I think a lot of commentators are missing the point of the original article. The fact that kids might see somewhat inappropriate videos is just a symptom of the underlying problem.
The problem is that the information we see and content we view is increasingly the result of the interactions of various algorithms. You see this in the way Google inadvertently promotes conspiracy theories. The content itself starts to become more and more automated as every video or article just ends up being a reconfiguration of popular keywords. I suppose the dystopic end-game if this were in an episode of Black Mirror would have everyone completely disassociated from reality as all information they consume is simply generated and and pushed out to them by various bots interacting.
I would argue my company never intends to defeat the intent of the law, though I understand that there are companies with more aggressive tax groups that will if they think they can. It's also worth noting that the tax code actually has various provisions intended to defeat tax planning that defeats the intent of the law even if the planning satisfies the letter.
To clarify my Africa example: the offshore company is paying taxes in Africa- exactly the same as it would if it were incorporated there.
Hate to say it, but there's not all that much much a regular W-2 employee can do- certainly nothing using offshore companies that would be beneficial. This is especially the case if you are not itemizing deductions. The thing is, most middle class people don't pay that much federal income tax at the end of the day, so there's just not that much in the way of savings to be had (payroll taxes are another story).
Make sure you are maxing out all of your tax advantaged savings space- Roth IRA, 401k, Health Savings Account, and 529 (if you have children and paying for college). If you are over the income limit for a Roth IRA, you can look into the backdoor Roth, and if you work for a company with a really god 401k plan - the mega backdoor Roth. In some cases, you can get almost $100k annually into investment accounts either tax-free, or with tax-free gains on the investments.
In order to do fancier tax planning you need to be in business of some sort. Real estate investing can be very tax favored. However, it makes little sense to change careers solely for tax purposes. Only do it if you really want to run the business- not because you want to save on taxes.
You seem to imply we are using offshore companies to defeat the intent of the law. But that's not the case. The law doesn't really intend to double-tax companies on their foreign earnings, but the various rules in place can cause that to happen if the company does not plan carefully.
I am a tax attorney. What you have described will not work. You evidently need to educate yourself a wee bit more and put in a little more effort. Under the scheme you describe, the license fees received by the Cayman company would be Subpart F income, fully taxable in the U.S. to the individual who owns the controlled foreign corporation. You'd also need to worry about IRC Section 367(d) on transferring your intellectual property offshore. Also, although loan receipts are generally not taxable income, there are rules under which a cross-border loan may be re-classed as a dividend or subject to withholding on the interest payments.
International tax is not an area where it is wise to dabble. Advising people do engage in transactions like this without understanding the rules is irresponsible at best.
I am a tax corporate attorney. My job is to ensure that a Fortune 500 company does not pay more tax than legally owed. When operating internationally, half the game is just making sure you don't get hosed and end up getting double-taxed by two different jurisdictions or not being allowed to use a big loss you have suffered to offset a gain elsewhere- so when I say more than "legally owed" I do not mean more than technically owed after some complected scheme is executed.
These stories tend to confuse tax evasion, tax avoidance, and money laundering. While an offshore company may be used for any of those things, the mere use of an offshore company doesn't necessarily mean a company or person is engaging in any of them.
In my business, we use offshore companies as neutral third locations. For example, if we need to operate in a dodgy part of Africa, we likely don't want to form a subsidiary in that country because such countries often lack robust corporate law and because it can be very administratively burdensome to form a new company there. The Caymans offers robust corporate law, a functioning court system, quick setup, and quick dissolution. There are both tax and non-tax reasons not to use a U.S. company for that purpose. If we were to sell that subsidiary, a foreign buyer may not want to purchase a U.S. company with all of the administrative and legal burden that comes with owning one. Tax-wise, using a non-U.S. entity prevents that company from being taxed in both the U.S. and the operating country. It would still be subject to U.S. tax if it sends money to the U.S. parent, but it's usually possible to manage tax attributes and cash so that's not necessary.
A tax avoidance motive might be something like an earnings-stripping transaction where intellectual property is licensed to a low-tax country. However, the tax code hardly allows carte-blanche for doing transactions like this, and the time has long passed when you could just set up a Cayman company with no employees that holds all of your intellectual property. Large companies are audited every single year or are under a continuous audit program the IRS runs- nobody in the world of big business "gets away" with something- everything must be legally justified. As a result, the most aggressive tax avoidance transactions tend to be seen from medium sized privately held businesses and high net worth individuals- not large public companies.
