Were they given different quarter endings so that they would be able to provide a continuous series of loans without cro...
Do you agree that the loan program that we are talking about contained a prescribed schedule from HP's treasury and tax ...
But there is a heavy cost to the United States.
Are those facts relevant to whether or not there was an arm's-length agreement which led to a transfer agreement which r...
Of course you could lend from one to another. But that would violate Section 956.
Thus, it appears that both courts and the IRS may seek to apply substance over form to transactions that it views as abu...
I believe that you said, Mr. Ezrati, that you did not depend heavily upon these funds for your liquidity.
You just said there could be a loan from one.
Take a look at Exhibit 3c, would you?
If you want to say that Microsoft's tax burden in the United States is not reduced... that is aimed at reducing taxes.
But Microsoft Asia Island Limited, located in Bermuda, has no employees. Is that correct?
If check the box were eliminated, there would be more taxation under Subpart F.
Loss of tax revenue is a key cause of the problem. Shifting of profits offshore by multinational corporations is a major...
The bottom line, though, is not complex. We have a fiscal crisis in this country.
If any company can get away with having an effective repatriation of money overseas--without paying taxes, in other word...
So you never audited your own tax advice and the implementation of that advice in HP's operations?
The record is going to speak for itself on that statement of yours.
the goal is to have a tax policy that is transparent, that is reproducible, that is fair, that does not allow people to ...
