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Facebook tax court trial begins over Ireland offshore deal

reuters.com

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Re: Facebook tax court trial begins over Ireland offshore deal

#231

Post by A4ET8a8uTh0 »

complianceowl wrote: post #157
riazrizvi wrote: post #119

Surely this is more about political coercion than tax? Amongst all US companies that offshore profits, including the likes of Halliburton, Facebook has been singled out because the US administration wants the company to do it's bidding regarding policy and algorithms for political advertising? Especially considering all the other political reprisals and pardons that are in the news, following the impeachment acquitta…

A lot of unfounded speculation in your comment. It seems more politically-motivated than rooted in facts. Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more. Thirdly, as much as I might dislike an administration, I won't take the giant, speculative leap as to assume that I know exactly what they're thi…

It may be speculation, but I honestly can't categorically state it is unfounded. I have no love for FB, and, as parent memtioned, they are hardly the only beneficiary of this particular loophole.

Then, if you recall FB recent stance on e2e, Barr's and Lindsay's comments, the question of political influence over IRS becomes much less an unlikely proposition.

It does not make it automatically true, but let us not pretend that IRS moves in mysterious ways.

To claim otherwise is to ignore context in which IRS goes after them. It may be completely unrelated, but it does raise questions.

Re: Facebook tax court trial begins over Ireland offshore deal

#232

Post by pgt »

riazrizvi wrote: post #119

Surely this is more about political coercion than tax? Amongst all US companies that offshore profits, including the likes of Halliburton, Facebook has been singled out because the US administration wants the company to do it's bidding regarding policy and algorithms for political advertising? Especially considering all the other political reprisals and pardons that are in the news, following the impeachment acquitta…

$9B looks pretty economically-focused to me.

Re: Facebook tax court trial begins over Ireland offshore deal

#233

Post by [deleted] »

sixhobbits wrote: post #137

People looking at their personal income tax return: Woah, this is more complicated than I expected - should probably pay a professional accountant to sort this out for me People reading news articles like this: Look at these stupid professionals arguing about how international tax law in the $XB range when one side is so obviously wrong, and the correct outcome is really straight forward.

[deleted]

Re: Facebook tax court trial begins over Ireland offshore deal

#234

Post by MrStonedOne »

vertig0h wrote: post #206
MrStonedOne wrote: post #176

Earlier quoted context omitted.

>unfounded speculation It's not unfounded in the days of pardons to political donors, political donations to jury members, and firing of whistleblowers and witnesses. You are allowed to assume bad faith when the entity has time and time again showed bad faith. This is suppose to be one of the detriments to acting in bad faith time and time again.

These things you're mentioning are minor issues which have been blown out of proper proportion and context by a hostile media spoon-feeding political propaganda to a willing segment of the public. That said, none of the things you mentioned are related to investigating tax evasion. "Oh, you sneezed on Sally when you were in first grade without apologizing? You must be guilty of armed robbery."

Corruption is never a minor issue unless you live under the rule of winnie the pooh.

Re: Facebook tax court trial begins over Ireland offshore deal

#235

Post by ska »

ksec wrote: post #226
ska wrote: post #196

Earlier quoted context omitted.

You latter point doesn't really make sense to me. Isn't it true that a sale of IP should model the value of the IP over its lifetime in some reasonable way? And that would include a growth model for FB, no? If it could be shown that facebook intentionally undervalued it in order to make this scheme work better for them, wouldn't the IRS have a case?

>Isn't it true that a sale of IP should model the value of the IP over its lifetime in some reasonable way? There aren't any "correct" way to measure it, but most of these IP are likely on percentage based. Sort of like 5G patents where they collect percentage of revenue. So the value I guess they did in 2010 were calculated based on ( projected ) 2012 ( its IPO ) figure. I think judging by majority of comment most p…

Agreed, of course there isn't a "right" way. But companies should be internally consistent in how they do these things.

So, I can imagine if you (as the IRS) can demonstrate that they used on method of doing this sort of thing for some stakeholders, but another for the sale to Irish subsidiary with no real justification ... you might just have an argument this was for tax avoidance purposes.

