patrick.net

bob2356 says

The other question that comes to mind is whether offshore profits represent double dealings for executives. Do they include the profits that go offshore as part of the basis for salaries and bonuses. In which case they are essentially stealing from the stockholders, since this pool of profits is being used to calculate how much to pay them but is not available for dividends to be distributed.

Lol.. YES! its all designed to screw the US taxpayer and keep all this hidden from the US Government/IRS... and if you really believe in this.. I got a bridge in San Francisco i like to sell you...

Ruki says

Cap gains taxation directly correlates to investment rates. Investment rates correlate with total production and productivity. Increased production and increased productivity generates more wealth and economic activity. Those in turn generate more tax revenues

LOL! unless its a price bubble.. than it all goes to pot!

thomas,
If the US company has to pay taxes when the income is brought in, what is the benefit of the double irish or dutch sandwich arrangements?
http://en.wikipedia.org/wiki/Double_Irish_arrangement

YesYNot says

what is the benefit of the double irish or dutch sandwich arrangements?

OK, what do you think transfer pricing is ? your not moving profits generated from US customers to non-US (foreign) entities. This is all within non-US entities overseas. Anyway, you dont double tax the same profit.

thomas.wong1986 says

bdrasin says

Also worth considering: in most other countries the corporations don't have to pick up the tab for health insurance the way they do here.

Actually, Asian and European companies do pick up the tab for Health and Social (retirement plans, social securities) from their employees salaries and from the foreign companies like we have here. Foreign companies doing business also pick up the tab having workers in the host Asian and Euro country. As do foreign companies doing business in the US. Nothing is free!

Really? There is a line item on your paycheck for health insurance company XYZ? I guess it must depend on the country. When I worked in the UK my health care was from the national healthcare service, which is paid for out of tax revenue. What it means is that the employer can pay me a somewhat lower salary because health care is already covered.

Ruki says

Tax revenues almost doubled under Reagan. Did you know that? But according to your world view, you require some mental gymnastics to believe it.

Yes, and interest rates dropped more than 50% under Reagan. See graph (long term rates, short term rates dropped even more)

A monkey President would look good in that environment. I hope you aren't going to make the retarded claim that Reagan brought interest rates down. When he raised taxes it might have helped maintain the trend, but it was CArter's appointee Volker who killed inflation with high interest rates, and when they fell like a rock, anything Reagan did was going to look great.

You're a troll.

I wasn't arguing that when tax rates are too high that lowering them can't be good. But rates are low now. And receipts even lower because of the way that people and corporations avoid paying taxes.

You're a troll.

Or if you aren't, maybe you can explain why competing with countries where corporate rates are lower is affected by our higher rates, when we actually PAY LESS than they do.

ruki says

Want to get more revenue (that means more in tax receipts for the ignorant)? Then cut the rate at least to levels competitive with world average levels

WTF ? Again. If we pay less than they do in taxes, it's actually rates that are irrelevant.

Stay tuned to see how Ruki dodges the question. We could start a pool. Will it be an ad hominem attack perhaps ? Maybe one of many logical fallacies ? I'll admit, I am curious. My bet is he just runs, or maybe changes his name again.

The question: Can you explain why competing with countries where corporate rates are lower is affected by our higher rates, when we actually PAY LESS than they do ?

By the way....

Ruki says

Tax revenues almost doubled under Reagan

Good thing, since the deficit tripled. I guess it could be argued that if revenues doubled while the deficit tripled, Reagan was really teaching us how to live beyond our means, and it's true what people say about the mother of all credit binges (and fake economies) being initiated by Reagan.

Also, one can't help but wonder whether the massive expansion of government and deficits under Reagan helped our economy ?

thomas.wong1986 says

OK, what do you think transfer pricing is ? your not moving profits generated from US customers to non-US (foreign) entities. This is all within non-US entities overseas. Anyway, you dont double tax the same profit.

I don't know what transfer pricing is, and was asking a genuine question. My understanding is that related entities (controlled by the same organization) can sell each other goods at non-market rates and move profits around. In the articles they mentioned that a company like Apple could place their IP in a subsidiary company in Ireland, and then the patent revenue would flow through Ireland.

In fact, my understanding was that the best argument for lowering corporate taxes is that corporations can so easily shift profits from one place to another. A human can do this to some degree by living in Florida for 6 months out of a year to avoid state taxes if they have a lot of investment income. A corporation doesn't have to make such sacrifices to avoid taxes.

