I mean, if they actually did move their HQ (ie majority of costs, execs, etc) to Singapore, then sure. And that'd be totally fair. What maybe doesn't seem fai

I mean, if they actually did move their HQ (ie majority of costs, execs, etc) to Singapore, then sure. And that'd be totally fair. What maybe doesn't seem fair (haven't thought about it deeply enough to say for sure) is pretending your HQ is where you really just have a satellite while the core of your IP creation, expenses, exec decision making etc is in the US. It's like you're getting the benefits of being in the US (whatever you think they are), but not paying the full price for those benefits. What I hate about rules like this is that it basically forces you to follow them. You have a fiduciary duty to shareholders as an officer and/or director, and so you have hard time justifying not using a technique like this.