Also I didn't mean to suggest that absolute value comparison was the right way to do this. Just that it is entirely plausible the FB intentionally lowballed the sale. It's clearly the reason these companies are in Ireland at all. Cases like this I suppose are about defining the line between "fair play" and not.

Re: Facebook tax court trial begins over Ireland offshore deal

#236

Post by JoshTriplett »

three_seagrass wrote: post #219
AnthonyMouse wrote: post #194

Earlier quoted context omitted.

Then you'd be judging a lot of people wrongly, because that sort of thing happens all the time for entirely legitimate reasons. For example, at various points there have been federal tax credits for installing solar panels on your house or buying certain types of green cars. For a lot of people the credit would exceed their federal tax liability for the year. You're prepared to send them all to jail for that without…

I think by implying that the IRS went after them, the "weird trick" was not as legal as previously anticipated, despite being guidance from a professional. Appealing to popularity wouldn't make it anymore legal than appealing to professionalism.

> I think by implying that the IRS went after them, the "weird trick" was not as legal as previously anticipated, despite being guidance from a professional.

That's about as legitimate as "the police investigated them, so they must have done something wrong". That kind of argument has huge problems.

Re: Facebook tax court trial begins over Ireland offshore deal

#237

Post by monadic2 »

CodeSheikh wrote: post #208
complianceowl wrote: post #157

Earlier quoted context omitted.

A lot of unfounded speculation in your comment. It seems more politically-motivated than rooted in facts. Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more. Thirdly, as much as I might dislike an administration, I won't take the giant, speculative leap as to assume that I know exactly what they're thi…

I hate to say this but a lot of unfounded speculation in your comment as well. "Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more." Can you back this up with some factual information? Would love to know more about other companies. Thanks.

Bud we entered a post fact world, especially when it comes to politics, decades ago.

Re: Facebook tax court trial begins over Ireland offshore deal

#238

Post by jedberg »

AndrewUnmuted wrote: post #212
MrStonedOne wrote: post #176

Earlier quoted context omitted.

>unfounded speculation It's not unfounded in the days of pardons to political donors, political donations to jury members, and firing of whistleblowers and witnesses. You are allowed to assume bad faith when the entity has time and time again showed bad faith. This is suppose to be one of the detriments to acting in bad faith time and time again.

> the days of pardons to political donors, political donations to jury members, and firing of whistleblowers and witnesses How long have we been in these "days," would you say?

Since the Senate voted, so about a week?

Re: Facebook tax court trial begins over Ireland offshore deal

#239

Post by mythrwy »

wpietri wrote: post #193
dcolkitt wrote: post #142

Earlier quoted context omitted.

The chance of an ordinary middle class person being audited by the IRS is extremely low. The enforcement division is severely understaffed, and pretty much only works on computers pattern matching clearly egregious returns. A large proportion of the US population commits some sort of low level tax evasion- unreported income, deductions that never happened, personal expenses as business deductions, claiming dependents…

I would love to see a citation for this: "A large proportion of the US population commits some sort of low level tax evasion".

I read somewhere it's actually the opposite.

That there is a net overpayment of taxes due to people not claiming deductions, not collecting refunds due etc. etc.

(not sure how true this is, simply something I read).

Re: Facebook tax court trial begins over Ireland offshore deal

#240

Post by Karunamon »

[deleted] wrote: post #218
sixhobbits wrote: post #137

People looking at their personal income tax return: Woah, this is more complicated than I expected - should probably pay a professional accountant to sort this out for me People reading news articles like this: Look at these stupid professionals arguing about how international tax law in the $XB range when one side is so obviously wrong, and the correct outcome is really straight forward.

[deleted]

The problem with that evaluation is that credibility can only rightly be evaluated by author, not by publication, and unless we're talking about scientific journals (and sometimes not even then), editors can't be expected to be subject matter experts in everything a paper ever writes about.

Example: Bloomberg is still a legitimate business paper of record despite running that unfounded story about backdoored motherboards. I'd take anything those authors put out with a shaker-full of salt in the future, but Bloomberg is still legitimate.

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