For individuals without extensive business operations, offshore companies rarely offer any legal tax benefit. As an individual, you are still subject to worldwide taxation. Rules such as the personal foreign holding company rules in the tax code are specifically designed to prevent offshore companies from being used for personal tax avoidance.
You will find individuals who use offshore company for straight-up tax evasion. This is one of the things Paul Manefort was indicted for. Legally, you must declare offshore accounts- and he allegedly did not. Laws such as FATCA and foreign equivalents are making this strategy tougher to pull off because they require tax withholding on transfer to an offshore location if the individual refuses to provide information necessary to report the transaction to the tax authorities.
Finally, you will find offshore accounts used for money laundering. That is a very different type of operation from multinationals using them for a legal benefit. It's worth noting that not all offshore locations are created equal in this regard. Jurisdictions like the Caymans and Bermuda have extensive anti-money laundering laws that they do their best to enforce. As a result, most Cayman and Bermuda companies are subsidiaries of legitimate business. By contrast, a fortune 500 company would almost never use Panama for a subsidiary unless it was actually doing business in-country.
TLDR: Articles like this talk about offshore companies as if they are always illegitimate and treat tax avoidance, tax evasion, and money laundering as the same thing. There are both legitimate and illegitimate uses of offshore companies, and each of these things are separate phenomena.
Speaking as a lawyer, I'm afraid you have far too much confidence in the judicial system. People have been convicted based on a lot less than a seemingly perfect photograph and few criminal defendants have the financial wherewithal to hire an expert to contest the veracity of a spoofed photo.
You will subsidize dangerous, immoral, irresponsible, and self-destructive behavior regardless of what happens to Obamacare. It is either subsidized explicitly through a program like Obamacare or implicitly through higher medical bills as long as we continue to provide care regardless of ability to pay.
Prior to Obamacare, you couldn't necessarily buy the insurance that reflected your actual risk either. You were often grossly overcharged if you purchased on the individual market- even if you were quite healthy and low risk. Lifetime maximums meant that even a catastrophic plan didn't necessarily fully cover a catastrophic event like cancer.
An apologist is anybody who defends a concept, so sure- call me an apologist. The Supreme Court found that the Obamacare mandate was, in fact, a tax. It's far cheaper than actually buying insurance if you really want to go down that route. And really, if you have to resort to name calling when making your argument, you've already shown your hand to be weak.
Yes, in theory people pay their medical bills. But what happens when things don't work out. A friend of mine had a brain aneurysm- her medical bills were in excess of $2 million. Do you have that sort of money sitting around ready to pay your bill? I'm not making any claims about anybody specifically, but the fact of the matter is that hospitals routinely have to write off bills of the uninsured. Those costs get passed onto the rest of us, either implicitly or explicitly.
No it doesn't. It just requires you to pay a relatively modest tax if you choose not to. Why? Because when you get hit by a bus and rushed to the hospital, we are still going to end up paying for it.
Perhaps you don't get much of a vote in the management of a public company as a small shareholder, but you are protected from things like insider trading and the company is required to report its financials and major corporate events to a government regulatory body. If you are investing through large mutual funds, those funds may have a pretty big vote in company management.
Moreover, if a company is being seriously mismanaged, there's a decent chance that someone (either an activist investor or private equity fund) will come along and buy enough shares to seriously challenge or replace the management. With current coin offerings, you could own every single coin and the company still wouldn't be required to give you the time of day.
There's nothing wrong with blockchain technology being used in public share offerings. In fact, ICOs could eventually become a replacement for current equity funding methods.
But as practiced today, they are totally scammy. Unlike stock offerings, coin offerings are almost completely unregulated- owning a coin doesn't confer any rights or protections to the owner akin to share offerings. They have a lot of appeal to the entity making the offering, but I don't see what they offer to the investor. They are like a penny stock offering, but without the protections of SEC oversight and a bunch of tech smoke and mirrors to attempt to make up for that.
Speaking as the spouse of an employment lawyer, public companies are hit by discrimination lawsuits all the time. The primary reason is that discrimination is the only cause of action most employees have if they feel they've been unjustly terminated. Even if they are really upset because they thought their boss unfairly evaluated their work, they may allege discrimination because they can't sue over anything else.
In other words, I wouldn't make too much of this. People are only paying attention because it's Tesla.
None of the above is to say that discrimination or harassment can't be a serious problem, and that the suits are never meritorious- just that the mere fact of the suit occurring doesn't mean much.
