Earlier quoted context omitted.
Which company would be big enough to fit that description and able to pay enough to make a dent in this big an amount?
IBM?
Can't wait until GitHub will be e̶n̶h̶a̶n̶c̶e̶d̶ bricked by Watson.
Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
221–230 of 334 posts
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#222The infraction happened in 2004-2013. So that would be over three billion dollars per year. Microsoft’s operating income in fiscal year 2005 was about $15B and in 2013 almost $27B. So you can kind see where the IRS is getting this number: if they believe that Microsoft evaded tax worth about 10-15% of its earnings before taxes, that’s how it would add up to this whopping sum. It seems like Microsoft believes they can…
>It seems like Microsoft believes they can settle for something much lower.
This is almost CERTAINLY true. MSFT will be able to tie this up in court, and has tremendous motivation to do so.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#223There should never be a gap this big unless fraud or evasion is involved. If the rules are that vague it needs to change.
I can understand why an honest mistake, an accounting misinterpretation, or incorrect decision leads to a gap this big - taxes can be complex.
Even honest mistakes can be construed as negligence.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#224The infraction happened in 2004-2013. So that would be over three billion dollars per year. Microsoft’s operating income in fiscal year 2005 was about $15B and in 2013 almost $27B. So you can kind see where the IRS is getting this number: if they believe that Microsoft evaded tax worth about 10-15% of its earnings before taxes, that’s how it would add up to this whopping sum. It seems like Microsoft believes they can…
> It seems like Microsoft believes they can settle for something much lower. The stock price doesn’t seem to be hurting pre-market at all Given the Stock Markets inability to predict the Twitter buyout despite public documents stating Elon Musk's contract to buy at $54.20/share throughout 2022, I'm pretty sure that stock market investors are literally illiterate, unable to read public documents. Anyone who bought Twi…
There are a million reasons that those trades were not free money. e.g. it's quite expensive to short stocks like AMC. Not knowing that makes me think you weren't actually in that trade.
Start putting your money in the market and you won't be talking about easy money for "anyone who can read" for very long.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#225Earlier quoted context omitted.
Glad it changed. It's still a 50% discount compared to most of EU though…
Sounds like something EU should change if EU don't like it.
I don't think this can be solved easily. Unless until https://www.europarl.europa.eu/news/en/press-room/20220603IP... (3rd point) lands and the original idea is not messed up during the rounds of debate.
Until then, not going to happen IMHO. Ireland, Luxembourg, and the Netherlands benefit outrageously from this and since they can veto stuff it's really hard to plug these holes. I think Ireland gave up some ground in this regard since its position was starting to really annoy other EU members.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#226The infraction happened in 2004-2013. So that would be over three billion dollars per year. Microsoft’s operating income in fiscal year 2005 was about $15B and in 2013 almost $27B. So you can kind see where the IRS is getting this number: if they believe that Microsoft evaded tax worth about 10-15% of its earnings before taxes, that’s how it would add up to this whopping sum. It seems like Microsoft believes they can…
> The stock price doesn’t seem to be hurting pre-market at all. Big investors will have eyes and ears inside the IRS, so will have known for years about this already.
[dead]
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#227Is this an issue unique to Microsoft, or did other similar companies receive the same type of notice?
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#228Earlier quoted context omitted.
> MNPI with you directly. Abbreviating that is so misleading, it's incredibly hard to not see it as bad faith! MNPI means "material non-public information". You're saying "non-public information is fine but material non-public information is not", without making it as obvious. Yes, it has to be material. "Owes $30b in taxes" is ABSOLUTELY material. If on top of that you learn about it from IRS insider contacts, enjoy…
The entire point is that MNPI is a legal concept and information can be both nonpublic (i.e. private correspondence) and tradable for profit (i.e. material) and yet does not constitute MNPI. You're making the exact mistake that I've repeatedly tried to correct. There is no bad faith on my part.
Your personal opinion on what "material" means might differ from the court's (and also differs from mine, at least how you phrased it), but I can assure you, a $30bil tax bill is DEFINITELY material.
It's a "legal concept" in the same way that every word used in a lawbook is a legal concept; the US is based on case law, and there is a large amount of precedent for this definition in particular. Again, refer to the Wikipedia for some examples.
I see this mistake a lot among programmers (also myself at some point). They (we) naturally think law is like a rulebook where you go through a decision tree and then arrive at a perfect conclusion, but the truth is that it's up to the courts to decide on the specifics. And they might disagree on those things with you, and with each other, but in the egregious cases disagreements are rare.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#229Earlier quoted context omitted.
LOL, like they would ever do that! They will make MS customers pay for it, if they can't convince the IRS to lower the bill significantly, which they probably can.
"if they can't convince the IRS to lower the bill significantly" Why would IRS agree to this? Would the IRS agree to lower your taxes if you pretty-pleased them? Microsoft should not be an exception.
The IRS settles for lower amounts ALL the time, it wouldn't be even remotely exceptional if MS gets a discount. They have an entire department to handle these offers in compromise: https://www.irs.gov/payments/offer-in-compromise
Even with 30B cash in the bank, MS will do everything it can to lower that bill. First they will fight it, and take all the little wins they can get. Then whenever it's pretty clear what parts they can't win, they will then start negotiating with the IRS to try and pay 50 cents on the dollar or something.
Part of the tactic is delaying, the longer they can put off actually writing the check, the better, as money today is worth more than money tomorrow(inflation and time value of money).
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#230Earlier quoted context omitted.
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On the contrary. I was not arrogant enough. The biggest winners were those who short sold Tesla, knowing that Elon would be forced to sell Tesla stock to afford a $44 Billion purchase (even if $13 Billion was covered in loans and maybe $9 Billion in handshake agreements with other investors like Saudis or Larry Ellison etc. Etc.) If you short sold Tesla and bought TWTR in preparation for the buyout event, you'd have…
Not so easy money anymore after omnipresent AIs come into play.