Maybe a company that shifts profits to a tax haven country just gets to hold it there and defer taxes? If you understand exactly how these things work, then maybe you can help explain it. This graphic in the NYT shows money staying in a tax haven country. I don't know if the money can be passed directly from the tax haven country to investors as a dividend or if it has to be brought back into the US, logged as corporate profit, and then passed on as a dividend.

http://www.nytimes.com/interactive/2012/04/28/business/Double-Irish-With-A-Dutch-Sandwich.html

From the next article...
In a regulatory filing just a week before the Japanese disaster put a spotlight on the company’s nuclear reactor business, G.E. reported that its tax burden was 7.4 percent of its American profits, about a third of the average reported by other American multinationals. Even those figures are overstated, because they include taxes that will be paid only if the company brings its overseas profits back to the United States. With those profits still offshore, G.E. is effectively getting money back.

http://www.nytimes.com/2011/03/25/business/economy/25tax.html?pagewanted=all

Ruki says

bob2356 says

Your proof of this is?

Prove to me the sky is blue.

Not my prob if you don't know the basics of Econ 101, dude.

Cap gains taxation directly correlates to investment rates. Investment rates correlate with total production and productivity. Increased production and increased productivity generates more wealth and economic activity. Those in turn generate more tax revenues.

Obey The Tripods

Oh yes the classic you prove the sky is blue because I don't have a clue other than Rush told me so response.

Ok you are so well versed on econ 101, how about some actual real world examples and numbers to back this all up? I'm sure the next step in this little farce is the classic I'm not your google whore response.

marcus says

Stay tuned to see how Ruki dodges the question. We could start a pool

I like it, the Ruki dodgem pool. I'm in .

thomas.wong1986 says

There really isnt a washing of US profits to offshore accounts.. somehow billions sitting in the caymans. They consolidate the non-US global operations in Ireland, pay Irish taxes as needed. ( see Exhibit 21.1 ).

its a sad myth! simple put! what is earned overseas, already taxed overseas, must yet be taxable again ... it will be paid when dividend to the parent is declared (IRS tax law). Otherwise this is a deferred liability. The cash held in asian and european banks are there to pay their staff, bills, taxes, build new operations/expansion, and acquire new companies.

So you are saying the NYT got it wrong, that apple is actually paying taxes on their intellectual property in ireland before shipping the money to the netherlands and then off to the carribean? Can you document that? I would be curious how as big a publication as the times got something so totally wrong and no one picked it up.

So when exactly will all these billions in yet untaxed profits sitting offshore actually be returned to the shareholders as dividends? Why is so much money being held offshore for long periods of time? Which was part 2 of my question. Are ceo's and senior management paying themselves based on the profits generated offshore but never distributed as dividends? Do they bring these profits back in to load balance loss years, never giving dividends but making their numbers and bonuses with it?

SFace says

You probably misundestand how this works. A multi-national corporation files on a consolidated basis. A consolidated return will exclude the foreign subs thus during the period of loss, your companies includable will be the same. The corporation will not be able to use losses on the federal consolidated return with offset from foreign E&P. In fact, I believe if the company have 20 foreign subs and file 20 form 5471's, they cannot be netted against another.

They can't net against each other in the same year. What about a company like apple that has 75 billion in untaxed (in the US) profits (who knows how much sitting in bvi, it's not broken out by apple) from many different years. Can't apple (or any corporation with substantial offshore profits) bring some back in a year they lose money in the US and net it out then? In which case the senior executives would have been paid for performance in generating the profits at time they were first created, then avoided be penalized for the losing year by moving the untaxed profits back? Plus there is 75 billion out there the stockholders are not getting. Last time I checked the stockholders were the actual owners of that money.

bob2356 says

Can't apple (or any corporation with substantial offshore profits) bring some back in a year they lose money in the US and net it out then?

simple put no! you cant 'move' revenues and related expenses (what you call profits) from one tax year to another. For that purposes your prior tax years are closed and if you suffer a loss (NOL net operating loss) in say year 3, you can apply a loss credit 2 years before the loss and forward for 20 years. Therefore you get a refund for years 1 and 2.
This applies to both Corp and Individuals tax payers.

bob2356 says

They can't net against each other in the same year. What about a company like apple that has 75 billion in untaxed (in the US) profits (who knows how much sitting in bvi, it's not broken out by apple) from many different years.

No.. what you see from the SEC filings is different from what the US auditors and what the IRS see. Not to mention all the foreign tax agencies who want to collect their taxes.

A typical consolidated internal PL will include... Same for balance sheet.