No reason why you can't stream sports too. Stream becomes available when the event starts, and available anytime after. They already offer streaming news stations-.
Back in the early days of radio, movies, and television, all of the talent was focused on producing a relatively small volume of content. Everything had to appeal to general audiences because the movie theaters only showed one movie at a time and there were only a small handful of radio/TV stations.
Today, content has evolved to fill hundreds of different niches. There are entire TV stations devoted to specific hobbies like fishing and podcasts about the most esoteric interests one can possibly think of. That content doesn't need to appeal to everyone- just its target audience. With all that content siphoning away most users, what's left in the "general appeal" category that gets broadcast on legacy networks prime time is watered down and uninspired- everyone with inspiration is off entertaining for their specific niche.
The situation is both better and worse in some ways. You have much better access to the content you like, but in return talent working on general appeal content is diluted.
You still need to pay for internet to exist in the modern world. I wouldn't include it in streaming costs unless you are upgrading to a higher speed tier than you would have otherwise.
Why would one subscribe to all of those services? Netflix and Prime are plenty for me with the occasional movie download from google play. I don't even view prime as part of my streaming service costs as I mostly use it for the shipping.
The same reason anybody would buy an item that satisfies more than the minimum specification. No, the iPhoneX (or Galaxy 8) is not going to run any of your core apps substantially better than a basic $200 android unit, but a substantial portion of the population will find that the overall user experience is better- bigger and better screen, wireless charging, bigger internal storage, easier to unlock, better camera, etc. You might also ask why anybody buys a $30,000 car when you can buy a new stripped down Mitsubishi Mirage that will get you to work for $10,000.
I'd also point out that the real cost of owning a smartphone is the service. I pay $80 a month for my unlimited data plan- that's almost $2,000 over the two-year period I tend to stick with one phone- more than double cost of the fanciest hardware.
There's a big difference between autonomous cars that are acceptable with a driver sitting there ready to take over in good conditions and autonomous cars we can allow to roam the city with nobody inside in the middle of a snowstorm. The former is already here (to a degree) for many driving situations. The latter may be decades off.
Slashdot Mirror
I think a lot of commentators are missing the point of the original article. The fact that kids might see somewhat inappropriate videos is just a symptom of the underlying problem.
The problem is that the information we see and content we view is increasingly the result of the interactions of various algorithms. You see this in the way Google inadvertently promotes conspiracy theories. The content itself starts to become more and more automated as every video or article just ends up being a reconfiguration of popular keywords. I suppose the dystopic end-game if this were in an episode of Black Mirror would have everyone completely disassociated from reality as all information they consume is simply generated and and pushed out to them by various bots interacting.
I would argue my company never intends to defeat the intent of the law, though I understand that there are companies with more aggressive tax groups that will if they think they can. It's also worth noting that the tax code actually has various provisions intended to defeat tax planning that defeats the intent of the law even if the planning satisfies the letter.
To clarify my Africa example: the offshore company is paying taxes in Africa- exactly the same as it would if it were incorporated there.
Hate to say it, but there's not all that much much a regular W-2 employee can do- certainly nothing using offshore companies that would be beneficial. This is especially the case if you are not itemizing deductions. The thing is, most middle class people don't pay that much federal income tax at the end of the day, so there's just not that much in the way of savings to be had (payroll taxes are another story).
Make sure you are maxing out all of your tax advantaged savings space- Roth IRA, 401k, Health Savings Account, and 529 (if you have children and paying for college). If you are over the income limit for a Roth IRA, you can look into the backdoor Roth, and if you work for a company with a really god 401k plan - the mega backdoor Roth. In some cases, you can get almost $100k annually into investment accounts either tax-free, or with tax-free gains on the investments.
In order to do fancier tax planning you need to be in business of some sort. Real estate investing can be very tax favored. However, it makes little sense to change careers solely for tax purposes. Only do it if you really want to run the business- not because you want to save on taxes.
You seem to imply we are using offshore companies to defeat the intent of the law. But that's not the case. The law doesn't really intend to double-tax companies on their foreign earnings, but the various rules in place can cause that to happen if the company does not plan carefully.
I am a tax attorney. What you have described will not work. You evidently need to educate yourself a wee bit more and put in a little more effort. Under the scheme you describe, the license fees received by the Cayman company would be Subpart F income, fully taxable in the U.S. to the individual who owns the controlled foreign corporation. You'd also need to worry about IRC Section 367(d) on transferring your intellectual property offshore. Also, although loan receipts are generally not taxable income, there are rules under which a cross-border loan may be re-classed as a dividend or subject to withholding on the interest payments.
