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Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

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281–290 of 334 posts

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#281

Earlier quoted context omitted.

Is this basically the Double Irish With a Dutch Sandwich?

A Dutch Sandwich sounds like two dry pieces of bread with a thin slice of cheese. I'd discourage MS from getting one.

Dutch cheeses are not many, but they are tasty even in dry bread. Best paired with a generous cup of évasion fiscale.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#282
post #149

The 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.

> Big investors will have eyes and ears inside the IRS, so will have known for years about this already.

Sorry, just so I'm clear, you are claiming that major hedge funds have "moles" in the IRS that illegally funnel them the private tax information of major public companies?

What possible source do you have for this?

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#284
> Microsoft had shifted at least $39 billion in U.S. profits to Puerto Rico, where the company’s tax consultants, KPMG, had persuaded the territory’s government to give Microsoft a tax rate of nearly 0%. Microsoft had justified this transfer with a ludicrous-sounding deal: It had sold its most valuable possession — its intellectual property — to an 85-person factory it owned in a small Puerto Rican city.

(2020) https://www.propublica.org/article/the-irs-decided-to-get-to...

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#285
post #245

Transfer pricing is sort of just a pile of black magic. Microsoft's American business is required to charge their European subsidiary some "fair market price" for the Windows intellectual property, but what is a fair price for a license to sell Windows on the European continent? Unlike with fungible goods, there is no established market for this product that the IRS can easily refer to. In this case Microsoft is sayi…

Part of me is like: 25% tariff, blanket, on everything unless there's an exemption. The list of exemptions can then be carefully curated. I don't care if it's 500 pages long for everything from honey to computer chips; but then at least we know that stupid tax stuff is unprofitable.

part of me is like: why does that particular governmental entity deserve additional payment just because its regulatory environment is uncompetitive in that regard and can't balance its own budget.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#286
post #149

The 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…

Do you have a link to the public documents? A short web search gave me nothing.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#287

Ironically, some IRS accountant must have some msft-back-taxes_v3_new_newer_final.xlsx file on their computer.

If it was that simple then Microsoft should have known it was coming and maybe even changed the numbers in the document.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#288

Earlier quoted context omitted.

Big investors have a pass for doing shady stuff. They can do insider trading (up to a point where it's not considered insider trading), they can break the SEC rules to artificially reduce the share price of a company so they can buy it or drive them to bankruptcy, but a normal person like me and you can't do these things, because we don't have the money to get around with it. Big market actors are just institutionali…

You are correct, this is America where we do A LOT of things that are bad for us because they are profitable. I'm writing a long form article about this idea, how in America we do stuff like private prisons, allow pollution, the "family" court system and social media for kids even though some countries can easily fix these problems we refuse to address them because just TOO much money is being made (at least that's h…

I’d definitely love to read it when it comes out.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#289

Earlier quoted context omitted.

> 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.

> Big investors will have eyes and ears inside the IRS, so will have known for years about this already. Sorry, just so I'm clear, you are claiming that major hedge funds have "moles" in the IRS that illegally funnel them the private tax information of major public companies? What possible source do you have for this?

At this point people assume everything is a scam, everything is "compromised", and everyone except the "little guy" is in on it. It's really silly. You might as well also claim that the IRS has moles inside of Microsoft and is compromised which is why they're going to get this $27 billion in owed payments and investors had no idea!

Better yet, the IRS and Microsoft are working together on a secret AI tax scheme and this is a cover-up for transferring large amounts of funds to the IRS or to Microsoft for the program to work.

Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B

#290
post #275

Earlier quoted context omitted.

There was close to a zero interest rate during all that time, or does IRS use something way above normal for their rate?

Back taxes have a baseline rate that grows at certain increments of lateness but is ultimately capped. I don't think it's in any way tied to the base or prime rate.

Based on what happens in my country, it could be both penalty + some interest rates based on the reference rate (which definitely haven't been zero for the past two years btw) but not equal to it.
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