philiphodgen
Joined 16 years ago
Joined 16 years ago
1. Why am I hearing this?
2. Why am I hearing this NOW?
Try to drop your pre-existing beliefs about the topic for a moment (rich people bad, FedBots evil, etc) and ask why this attempt at persuasion has been brought to your attention.
Who benefits from the agitation that occur in your mind when you read this?
Source: am a lawyer.
Extreme privacy is extremely expensive and permanently lifestyle-altering.
Take your strategic and tactical cues from Cold War-era spycraft and from current-day hyperparanoid internet security practices.
I was in DC on a boondoggle maybe 15 years ago and had a meeting with an old-time staffer (and lawyer) for the Senate Finance Committee. Attached to the Democrat side of the SFC for what it’s worth.
He had been on the tax policy scene long enough to see the pre-1976 carryover basis days and the post-1976 step-up basis days.
He was adamant that a return to carry-over basis would be a shitshow for IRS administrative purposes and fervently argued for the current step-up at death law.
This is a Chesterton’s Fence situation.
The collective “we” seem to forget that many of these ideas have been tried before. This “soak the rich” idea (look at the CRS report and see the reference to an exemption for the little guy so we can tax the billionaire) is one such idea.
The other idea — floated by our current president — is to crank up the capital gains tax rate. This one has been tried (and reversed) before. It would be instructive to find out what those politicians Back In The Day were thinking when the capital gains tax rate went up and why it went down again.
A little bit of humility and history might save some optional wounds.
Loans must be interest-bearing. This makes your life as an entrepreneur more complex. Your tax return and the corporate tax return will cost more to prepare.
Optimize for simplicity in legal structure, bookkeeping, and tax return preparation.
(1) Why corporation?
(2) Why C corporation?
(3) Unless you’re injecting multiple millions of your own money into your new venture, whatever perceived tax benefit you can imagine will be dwarfed by the overhead and cognitive opportunity cost of getting clever.
(4) If you add investors, the first thing they’ll want to do is clear all the bullshit off your balance sheet. Why add it in the first place?
Just contribute capital, unless you can think of a damn good reason to do otherwise.
You need real tax advice. Go get some.
Is this sudden oh-so-close-to-libel wave of stories coordinated? Or is it a viral pile-on sparked by someone, somewhere?
Truly, these stories say more about the storyteller than they do about Elon Musk.
Cui bono?
Status with an airline is useful for (a) free upgrades, (b) lounge access, and (c) better phone service when you need to fix things.
I have Diamond status on Delta. (Top tier before their invite-only tier).
Upgrades. The only value I get out of it is that I can book a generic economy seat and immediately get upgraded to Comfort+ for free. I rarely get upgrades to First Class since Delta sells out the seats to real people for real money. I'm frequently #1 of a bunch of people on the upgrade list for nonexistent First Class seats.
Lounge access. I have the Delta Reserve Amex card that gets me into the lounges anyway.
Phone service. This is really an indictment of the shit service that airlines give. For a while, even with the priority phone service I would be on hold for an hour or so. It's far better now, admittedly.
Delta is making it drastically harder to achieve status in 2024. In all probability I am going to go free agent and fly any airline that gets me where I want to go, when I want to go, at a reasonable price.
The airline miles are useful. I don't think I've paid for a flight for my kids with money once in all the years they've been at university in other states. But that's just a "charge enough money on a credit card" thing. It has nothing to do with status.
Paste the URL in a comment.
Reason: U.S. tax reporting requirements create high accounting costs.
Your problem is not “controlled foreign corporation” status. That’s only for U.S. persons who are shareholders of non-U.S. corporations.
Your primary tax returns will be Form 1120 (the income tax return for a corporation) and Form 5472 (required when a U.S. corporation has at least one non-U.S. shareholder owning 25%+ of the stock).
Form 5472 is the anti-transfer pricing form used by the U.S. tax system to make sure that taxable income remains in the USA to get taxes. Penalties for screwing this up are steep: $25,000.
This means you will want to hire competent tax professionals. Competent U.S. international tax specialists tend to be rare and expensive.
Your tax reporting will also get more complicated in Germany.
I am a big believer in doing things correctly. Future You will reap the rewards that Today You made possible through hard work and solid foundations. Life is a marathon with no finish line.
That said, there are different gradients of “correct” at each stage of business growth.
I don’t know where you are now. I don’t know your revenue, your business needs, your product, where your customers are, whether you will hold this business forever or are building to be acquired, etc.
I will give you a data point for you to make a management decision, because this is a management decision and not an engineer decision. You are making a decision with significant opportunity cost to it, even if it is the correct decision.
Here you go. Money. Order of magnitude for a tax return for a simple U.S. corporation with ownership as you describe and minimal transactions between you and the corporation and the corporation and the outside world. $10,000. Reason: Form 5472. That’s the peak of the bell curve.
Opportunity cost of time and brain damage. 40 hours of your time per year (or pay someone and buy their time). You could be building a product or creating new customers.
At some point you need the infrastructure. Choosing the right time to buy it? That’s hard and there is no right answer.
Source: am international tax lawyer.
Standard legal waiver/disclaimer/pre-emptive strike/warning shot applies: I’m an idiot and I am not your lawyer, so this is not legal advice and if you think it is, you are an idiot.
1. How do I know you are who you say you are? (You don't identify yourself).
2. How do I know that you will do what you say you will do? (The website says says nothing).
3. How do I know that all spammers, worldwide, will do what you tell them to do and delete my email address from their databases permanently and forever? (Are you God?)
I'm sorry, but color me skeptical. Here's what I would want to see before accepting your offer:
A. Tell me who you are.
B. Tell me why I should trust you.
C. Tell me what you will do for me.
D. Tell me why you will succeed while Google, Barracuda, and countless other juggernauts have failed to keep spam out of my inbox.
"They sell you the benefits and give you the harms for free."
Your HN post sells me the benefits (no spam). That means you're giving me the harm for free. I don't know what harm is bundled with your benefits, so I will pass on buying the benefits.
My interpretation is that “strategy” as he defines it is an exercise in human whimsy. “I choose to play in this playing field.” “My theory for why I can achieve the objective — which is inherently outside my control — is xyz.” In other words, strategy is first a moment of creation. Ex nihilo.
After selecting a strategy the AI berserkers* take over and relentlessly and pitilessly drive you forward to Total World Domination.
So I guess what I’m saying is: I don’t understand how AI participates in that “In the beginning . . . “ creation of a strategy. Unless, of course, AI is God.
What am I not seeing?
* when I read all of the breathless doomer “AI is going to eat babies” articles online I am reminded of Fred Saberhagen’s Berserker series.
Thanks for posting this.
http://hodgen.com
Email address: my username at gmail.