International tax is not an area where it is wise to dabble. Advising people do engage in transactions like this without understanding the rules is irresponsible at best.
I am a tax corporate attorney. My job is to ensure that a Fortune 500 company does not pay more tax than legally owed. When operating internationally, half the game is just making sure you don't get hosed and end up getting double-taxed by two different jurisdictions or not being allowed to use a big loss you have suffered to offset a gain elsewhere- so when I say more than "legally owed" I do not mean more than technically owed after some complected scheme is executed.
These stories tend to confuse tax evasion, tax avoidance, and money laundering. While an offshore company may be used for any of those things, the mere use of an offshore company doesn't necessarily mean a company or person is engaging in any of them.
In my business, we use offshore companies as neutral third locations. For example, if we need to operate in a dodgy part of Africa, we likely don't want to form a subsidiary in that country because such countries often lack robust corporate law and because it can be very administratively burdensome to form a new company there. The Caymans offers robust corporate law, a functioning court system, quick setup, and quick dissolution. There are both tax and non-tax reasons not to use a U.S. company for that purpose. If we were to sell that subsidiary, a foreign buyer may not want to purchase a U.S. company with all of the administrative and legal burden that comes with owning one. Tax-wise, using a non-U.S. entity prevents that company from being taxed in both the U.S. and the operating country. It would still be subject to U.S. tax if it sends money to the U.S. parent, but it's usually possible to manage tax attributes and cash so that's not necessary.
A tax avoidance motive might be something like an earnings-stripping transaction where intellectual property is licensed to a low-tax country. However, the tax code hardly allows carte-blanche for doing transactions like this, and the time has long passed when you could just set up a Cayman company with no employees that holds all of your intellectual property. Large companies are audited every single year or are under a continuous audit program the IRS runs- nobody in the world of big business "gets away" with something- everything must be legally justified. As a result, the most aggressive tax avoidance transactions tend to be seen from medium sized privately held businesses and high net worth individuals- not large public companies.
For individuals without extensive business operations, offshore companies rarely offer any legal tax benefit. As an individual, you are still subject to worldwide taxation. Rules such as the personal foreign holding company rules in the tax code are specifically designed to prevent offshore companies from being used for personal tax avoidance.
You will find individuals who use offshore company for straight-up tax evasion. This is one of the things Paul Manefort was indicted for. Legally, you must declare offshore accounts- and he allegedly did not. Laws such as FATCA and foreign equivalents are making this strategy tougher to pull off because they require tax withholding on transfer to an offshore location if the individual refuses to provide information necessary to report the transaction to the tax authorities.
Finally, you will find offshore accounts used for money laundering. That is a very different type of operation from multinationals using them for a legal benefit. It's worth noting that not all offshore locations are created equal in this regard. Jurisdictions like the Caymans and Bermuda have extensive anti-money laundering laws that they do their best to enforce. As a result, most Cayman and Bermuda companies are subsidiaries of legitimate business. By contrast, a fortune 500 company would almost never use Panama for a subsidiary unless it was actually doing business in-country.
TLDR: Articles like this talk about offshore companies as if they are always illegitimate and treat tax avoidance, tax evasion, and money laundering as the same thing. There are both legitimate and illegitimate uses of offshore companies, and each of these things are separate phenomena.
Speaking as a lawyer, I'm afraid you have far too much confidence in the judicial system. People have been convicted based on a lot less than a seemingly perfect photograph and few criminal defendants have the financial wherewithal to hire an expert to contest the veracity of a spoofed photo.
You will subsidize dangerous, immoral, irresponsible, and self-destructive behavior regardless of what happens to Obamacare. It is either subsidized explicitly through a program like Obamacare or implicitly through higher medical bills as long as we continue to provide care regardless of ability to pay.
Prior to Obamacare, you couldn't necessarily buy the insurance that reflected your actual risk either. You were often grossly overcharged if you purchased on the individual market- even if you were quite healthy and low risk. Lifetime maximums meant that even a catastrophic plan didn't necessarily fully cover a catastrophic event like cancer.
An apologist is anybody who defends a concept, so sure- call me an apologist. The Supreme Court found that the Obamacare mandate was, in fact, a tax. It's far cheaper than actually buying insurance if you really want to go down that route. And really, if you have to resort to name calling when making your argument, you've already shown your hand to be weak.
