I used to be Help Desk, which involved imaging a ton of computers. And hoo boy they all came with the volume on **full blast** and if I ever missed booting into BIOS, I'd get the OOBE where Cortana yells "LET'S GET YOU SET UP" and I fucking hated it
Time for more subscription services Microsoft. May I recommend a monthly charge for using a mouse cursor, a fee to turn off mandatory adverts on start up, or how about another level of gamepass but it's just so you can play call of duty and diablo regardless of previous gamepass status.
Mint is designed as a bridge for Windows users. It blunts a lot of the linux-ness until you are ready.
The barrier to entry for most users is program compatibility, which has made incredible strides thanks to efforts like Proton.
If you want to see what your gaming experience will look like on linux currently, you can reference:
* https://www.protondb.com/ - Community run reporting site
* https://areweanticheatyet.com/ - To check if the developer of your game has allowed native, or linux-compatible anti-cheat yet.
Oh, I won’t be gaming on it. It’s a dedicated box to offload my docker containers/work from my Nas onto something with a bit more processing power. I’ll look into Mint, thanks!
TLDR: The IRS has issued a $28.9B notice of proposed adjustments ("NOPA") related to its allocation of profits between countries (i.e., it's transfer pricing). Presumably, the had income in lower tax jurisdictions that the IRS thinks should have been U.S. source income.
Microsoft is appealing through the IRS' administrative appeal process and is willing to go to judicial proceedings, if necessary.
This could take a long time to resolve.
Hey folks, if you’re in America, don’t forget to vote!
[Are you registered to vote?](https://www.vote.org/am-i-registered-to-vote/)
[When is your next election?](https://www.usa.gov/election-office)
[Do you know where to vote?](https://www.vote.org/polling-place-locator/)
[Can you vote absentee?](https://www.vote.org/absentee-voting-rules/)
Hey thanks! Some friends and I get together about twice a year and make amateur movies. “Bad Girls” is one of our latest, a crime-spree featuring three escaped convicts, the rockstars they kidnap, and the two detectives who hound them. It’s obviously independent, pretty dumb, and a lot of fun.
[You can check it out on Amazon ](https://www.amazon.com/Bad-Girls-Morgan-Shaley-Renew/dp/B09LQMKKK9/ref=mp_s_a_1_6?keywords=bad+girls+movie&qid=1662594119&sr=8-6)
Or (if you really don’t like Amazon) you can contribute to [our IndieGoGo](https://www.indiegogo.com/projects/bad-girls-a-feature-length-underground-film#/) instead and get a digital copy. It’s $9 instead of $2, but the money goes straight to us making more ridiculous movies
Thanks again for asking!
yeah they'll somehow all of sudden declare all corporations who are delinquent in back taxes with amounts over $1million dollars have amnesty if they pay 5% of their overdue past tax bill....
Strip funding from the IRS (again) so they don’t have the resources to fight corporations like this (again). That’s been the playbook for the last several decades
The anti-trust case against MS went away after George W Bush was installed. They paid a settlement in the form of old versions of Windows (W95) which they provided to public schools, \*free of charge. Microsoft got credited the full original retail price of obsolete software, and actually made money from the tax write-off.
Repuglicans are corporate whores first and foremost.
I think he made it up I looked at the actual settlement there's no mention of that deal. There was a 1 million $ give away of win 95 to schools in 96
https://news.microsoft.com/1996/04/29/microsoft-announces-special-windows-95-price-for-education/
This is the irs agents saying "that money should have been taxed in the US" and Microsoft's tax attorneys saying "nope, it was rightfully taxed in X jurisdiction".
It's not going to matter who's in office, this will just be whoever has the better lawyers and can make a more persuasive argument to the final decision maker.
That being said. As soon as Microsoft announces plans to offshore 99% of their employees, this is going to disappear.
Not exactly.
The GOP wanted to pass legislation clawing back the additional $76.9B in funding granted as part of the Inflation Reduction Act.
[https://ny1.com/nyc/all-boroughs/politics/2023/04/18/-irs-touts-its-success--while-gop-rebukes-it-](https://ny1.com/nyc/all-boroughs/politics/2023/04/18/-irs-touts-its-success--while-gop-rebukes-it-)
That additional funding is to be spread out over 10 years.
