and incur charges either from Employee Income Tax, Capital Gains Tax for investors, or possible Sales Tax).

  18. Re:These aren't the rich you are looking for... on Facebook Paid 0.3% Taxes On $1.34 Billion Profits · · Score: 1

    These charges are known as "Transfer Pricing."

  19. Re:Tax avoidance on Facebook Paid 0.3% Taxes On $1.34 Billion Profits · · Score: 5, Insightful

    When talking about income taxes, yes, you are member of the society, you benefit from such things, you should pay taxes. Companies, however, don't benefit from army, from healthcare and from any other things that society provides. In fact, when nobody uses the company, the company ceases to exist. Taxing the companies only forces the companies to spend every year the most so they don't have to pay such high taxes. For me, it is not bad if for example Microsoft holds great untaxed amount of cash this year and invests it the next year or the year after. The company is already punished for not spending their money by inflation, the income tax is just bad tool and shouldn't be used.

    Complete bullshit across the board.

    • Companies, however, don't benefit from army

      Example: Halliburton rebuilding the Middle East

    • Companies, however, don't benefit from...healthcare

      I work in the Healthcare analytics world, a healthy population has a DIRECT correlation to higher productivity from your workforce, ergo higher profits. This is why companies track Health and Productivity Management and implement programs designed to change employee lifestyles to be more healthy.

    • Companies, however, don't benefit from...any other things that society provides
      • Roads and other public infrastructures allow your employees to come to work and customers to purchase your product/service.
      • Police and Fire departments help to protect corporate assets from theft and destruction.
      • Patents and Trademarks should be self-explanatory
      • And the list goes on...

    Drop the corporate shill routine that companies don't benefit from the government. They benefit a hell of a lot more than most citizens and at a lower effective tax rate.

  20. Re:See which bastards voted for it on Senate Renews Warrantless Eavesdropping Act · · Score: 1

    Here's the vote of each Senator on this bill. Only 23 voted Nay, only 3 of those Nays were Republicans, and 4 Senators didn't even show up to vote. And President Obama is quite ready to sign it into law.

    This country is broken.

    It only takes one Democrat president to veto it. Funny how you drop party label for that.

    In that case, don't forget that it was Republican Representative Lamar Smith [R-TX21] that introduced the renewal in the House that started the renewal. Honestly, both parties are the problem and the labels mean little at this point.

  21. Re:They could have just asked any geek on Physicists Turn Pull Into Push · · Score: 3, Funny

    I have data points that indicate this to be correct at least some of the time. There may be just a little more to it of course, but I'm sure future physics papers will give us some more hints.

    Pretty sure those are just outliers. Are you sure p from your dataset is remotely close to 0.05?

  22. Re:encryption on The Trouble With Bringing Your Business Laptop To China · · Score: 2

    And USB Switchblade still gets around it with ease depending on the Operating System.

  23. Re:Case dismissed? on Bradley Manning (WikiLeaks Source) Given Hearing After 2 Years In Jail · · Score: 4, Informative

    Military action under the War Powers Resolution (1973) that was authorized by Congress to extend beyond the 60 day max. It's one of their favorite loopholes.

  24. Unfortunately the biggest chunk of that capital is in investment funds made up of people's 401K and IRA retirement funds.

    And most of that is buried in the derivatives market. That's the hole your 401K is being thrown into, a true gamble, if there ever was one, and it won't take 30 years for it to disappear.

    I believe the GP meant it took 30 years of hard work and sacrifice to save up to that quarter of a million dollars, not that it would take 30 years to spend it.

  25. Re:Another moron CEO on Salesforce.com's Benioff Disses Windows 8, Oracle · · Score: 3, Informative

    On the contrary, the fortune 500 company I work at just migrated their entire intranet infrastructure over to a SharePoint 2010 cluster. When you have a need to be able to quickly deploy/manage department-level sites, you cannot beat SharePoint. While I personally hate the software, it is the equivalent to a Windows Domain for ease of management and configuration at an enterprise-level.