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The time bomb in the tax code that's fueling mass tech layoffs

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Re: The time bomb in the tax code that's fueling mass tech layoffs

#311

Earlier quoted context omitted.

This is a highlight in an otherwise shitty bill. I saw let Trump’s ugly bill die and then a small fix up to the tax code could be this. Should be able to pass.

This bill is goated for upper middle class and tech and defense sector And I’m tired of pretending like we aren’t going to be beneficiaries Every Congress increases the debt, we can acknowledge that the cuts they picked are going to wreck the lower class especially with the medicaid, we can acknowledge that it won’t meet its goals of cuts but are you guys just scared to acknowledge its going to super charge things th…

You don't want to live in a society where an increasingly large percentage of the population have nothing to lose.

Regardless of whether it benefits our industry or socioeconomic status, it'd be incredibly shortsighted to just do all of that at the expense of the lower classes.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#312

Earlier quoted context omitted.

If everyone agreed on it, Congress would have no problem doing it (Congress itself, after all, is a subset of "everyone".)

That's still not true. As long as a group within "everyone" (or multiple groups) decide that their support is required to pass the bill, they can suddenly demand concessions and the bill now gets complicated with good and bad.

> As long as a group within "everyone" (or multiple groups) decide that their support is required to pass the bill, they can suddenly demand concessions

Well, yes, but then everyone doesn't really want it, do they? Someone wants something else, and wants that something else enough that it is worth jeopardizing the supposedly universal goal for it.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#313

So, we want incredibly profitable companies like Google, Microsoft, and Apple to take their software development costs and subtract that from their tax bill? These are the same companies that file patents so nobody else can use the ideas that they developed at the expense of public services. How about making it a tax break only for small and medium sized companies?

Fix the patent problem. Leave the r&d right off alone.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#314
post #185

As a non-American, it seems strange to me that the cost of regular software development, i.e. that is neither “research” nor “experimental” in a conventional sense, would be deductible in the first place (amortized or not). Isn’t that subsidizing a whole business sector? Maybe I’m misunderstanding something.

We're not talking about a tax deduction in the sense of a special privilege, we're talking about simple calculations of profit. Before this change, tax for software development was calculated against: * Profit = Revenue - Expenses And software developer salaries fell neatly into Expenses unless you were looking for an R&D tax credit. After this change, tax for software development is calculated against this new equat…

Wasn't there something when this went into effect about the mid-year being the start so it is 10% in years 1 and 6?

Re: The time bomb in the tax code that's fueling mass tech layoffs

#315
post #304
post #181

Earlier quoted context omitted.

Risky startups with multiple years of R&D before revenue would be the least impacted. You’re only paying taxes if the business is profitable ignoring investments like R&D spending.

You seem extremely confused. Section 174 specifically made those R&D costs “ignorable” from a tax standpoint. When it ended R&D costs could no longer be used to offset income.

What specifically do you disagree with? That R&D is an investment? I mean outside of the tax code that’s what it means to do R&D.

As to my other point, the highest risk category of startup has zero customers for years they also have zero revenue, zero profit, and zero taxes to pay here. On the 5th year they can deduct R&D from each of those years making the net effect on them minimal vs a startup with profits on year 0.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#316

Earlier quoted context omitted.

We're not talking about a tax deduction in the sense of a special privilege, we're talking about simple calculations of profit. Before this change, tax for software development was calculated against: * Profit = Revenue - Expenses And software developer salaries fell neatly into Expenses unless you were looking for an R&D tax credit. After this change, tax for software development is calculated against this new equat…

Wasn't there something when this went into effect about the mid-year being the start so it is 10% in years 1 and 6?

Yeah, I just read that. So it's actually 10-20-20-20-20-10, which is both weirder and also slightly worse than my formula above.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#317

Earlier quoted context omitted.