Top horizontal line (my country or legal entity)
US, Japan, Mexico, China, Canada, Ireland, UK, Norway, etc etc etc.

Vertical Account line...
Revenues by product lines
Cost of goods detail by product lines
Salaries
Bonus
Commission
Rental
Small tools
and
100s of other expense lines

Other income/taxes... detail by type
FX gain losses

US federal Tax
US State tax
Foreign Tax
etc etc

Net Income..by each country - entity.

Pretty much everthing is finally audited by their Price Waterhouse (3rd party US auditors and their own affiliated).

bob2356 says

So you are saying the NYT got it wrong, that apple is actually paying taxes on their intellectual property in ireland before shipping the money to the netherlands and then off to the carribean? Can you document that? I would be curious how as big a publication as the times got something so totally wrong and no one picked it up.

Define Intellectual property from the Balance Sheet you see in the SEC filings.. what exactly is this IP assets the media talks about ?

is it Cash, investments, AR, inventory, fixed assets.. long term assets ?
Like Apple many have few dollars sitting in their cash accounts (pay salary,vendor bills).. Apple has what 3-4B out of $80-90B in cash US accounts.. the rest are in US Govt Bonds.. there isnt Billions sitting in some cayman islands transfered from the US as you think...
How does it come to be..

NYT, arent accounting or tax experts.. they have a political agenda.
Surely they should get someone from the Big 4 Accounting/Tax firm to explain all this ... but that would kill their articles off !

SFace says

In short, it will allow the company to lower their effective tax rate, increase their earnings and earnings per share.

Thanks SFace.
I want to make sure I have this right. Taking your profits in a low tax country and moving the profits to a place like the Caymans is done, and it is used to defer taxes. The company earnings (used for price to earnings ratio) is calculated based on after tax earnings, so includes all of the money that goes into the Caymans account.
Is that correct?
thomas.wong1986 says

simple put no! you cant 'move' revenues and related expenses (what you call profits) from one tax year to another. For that purposes your prior tax years are closed and if you suffer a loss (NOL net operating loss) in say year 3, you can apply a loss credit 2 years before the loss and forward for 20 years. Therefore you get a refund for years 1 and 2.
This applies to both Corp and Individuals tax payers.

I think what bob meant was that by shifting profits to foreign subsidiaries, and then storing money in a foreign company, you are deferring taxes until you bring the money home. The questions is not whether profits from one year can balance losses from another year. The question is, can you offset the 'profits' generated when you bring money back to the US with losses in the US in one year. These seem different to me.

^Thanks again SFace. I'm not sure how the ETR ends up being 23.4 in the above. But I get the tax holiday bit. Interestingly, it seems like the money sitting overseas can be used to purchase things like treasuries through the US banking system. Do you know if it can be used to do buybacks of company stock or to buy stock in general?

http://blogs.wsj.com/washwire/2011/12/14/corporate-tax-holiday-takes-another-hit-in-congress/

thomas.wong1986 says

is it Cash, investments, AR, inventory, fixed assets.. long term assets ?
Like Apple many have few dollars sitting in their cash accounts (pay salary,vendor bills).. Apple has what 3-4B out of $80-90B in cash US accounts.. the rest are in US Govt Bonds.. there isnt Billions sitting in some cayman islands transfered from the US as you think...
How does it come to be..

NYT, arent accounting or tax experts.. they have a political agenda.
Surely they should get someone from the Big 4 Accounting/Tax firm to explain all this ... but that would kill their articles off !

No one said or thought there are billions transferred from the US to the caymans, where did you get that? The story clearly gives the trail of the money, did you actually read it?

So you are saying the NYT story is completely wrong and no one of the hundreds of millions of people that read it has challenged it. At least I've never seen anything challenging it. That's very interesting.

SFace says

On the other hand, it puts US multinationals at a huge disadvantage becuase let's say Suntech (China) and First Solar (US) competes in Mexico. Suntech pays the Mexico income tax rates that is it and they can take the cash back and invest in Brazil. First Solar pays the Mexico rate. If they take the cash back to the parent, they have to bring the rate to 35% whereas Suntech doesn't. They can use the cash to expand in Mexico but cannot move it around and deploy capital like China.

