hvalika

6 ms·

1.
by hvalika 10y ago
You can't make it "dead simple" when some of the concepts are not "dead simple." Let me give you the example of debt vs equity. Just because the company/lender codes it as such, does not make it so. What might
2.
by hvalika 10y ago
I don't entirely disagree with your post but I generally avoid calling these loopholes. It is all about finding the mismatch between two countries -- For example, if a little kid asks his dad if he can go to the movies, and dad replies
3.
by hvalika 10y ago
Thanks Kell - I must ask - did Google ever approach the French Revenue Authorities and try to get a ruling ahead of time? I assume they are arguing that Google does not have a permanent establishment in France.
4.
by hvalika 10y ago
^^^ exactly that. The rule is generally that your "principal purpose" can't be to avoid taxes (in this case). There is also the "economic substance doctrine" which actually codifies the above principle. Basically, y
5.
by hvalika 11y ago
Thank you! People are blowing this whole LLC thing out of control. It really isn't a big deal deal at all. He probably went against the word of his tax advisors to use an LLC as opposed to a typical foundation. Just applaud the man for
6.
by hvalika 11y ago
Just a slight clarification -- there is no "avoidance" going on here. This is merely "deferral." Transferring the shares of any company to another company is often a tax free transaction (provided some basic rules are me
7.
by hvalika 11y ago
But really, what is this saying about the companies that are allowed to remain? Does the Pakistani government have the ability to monitor every message/email sent via phones through a domestic carrier? (I suppose all carriers are domes