Yes, in theory people pay their medical bills. But what happens when things don't work out. A friend of mine had a brain aneurysm- her medical bills were in excess of $2 million. Do you have that sort of money sitting around ready to pay your bill? I'm not making any claims about anybody specifically, but the fact of the matter is that hospitals routinely have to write off bills of the uninsured. Those costs get passed onto the rest of us, either implicitly or explicitly.
No it doesn't. It just requires you to pay a relatively modest tax if you choose not to. Why? Because when you get hit by a bus and rushed to the hospital, we are still going to end up paying for it.
Perhaps you don't get much of a vote in the management of a public company as a small shareholder, but you are protected from things like insider trading and the company is required to report its financials and major corporate events to a government regulatory body. If you are investing through large mutual funds, those funds may have a pretty big vote in company management.
Moreover, if a company is being seriously mismanaged, there's a decent chance that someone (either an activist investor or private equity fund) will come along and buy enough shares to seriously challenge or replace the management. With current coin offerings, you could own every single coin and the company still wouldn't be required to give you the time of day.
Exactly.
There's nothing wrong with blockchain technology being used in public share offerings. In fact, ICOs could eventually become a replacement for current equity funding methods.
But as practiced today, they are totally scammy. Unlike stock offerings, coin offerings are almost completely unregulated- owning a coin doesn't confer any rights or protections to the owner akin to share offerings. They have a lot of appeal to the entity making the offering, but I don't see what they offer to the investor. They are like a penny stock offering, but without the protections of SEC oversight and a bunch of tech smoke and mirrors to attempt to make up for that.
I suppose Trump's response was "if you can't beat 'em, join em."
Speaking as the spouse of an employment lawyer, public companies are hit by discrimination lawsuits all the time. The primary reason is that discrimination is the only cause of action most employees have if they feel they've been unjustly terminated. Even if they are really upset because they thought their boss unfairly evaluated their work, they may allege discrimination because they can't sue over anything else.
In other words, I wouldn't make too much of this. People are only paying attention because it's Tesla.
None of the above is to say that discrimination or harassment can't be a serious problem, and that the suits are never meritorious- just that the mere fact of the suit occurring doesn't mean much.
Why not? They just didn't provide enough server bandwidth for that stream. In the future, they will.
No reason why you can't stream sports too. Stream becomes available when the event starts, and available anytime after. They already offer streaming news stations-.
We might want to avoid sending any space marines.
Back in the early days of radio, movies, and television, all of the talent was focused on producing a relatively small volume of content. Everything had to appeal to general audiences because the movie theaters only showed one movie at a time and there were only a small handful of radio/TV stations.
Today, content has evolved to fill hundreds of different niches. There are entire TV stations devoted to specific hobbies like fishing and podcasts about the most esoteric interests one can possibly think of. That content doesn't need to appeal to everyone- just its target audience. With all that content siphoning away most users, what's left in the "general appeal" category that gets broadcast on legacy networks prime time is watered down and uninspired- everyone with inspiration is off entertaining for their specific niche.
The situation is both better and worse in some ways. You have much better access to the content you like, but in return talent working on general appeal content is diluted.
You still need to pay for internet to exist in the modern world. I wouldn't include it in streaming costs unless you are upgrading to a higher speed tier than you would have otherwise.
Why would one subscribe to all of those services? Netflix and Prime are plenty for me with the occasional movie download from google play. I don't even view prime as part of my streaming service costs as I mostly use it for the shipping.
Yeah, people have been arguing about that stuff since Descartes.
The same reason anybody would buy an item that satisfies more than the minimum specification. No, the iPhoneX (or Galaxy 8) is not going to run any of your core apps substantially better than a basic $200 android unit, but a substantial portion of the population will find that the overall user experience is better- bigger and better screen, wireless charging, bigger internal storage, easier to unlock, better camera, etc. You might also ask why anybody buys a $30,000 car when you can buy a new stripped down Mitsubishi Mirage that will get you to work for $10,000.
I'd also point out that the real cost of owning a smartphone is the service. I pay $80 a month for my unlimited data plan- that's almost $2,000 over the two-year period I tend to stick with one phone- more than double cost of the fanciest hardware.
There's a big difference between autonomous cars that are acceptable with a driver sitting there ready to take over in good conditions and autonomous cars we can allow to roam the city with nobody inside in the middle of a snowstorm. The former is already here (to a degree) for many driving situations. The latter may be decades off.
But Skymall went bankrupt in 2015.
Just things like a steel structure that will keep you from getting killed in an accident. They are also physically much larger than your old Corolla.