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We detached this subthread from https://news.ycombinator.com/item?id=37850384.
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.)
Earlier quoted context omitted.
That tax break "Double Irish Dutch Sandwich" is being phased out. It involves both those countries with one of the Irish companies managed out of Bermuda. It has shifted to other schemes now. https://en.m.wikipedia.org/wiki/Double_Irish_arrangement
What other schemes?
Going back almost 20 years has got to be painful. I doubt half of the people involved are even still at the company.
> Not reflected in the proposed adjustments are taxes paid by Microsoft under the Tax Cuts and Jobs Act (TCJA), which could decrease the final tax owed under the audit by up to $10 billion.
I 100% believe that it was a good faith mistake, and it still is.
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.
All they have to do is find the agreement
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.
“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…