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hvalika

HN member
Joined
Tue, Oct 13, 2015, 4:45 PM UTC
HN karma
9
Public activity
7 items

About hvalika

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Recent public activity

  1. comment
    Comment #11765983

    You can't make it "dead simple" when some of the concepts are not "dead simple." Let me give you the example of debt vs equity. Just because the company/lender codes it as such, do…

  2. comment
    Comment #11765957

    I don't entirely disagree with your post but I generally avoid calling these loopholes. It is all about finding the mismatch between two countries -- For example, if a little kid a…

  3. comment
    Comment #11765899

    Thanks Kell - I must ask - did Google ever approach the French Revenue Authorities and try to get a ruling ahead of time? I assume they are arguing that Google does not have a perm…

  4. comment
    Comment #11765873

    ^^^ exactly that. The rule is generally that your "principal purpose" can't be to avoid taxes (in this case). There is also the "economic substance doctrine" which actually codifie…

  5. comment
    Comment #10670224

    Thank you! People are blowing this whole LLC thing out of control. It really isn't a big deal deal at all. He probably went against the word of his tax advisors to use an LLC as op…

  6. comment
    Comment #10670178

    Just a slight clarification -- there is no "avoidance" going on here. This is merely "deferral." Transferring the shares of any company to another company is often a tax free trans…

  7. comment
    Comment #10657128

    But really, what is this saying about the companies that are allowed to remain? Does the Pakistani government have the ability to monitor every message/email sent via phones throug…