Which brings up the point that if the tax rate is so bad that it represents a "huge disadvantage" to US multinationals then why are so many huge multinational companies willing to be based in the US? Of the 10 biggest corporations that "moved" out of the US in the last decade 5 were in legal trouble and 2 moved because most of their business shifted to other parts of the globe. I say "moved" because a lot of the "moves" were paper moves with the bulk of the corporate headquarters operations staying in the US. Pretty amazing that so many huge corporations stay headquartered in a country with such repressive tax rates and overwhelming business regulation. Maybe, just maybe, the grass isn't always greener.

Secondly they most certainly can move the cash around and deploy the capital. They can do it any where in the world except bringing it to the US.

Highest corporate tax rates in the world:

1- Japan
2- USA

http://www.forbes.com/pictures/eglg45hhik/usa/#gallerycontent

Do the math.

bob2356 says

I say "moved" because a lot of the "moves" were paper moves with the bulk of the corporate headquarters operations staying in the US. Pretty amazing that so many huge corporations stay headquartered in a country with such repressive tax rates and overwhelming business regulation. Maybe, just maybe, the grass isn't always greener.

You can simply look at Delaware.. why are so many US Companies like the ones in California, New York or other states incorporated in Delaware.. what is Delaware doing to attract the majority these companies business.

http://en.wikipedia.org/wiki/Delaware_General_Corporation_Law

YesYNot says

I think what bob meant was that by shifting profits to foreign subsidiaries, and then storing money in a foreign company, you are deferring taxes until you bring the money home.

No! thats not it...

If US Company "A" sells to a US Customer "B" then it is booked in the US Books and will be taxed accordingly. its Cash collected will remain in the US books and US Bank Accounts.

You will not find that the revenue/expenses and its associated profits are moved anywhere! They remain on US Books..

There is no way to "move" or allocate your US BASED "PreTax Profits" around. This is a Accounting/IT boondoggle... IT CANNOT BE DONE!

To attempt to do it would be considered Accounting Fraud and your auditors would nail you for it. The profits that are earned in the US, remain in the US Book's Retained Earnings Account of the US Entity. The Cash that is earned in the US, often stays in the US, either as Cash in Bank or are used to often Buy US Treasury or other securities. All of this is reconciled and reported on the IRS M-1 and M-2 schedule.

If your moving money to fund your subs operations, this is a intercompany transfer (cost plus structure).. A Receivable to the Parent and a Liability to the Sub. Very often you will find the cash is burned to pay foreign employee salaries, bills, taxes, vendors. and nothing is left at the end of the month until funding is required again.

For bigger companies..

Many are confusing what is going outside of the US. Ireland is the Consolidation and Taxing Entity of your NON-US business.. Foreign Customer Sales, Foreign Expenses, and Foreign taxes paid.
Again .. non US Business.. foreign customers and foreign expenses.

All these companies are doing is Consolidating their Financial Statements from UK pounds, Euro (France, Span, Germany, Italy), Yen Japan, China, Australian, etc etc. into a single International Entity in Ireland.

Are they transferring Euros, Yen, UK Pounds to Irish currency... maybe ! but what does that do regarding taxes.. nothing!

Each one of these countries taxing authority will audit the books of the subs as part of the taxing process. And the US SEC/ IRS also audits the books of the multinationals Consolidated (US and Non-US entities) on a 5 year rotational process.

Your unlikely to find some shady stuff going on here.

bob2356 says

So when exactly will all these billions in yet untaxed profits sitting offshore actually be returned to the shareholders as dividends?

The dividend isnt a "Cash shareholder dividend".. it is transfered to the US back via Intercompany .. "Due from Sub" offset by "Due to Parent" and eliminated in Consolidations. At that point the deferred tax asset/liabilty is reduced and "declared on the IRS return". Your payment is the difference between the US rates and Foreign Tax paid. (see foreign tax credit). So your paying only the difference between the two rates.

Many companies, who do business overseas and have cash offshore, have already been taxed by foreign governments. In addition if they file a US IRS consolidated tax return, they pay for the US taxes get a IRS foreign tax credit for the foreign taxes already paid and not some 35%.

OK! now you moved the "Cash" to the US and Paid US Taxes..

So how do you pay your Foreign sub Salary, Bills, Rent, other expenses, and expansion project. What exactly is left in the Bank ?

bob2356 says

So you are saying the NYT story is completely wrong and no one of the hundreds of millions of people that read it has challenged it. At least I've never seen anything challenging it. That's very interesting.

Why is it they never quote some CPA working for a Big 4 accounting firm tax department who knows all this stuff. Fact is they dont even quote the IRS. Ever wonder about that... its all politics!