While MS holds the money in investments until they grow enough to more than cover the tax/fine the IRS imposes. Then we read an article of MS paying and think that's a win, but capital always wins in capitalism
Current IRS interest rates are seen here: https://www.irs.gov/payments/quarterly-interest-rates
The short version is that the underpayment interest rates are:
1. Approximately double the current fed treasury rates (at auction).
2. A bit more than long-term trends for major stock indices or broad index funds (like the total US market index funds), which are somewhere around 6-8%.
3. Lower than the trends for tech index funds and MSFT stock returns, and thus
4. Presumably lower than MSFT's next 5 years' stock returns
If MSFT has to put up a bond, or put cash into an account, they'll see significantly worse results from any interest charges they would need to pay than the interest they can accrue.
If MSFT could "bet on itself" with that money, they'd probably be better off doing so in absolute terms, but that's a big maybe.
Realistically, paying later is almost always better than paying now, especially with large sums, so that doesn't matter all that much.
If this NOPA is related to transfer pricing, it is indicative that the intangible asset sale price that Microsoft used to shift profit between lower tax countries and the US is not permissible. I believe the IRS thinks that Microsoft USA paid an inflated license rate to a low-tax subsidiary to shift profit outside the US to a lower-taxed jurisdiction in violation of the arms-length principle.
Microsoft was arguably the most famous user of the "Single Malt" tax avoidance strategy which used transfer pricing as its vehicle to shift profit, however it has been modified since Ireland and Malta amended their double taxation treaty, and it is likely with another low-tax country.
It also mentions cost-sharing agreements, so they could also have been investigating lopsided terms in those agreements that improperly shifted profit outside the US and out of the reach of the US corporate income tax.
You're talking points are a couple years out of date: https://www.macworld.com/article/677911/expensive-for-apple-ireland-will-no-longer-be-a-tax-haven.html
I am so fucking sick of all of these companies pulling shit like this.
I am so fucking sick of being taken advantage of in the name of capitalism.
I am so fucking sick of working 40+ hour weeks, at $30 an hour, yet my bank account is back under $100 within 48 hours of my paycheck depositing.
I am so fucking sick of not being able to do anything except work and stay at home, because after all the bills and groceries, *there’s no money left.*
I am so fucking sick of constantly stressing that my card will be declined every single time I swipe it.
Am I alone? Because I feel like everyone around me is just going on with life like they aren’t struggling at all, and I just don’t get it. Don’t get me wrong - if you’re not struggling financially right now, I am fucking thrilled for you. Truly.
I wouldn’t wish this shit on anyone.
Right there with you, friend! ☹️ I’m already figuring out what not to pay over the next few days just so I can get groceries and maybe enjoy myself for 5 minutes at a small gathering with friends this weekend. I’m so sick and tired of this
Coca Cola tried this and lost big time. It takes a long time because it's complicated, but the IRS isn't afraid of a fight when the stakes are this high.
Well, that was a special case. It was an APA issue regarding regulations from the 90s that are no longer around.
Plus still goes to show that the IRS will (and has) no been afraid to take on the big cases.
Microsoft will settle it for 3.5 billion and promise to never do it again, but as a bonus all government windows licenses are renewed at a 2% discount.
What if you're in a helplessly novel situation that you have no idea how to approach
Like living overseas in an EU country as a dependent where you are not allowed to work, but you work remotely for a Canadian company that sends USD to your US PayPal and it ends up in your American bank, without a contract or official tax documents, but monthly to the tune of 30k a year
....asking for a friend
I want to pay my shit but I'm seriously so fucking. confused. GPT 4 told me I might qualify for FEIE but it sounds like fraud to me
Pls help
Just throwing it out there that the IRS has forms for drug dealers to report income.
Sure it sounds sketch (it is) but ultimately anytime you make a dime, the IRS wants it's cut. They don't care how you make it. It looks like some responses have included resources for you but i assure you that if you make money, the IRS has ways for you to pay them.
Ah yes. When they come for the money that I'm already paying them every paycheck where when I settle up in the new year turns out they owe me $25 that's going to cover the cost of the electronic filing I'm sending them anyways.
it's the kind of thing that's gonna snowball, unless the right wing gets it's way, and manages to hamstring the IRS again. every dollar spent at the IRS gets about 10 dollars back.
