Live data from Hacker News

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

microsoft.gcs-web.com

51–60 of 334 posts

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

#51

This spells bad news for "MICROSOFT B.V.", the famous Dutch software company that has reported being responsible for billions of revenue of the Microsoft Corporation over those years.

Apple and others are working to explain how the majority of app and hardware sales have a nexus in Ireland.

But wait til you hear of Ugland House (https://en.wikipedia.org/wiki/Ugland_House) in the Caymans - 10,000 sq ft, 5 stories...

... and registered offices of 42,000 companies.

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

#52
post #48

“Many large multinationals use cost-sharing because it reflects the global nature of their business.” A comparable example might be Apple, where sales of my (american) app being sold from (american) servers somehow curiously involves the Republic of Ireland and their low corporate tax rates…

It's simple enough, an Irish company called Apple licenses its very valuable IP to its entities in cheaper countries so they can do things like manufacturing, server farms, customer support. (It also carries on these some of these functions in Ireland, as it happens, and pays a ton of tax at the relatively high income tax rates there.) It's frankly curious to me when a multinational chooses to base itself anywhere le…

At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.

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

#53

Wonder why the stock hasn't taken a huge hit after the news. $28.9bln sounds like a lot. Maybe investors think MS will find a way to reduce the amount or pull of an extremely long term repayment plan? >As of September 30, 2023, we believe our allowances for income tax contingencies are adequate. We disagree with the proposed adjustments and will vigorously contest the NOPAs through the IRS’s administrative appeals of…

The back taxes add up to about 1.2% of Microsoft's current market cap, and it looks like the stock is down roughly 0.6% in after-hours trading. So I guess the market collectively estimates MS will end up owing about half of that amount.

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

#55

Wonder why the stock hasn't taken a huge hit after the news. $28.9bln sounds like a lot. Maybe investors think MS will find a way to reduce the amount or pull of an extremely long term repayment plan? >As of September 30, 2023, we believe our allowances for income tax contingencies are adequate. We disagree with the proposed adjustments and will vigorously contest the NOPAs through the IRS’s administrative appeals of…

Partly (or maybe totally) because the 28.9 billion number is essentially the opening number in a negotiation (and there is even a chance the the figure is completely wrong and nothing additional is owed) and there is basically 0% chance MS ends up paying $28.9 billion.

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

#56
post #48

Earlier quoted context omitted.

It's simple enough, an Irish company called Apple licenses its very valuable IP to its entities in cheaper countries so they can do things like manufacturing, server farms, customer support. (It also carries on these some of these functions in Ireland, as it happens, and pays a ton of tax at the relatively high income tax rates there.) It's frankly curious to me when a multinational chooses to base itself anywhere le…

At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.

It's no less fiction than any other contract or legal document.

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

#57

Wonder why the stock hasn't taken a huge hit after the news. $28.9bln sounds like a lot. Maybe investors think MS will find a way to reduce the amount or pull of an extremely long term repayment plan? >As of September 30, 2023, we believe our allowances for income tax contingencies are adequate. We disagree with the proposed adjustments and will vigorously contest the NOPAs through the IRS’s administrative appeals of…

Its not a final determination. If they do actually paying up that much money is when I expect investor sentiment to change.

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

#58
post #48

Earlier quoted context omitted.

It's simple enough, an Irish company called Apple licenses its very valuable IP to its entities in cheaper countries so they can do things like manufacturing, server farms, customer support. (It also carries on these some of these functions in Ireland, as it happens, and pays a ton of tax at the relatively high income tax rates there.) It's frankly curious to me when a multinational chooses to base itself anywhere le…

At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.

Of course they are, it’s a contractual agreement that is within the law. The fact that you don’t like it could not be less relevant, you don’t matter. If the government doesn’t like the law, they can (try) to change it but that has to go through the actual process. They are welcome to be as mad as they want that their law is poorly written but it is still their law.

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

#59

Wonder why the stock hasn't taken a huge hit after the news. $28.9bln sounds like a lot. Maybe investors think MS will find a way to reduce the amount or pull of an extremely long term repayment plan? >As of September 30, 2023, we believe our allowances for income tax contingencies are adequate. We disagree with the proposed adjustments and will vigorously contest the NOPAs through the IRS’s administrative appeals of…

> Wonder why the stock hasn't taken a huge hit after the news. $28.9bln sounds like a lot. Maybe investors think MS will find a way to reduce the amount or pull of an extremely long term repayment plan?

It’s very simple, the market doesn’t expect that MSFT will have to pay $28.9B in back taxes.

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

#60
post #12

I know we're not supposed to editorialize the titles, but this one really buries the lede.

Suggested alternatives:

"Microsoft on the Issues Blog – An update on our IRS tax audit"

Or:

Microsoft SEC 8-K: "IRS is seeking an additional tax payment of $28.9 billion"

(I've emailed mods to suggest these.)

Post reply on HN