If all this crap was true... dont you think the IRS (even under Obama) would be like a pack of dogs all over this as if it was Enron! Dont they Audit the big multinationals on a rotational basis. But NO! you never hear that from some journalist.

thomas.wong1986 says

OK! now you moved the "Cash" to the US and Paid US Taxes..

So how do you pay your Foreign sub Salary, Bills, Rent, other expenses, and expansion project. What exactly is left in the Bank ?

No one seems to have any trouble paying the bills overseas when the US government declares a tax repatriation holiday and all the cash comes rushing back into the US. In the 2004 tax holiday over 300 billion came back. Over 90% went to executive bonuses, stock buybacks (which boost stock prices, boosting executive bonuses), and last, but certainly least dividends (oh joy for the stockholders). The remaining crumbs went into reinvestment in the companies.

thomas.wong1986 says

bob2356 says

So you are saying the NYT story is completely wrong and no one of the hundreds of millions of people that read it has challenged it. At least I've never seen anything challenging it. That's very interesting.

Why is it they never quote some CPA working for a Big 4 accounting firm tax department who knows all this stuff. Fact is they dont even quote the IRS. Ever wonder about that... its all politics!

If all this crap was true... dont you think the IRS (even under Obama) would be like a pack of dogs all over this as if it was Enron! Dont they Audit the big multinationals on a rotational basis. But NO! you never hear that from some journalist.

So where are all the rebuttals for the story? I can't find any other than the usual fox incoherent babbling. Forbes, the wsj, and the economist have run articles about the nyt article and haven't disputed it. I read wsj and forbes articles about google using double irish in 2009 I believe. So everyone is wrong about this? What about the former apple executives in the story? They don't know what they are talking about?

No one quotes the IRS. The IRS doesn't make statements.

bob2356 says

In the 2004 tax holiday over 300 billion came back. Over 90% went to executive bonuses, stock buybacks (which boost stock prices, boosting executive bonuses), and last, but certainly least dividends (oh joy for the stockholders). The remaining crumbs went into reinvestment in the companies.

What does executive bonus have to do with intercompany dividend payments ? Since it eliminates on a consolidated books it has no impact on net income. Very often, exec pays is tied to revenue growth targets, timely product introductions and net income on a consolidated basis.

Dividends received deduction

http://en.wikipedia.org/wiki/Dividends_received_deduction

Impact

This deduction is designed to reduce the consequences of triple taxation. Otherwise, corporate profits would be taxed to the corporation that earned them, then to the corporate shareholder, and then to the individual shareholder. While Congress allowed for double taxation on corporations, it did not intend a triple - and potentially infinitely-tiered - tax to apply to corporate profits at every level of their distribution.
The dividends-received deduction complements the consolidated return regulations, which allow affiliated corporations to file a single consolidated return for U.S. federal income tax purposes.
[edit]Application

Generally, if a corporation receives dividends from another corporation, it is entitled to a deduction of 70 percent of the dividend it receives.

If the corporation receiving the dividend owns 20 percent or more, however, then the amount of the deduction increases to 80 percent.[3] If, on the other hand, the corporation receiving the dividend owns more than 80 percent of the distributing corporation, it is allowed to deduct 100 percent of the dividend it receives.

Note that in order for the deduction to apply, the corporation paying the dividend must also be liable for tax (i.e., it must be subject to the double taxation that the deduction is intended to prevent)

SFace says

As a controller, that is a stupid statement. Do you tell your boss no it cannot be done all the time. Accounting is based on entity concepts and related entity transactions are based on arms-length theories.

If you have revenues related to your US customers ( in any of the 50 states) and expenses to your US employees and vendors ( in any 50 states), how exactly are you carving the (pre tax profit or taxable income) items out and transferring to some other Entities oversees at some other foreign currency unrelated to the sale?

This is a boondoggle!

SFace says

Let's say the US entity has 2B in Gross Receipts and 10% operating margin or 200M in income. If they can allocate more favorably and achieve, 8% operating margin, taxable income is now 160M, or a difference of 40M. @ 35% that is 14M in tax. Good luck to the IRS to fight over and win om something that is well documented and supported from the transfer pricing study.

each entity serves its own market.. there are boundaries to which apple in US sells to US customers only.. Apple france sells to french customers only .. etc etc etc. Your not shifting any profits around to meet your targeted net income.

Transfer pricing at one time was used when we actually had production and plants on US soil and shipped goods overseas and billed the foreign entities for the goods... but that is history.. we dont do that anymore. Now it comes from Foxx Comm (Third Party arms-length agreement)..