> But you haven't gained... Yes, you have. You have an asset of greater value which you can leverage in a number of ways without liquidating it and "realizing" the gains. That's a real gain, with real value. > you could be taxed over and over again Only if you make new unrealized gains. > and if the stick drops or hits zero then what? Then you have a negative unrealized gain, or, equivalently, an unrealized loss. If…

The unrealized value is notional, not actual. This is a very important distinction. The notional value is often not remotely realizable. In many cases, the realizable value can be a tiny fraction of the notional value. Most laypeople grossly conflate notional and real value. Taxing notional value massively inflates the adverse impact of tax incidence on expected returns relative to people’s casual intuition based on…

For many assets, like real estate, there are liquid markets with market prices. There are a number of US states that already tax based on real estate value, you can dispute the assessed value but that impacts other things like insured value.

Being difficult to assess value is a problem they’ll make you pay an accountant for and punish you if you get it wrong, it’s not going to stop them.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#318

Earlier quoted context omitted.

Repealing SB174 has bipartisan support. The house already passed its repeal but it died in Senate because a separate took (that also repealed it) took its place but that separate bill stalled out. 174 is so small it can't go through both chambers on its own so it needs to get attached a larger bill like OBBA. It's unfortunate because it appears both sides want this repealed to allow immediate amortization of domestic…

> 174 is so small it can't go through both chambers on its own so it needs to get attached a larger bill like OBBA. There's a minimum size for laws?

I think there is a limit on the number of bills that can make it through the procedures so it’s too low profile to get scheduled.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#319

Earlier quoted context omitted.

> But you haven't gained... Yes, you have. You have an asset of greater value which you can leverage in a number of ways without liquidating it and "realizing" the gains. That's a real gain, with real value. > you could be taxed over and over again Only if you make new unrealized gains. > and if the stick drops or hits zero then what? Then you have a negative unrealized gain, or, equivalently, an unrealized loss. If…

The unrealized value is notional, not actual. This is a very important distinction. The notional value is often not remotely realizable. In many cases, the realizable value can be a tiny fraction of the notional value. Most laypeople grossly conflate notional and real value. Taxing notional value massively inflates the adverse impact of tax incidence on expected returns relative to people’s casual intuition based on…

> The unrealized value is notional, not actual.

No, its an actual thing, measurable by some mechanism. Otherwise, this would be a non-discussion, as taxing it would be impossible, not a possible thing that we can argue about the merits of.

> The notional value is often not remotely realizable.

Whether it is or is not immediately realizable is immaterial to the desirability of taxing it; it may be material to designing the forms of taxation that should be acceptable. E.g., if the difficulty of realizing the value is, across the tax base, likely to making collecting the tax in cash or equivalents difficult, it would argue for permitting a fallback option for the tax to be collected in-kind, e.g., by the taxing jurisdiction acquiring a proportional interest in the asset equal to the share of the value of the asset represented by the taxes not paid by other means.

> A tax on unrealized gains is in effect a way of laundering a steep tax rate so that it looks “small” and therefore reasonable to the unsophisticated.

If you allow carry forwarded losses, even just by the simple method of adjusting basis values, and include taxes on realized gains (and carry forward, offsetting against current income with perhaps a negative net, etc., for realized losses), then taxing unrealized gains is identical to taxing realized gains if the gains are eventually realized, but simply avoids the ability to find maneuvers to benefit from leveraging the value of the asset without paying taxes by avoiding realization. It doesn't make a "steep" tax rate look small, it makes the tax rate look like exactly what it actually is, unlike taxing only realized gains, which makes an effectively non-existent tax on capital gains look like something more, when people can benefit from assets without realizing the gains.

Re: The time bomb in the tax code that's fueling mass tech layoffs

#320

Amortization is bad policy when it comes software. Software is inherently high risk. Every piece of software is unique and does not guarantee steady income over 5 years. Most startups won't survive 5 years to fully realize the deductions. This is the end of US software dominance.

Is US software dominance because of our startups? Or because of the giant trillion dollar monopolies we have? Didn't AAPL, GOOG and FB all create products _before_ they had any taxable income? Would this change have had any actual impact on their foundings?

I’m not familiar enough with the very early days of Apple which started out as a hardware company to rebut you; but perhaps you mean the current Apple that has re-invented itself?
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