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In order to gauge interest on HN you will need to tell them the price -- setup and annual maintenance. Then compute the estimated tax savings. "Savings" means

In order to gauge interest on HN you will need to tell them the price -- setup and annual maintenance. Then compute the estimated tax savings. "Savings" means the present value of a deferred tax liability. Until the tax deferral is large this value is not worth chasing. Especially since the true cost is not in the money. It is the distraction to management. It's a good idea. But compute the cost/benefit. Disclaimer. I am an international tax lawyer. I fix these things when people fuck 'em up because they don't spend money on the maintenance. Further. I really like the idea though. Much of the bespoke international tax stuff can be standardized and product-ized. If you pursue this idea do your analysis assuming setup costs are zero. They won't be but try it out. Assign all of the costs to annual maintenance. Assign a price to the penalty risks if the maintenance fails. See where your break even is. My guess is you won't bother until the foreign income generates US net (of foreign tax credit) tax liabilities of a couple of million a year. Another idea -- offshore structures in a box for holding IP, especially IP under development. Hold on. I'm at Chipolte. Must run to register internationaltaxlawyerinabox.com. :-)

husein10 13y ago
Thanks for the input. Re: Price - This was just a quick and dirty attempt to gauge interest before investing a ton of time figuring out exactly how much it would cost. Didn't see much of a point in figuring out the exact cost if nobody expressed any interest. I suspect that many HN readers understand that setting up this type of structure is likely a plus expected value play (assuming you have sufficient income to protect) given the fact that many major companies (apple, google, fb, twitter) have successfully implemented the Double Irish Arrangement. Also, I'll shoot you an email about this later today. Interested in hearing more of your thoughts on this matter.
- philiphodgen 13y ago
  Price is always relevant. I heard Nolan Bushnell talk at a VC lunch 20 years ago and he said (approximately) that all marketing research is bullshit until you say "What's your VISA card number?" This was the mid-90s and he was espousing lean startup philosophy then. But I digress. The idea ("international tax structures in a box") can only be intelligently pitched as a money question. E.g., "Your income tax liability this year is $2,000,000. You can postpone payment and use that money as working capital for one year, and you pay zero interest on that working capital "loan" from the IRS. At your gross profit margin of 40%, at the end of the year you will have $800,000 in profit that you would not have otherwise achieved. What's that worth to you, Dear CFO?" Take what the CFO would pay for that result. This is the value you have delivered to the customer. Now you assign a price to that. Tell the CFO you will deliver a black box of magic that delivers $800,000 of pre-tax profit in exchange for $X. This is how a CFO should look at these complex structures. And this, by the way, is how you do value pricing. I look forward to your email.

husein10 13y ago

Thanks for the input. Re: Price - This was just a quick and dirty attempt to gauge interest before investing a ton of time figuring out exactly how much it would cost. Didn't see much of a point in figuring out the exact cost if nobody expressed any interest. I suspect that many HN readers understand that setting up this type of structure is likely a plus expected value play (assuming you have sufficient income to protect) given the fact that many major companies (apple, google, fb, twitter) have successfully implemented the Double Irish Arrangement. Also, I'll shoot you an email about this later today. Interested in hearing more of your thoughts on this matter.

philiphodgen 13y ago
Price is always relevant. I heard Nolan Bushnell talk at a VC lunch 20 years ago and he said (approximately) that all marketing research is bullshit until you say "What's your VISA card number?" This was the mid-90s and he was espousing lean startup philosophy then. But I digress. The idea ("international tax structures in a box") can only be intelligently pitched as a money question. E.g., "Your income tax liability this year is $2,000,000. You can postpone payment and use that money as working capital for one year, and you pay zero interest on that working capital "loan" from the IRS. At your gross profit margin of 40%, at the end of the year you will have $800,000 in profit that you would not have otherwise achieved. What's that worth to you, Dear CFO?" Take what the CFO would pay for that result. This is the value you have delivered to the customer. Now you assign a price to that. Tell the CFO you will deliver a black box of magic that delivers $800,000 of pre-tax profit in exchange for $X. This is how a CFO should look at these complex structures. And this, by the way, is how you do value pricing. I look forward to your email.