Today, each global Apple sub gets the goods and a bill ....X units and the total bill to be paid to FoxxComm for the shipment as finished goods. And many others mfg. do the same.

SFace says

A big multinational company has billions in resources, it is fair to say the the IRS does not have the type of resource to proof otherwise as there are 10K multinationals but one IRS. This doesn't even count foreign multinationals like Sony, Fujitsu and Samsung which has the same issues. There is a lot of vertical and horiozontal integregation between a large multinational containing dozens to hundreds of entity. Why do you think GE's tax return is sonmething like 20K pages?

You have local US state auditors, IRS auditors, and your third party Independent audits ( segment reporting) ALWAYS reviewing the numbers.

The huge multi-nations invest in Oracle / SAP and other ERP systems to allow them to track all of there financial results.

In addition, you have internal controls in accounting, tax, and IT that prevent creating any tax scheme avoidance.

SFace says

Go to indeed.com and search title: "international tax". There are currently 650 postings just on jobs that is strictly for international tax alone.

As there are International Accounting jobs as they relate to FAS 52 consolidations staff. Someone has to do the work and oversee compliance.

But they also have State Tax Managers, Fed Tax Managers, and Sales/Property Tax managers. No sinners to be found here.

SFace says

What the NYT described is in fact true. I think you need to step back and think about how these things work carefully. These issues are mostly high level legal issues designed to be IRS audit proof, albeit controversial, thus the financial audits will agree with these positions.

your source in the NYT.. not what he writes about as FACTS! Its all politics.

David Kocieniewski is a business reporter who has been covering the nation’s tax system for The New York Times since 2010.

"Neither corporations nor the government make tax returns public, and the information most companies disclose in their regulatory filings is insufficient to determine how much they pay in federal taxes and how that compares to the official United States corporate rate of 35 percent." - David Kocieniewski

http://www.nytimes.com/2011/09/11/technology/rich-tax-breaks-bolster-video-game-makers.html?ref=davidkocieniewski

SFace says

You're "Mr. No", "can't do it", "not possible" The fact is they all take it to the legal limit. and the end result is the US always get the smallest portion possible for obvious reasons.

What does a sale (revenue) in the USA to a US Customer have anything to do with Ireland or any "Tax Heaven". Which "arbitrary revenue and expenses" in the US are you going to carve out to transfer to a foreign entity to reduce or defer taxes.. no such practice exist today.

SFace says

My source is my knowledge from reading thousand's of 10K's, undertand how business and corporate structuring works in careers that look closely in these things in client service, and M&A.

My suggestion is go work for a big corporation.. SF based SalesForce, Oracle, or McKesson. Nothing like real life experience know the processes and the people actually doing the work.

"Neither corporations nor the government make tax returns public, and the information most companies disclose in their regulatory filings is insufficient to determine how much they pay in federal taxes and how that compares to the official United States corporate rate of 35 percent." - David Kocieniewski

SFace says

I also sleep with someone that deals with this stuff. What the NYT descrribe is dead on accurate.

I banged enough accounting pussy, but we never talk about shop!

thomas.wong1986 says

your source in the NYT.. not what he writes about as FACTS! Its all politics

You are the best tap dancer I've seen since Fred Astaire in "Puttin on the Ritz". The question stands, where are all the rebuttals for the NYT article, or for earlier articles in Forbes, WSJ, and The Economist about the exact same accounting practices. How has the entire world missed all these political stories that are non facts in such major publications? Why don't you rebut the story in detail.

thomas.wong1986 says

your source in the NYT.. not what he writes about as FACTS! Its all politics

You are the best tap dancer I've seen since Fred Astaire in "Puttin on the Ritz". The question stands, where are all the rebuttals for the NYT article, or for earlier articles in Forbes, WSJ, and The Economist about the exact same accounting practices. How has the entire world missed that these were only political stories that are non facts in such major publications? Why don't you rebut the story in detail.

bob2356 says

How has the entire world missed all these political stories that are non facts in such major publications? Why don't you rebut the story in detail.

they are journalists... surely they must have spoken or can get info from public accounting firms tax advisors and publish it.

but that would kill the political goals of the left.

Had there been something shady going on.. the IRS, SEC, and foreign Revenue (tax) authority would be all over this... like a pack of wolves.. where is my money?

thomas.wong1986 says

I banged enough accounting pussy, but we never talk about shop!

I'm going to have to go with Thomas Wang on this one. By the transmissitive property of accounting rules, he must have caught a knowledge outbreak by now.