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Except for the fact that historically this sort of maneuver is used to defer repatriating money earned abroad until such time as the conditions are favorable to do so. For example, http://articles.baltimoresun.com/2011-11-02/news/bs-ed-tax-r...

This article discusses how in 2004 there was a tax holiday for corporations to 'repatriate' profits stashed over seas. Presently corporations are lobbying Congress for another such one time tax holiday. Under these special one time deals the money being brought in is generally taxed at a ridiculously low rate. In 2004 it was 5% meaning Google's effective tax rate once the money arrives back in Mountain View is 7.5% still very very low.



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