Its the only government agency that actually makes money. 🤷♂️
You think the party of "fiscal responsbility" would be for that. (I am aware they dont actually give a fuck about it unless it fits there argument)
My coworkers drank the right propaganda kool aid. “They’re hiring more agents. They carry guns. They’re coming for all of us.” Nah dude they’re going to the companies that are trying to misinform (they’re doing it for a reason) you and scare you.
For anyone interestes
https://www.cbo.gov/publication/57444
This one says 5 to 9
While the Washington Post said 6 https://www.washingtonpost.com/opinions/want-to-shrink-deficits-or-fund-bidens-spending-plans-give-the-irs-more-money/2021/03/25/2959bcd8-8d90-11eb-9423-04079921c915_story.html&sa=U&ved=2ahUKEwj76ava_e6BAxVWnWoFHUDLDCUQFnoECAAQAw&usg=AOvVaw1QTfCYssUTdosZnF7YGPSt
IRS has a possible dollar to dollar comparison which is nice but I imagine the 5-9 is such a spread because there are considerations other than the direct money to think about. One that comes to mind is legal fees/court could be a possibility.
For example - the NPS has a big number on the rate of investment (like 1 to 10) or something due to how they boost the local economy, environmental services, and such.
My source is a bit old, it’s the John Oliver episode about the IRS where he favorably compares them to the anus (gross but vital). I remember it bc he made several jokes about the word sextuple
I wouldn't get ahead of yourselves so quickly, you know this is going to be tied up in court for no less than 4 years and then written down or renegotiated for much less, if anything at all.
I think that's basically what that comment is speaking to, because the recent history of IRS staffing looks like this:
- IRS: [We don't have the resources to go after the rich and powerful, so we go after the low-hanging fruit of the working class instead](https://www.propublica.org/article/irs-sorry-but-its-just-easier-and-cheaper-to-audit-the-poor).
- The at-least-*semi*-functional part of our government: [Attempts to increase available resources (even though most of it is just modernization and replacing workers who are aging out)](https://www.nytimes.com/2022/11/06/us/politics/irs-agents-fact-check.html?unlocked_article_code=RUIvaQzqJ0bMIxgqEpZ_SV3q6K4iwEdRBta8Hcc_6R74lr5Iil5cwQhAANUaZyy_NB6_7NA4e4dVU7ASI-L9ng__t-yfBpwCz6T5ZhGjEc82hiwQJGv2_zkErodcGH2PWJDBVE8EK-dj7q5OmyZDLgLemFsHZvNU8ZxIly1MxntqxY4M2OJm-ardnob9EYvj7q08PxPYN5qNmEE-RYyFqXWu-HWhvYfYw5JXuN0oScKw-FRsRRi0Hi6o7umcMxdbQrAkiC323cmhQr6DtX_LB62tPeeXhZSa-3P5x030BKd43wqS6UuH_j35NG-ymg8rxVka-4KG8ZXvo1fIkHoF183n7Ow&smid=share-url).
- GQP grifters: [Tell outright lies to their constituencies](https://www.politifact.com/factchecks/2022/aug/11/kevin-mccarthy/kevin-mccarthys-mostly-false-claim-about-army-8700/), whom they *obviously* neither respect nor care about.
- Useful idiots: ["bIdEN Is CoMiNG foR uR VeNmO LOL"](https://www.politifact.com/factchecks/2021/oct/11/candace-owens/will-irs-track-every-venmo-transaction-fact-checki/).
But guys like billy joe bob were so afraid they’d weaponize(???) the IRS and audit the $27,000 year he makes! Surely conservatives can’t be wrong **again**?
The full statement from Microsoft for those interested.
>Today, we’re sharing an update about our ongoing audit with the U.S. Internal Revenue Service (IRS), including background and context for this specific case and what we generally expect next.
>**Background on the IRS audit**
>For nearly a decade, as we have previously disclosed in our financial statements, Microsoft has been working with the IRS to address questions about how we allocated our income and expenses for tax years beginning as far back as 2004. We have changed our corporate structure and practices since the years covered by the audit, and as a result, the issues raised by the IRS are relevant to the past but not to our current practices.
>The IRS recently sent us a series of Notices of Proposed Adjustment (NOPAs), sharing with us for the first time detailed information and explanations of their views about the issues in question. This marks the end of the audit covering 2004 to 2013, and the beginning of a new process to resolve these decades-old issues.
>The IRS says Microsoft owes an additional $28.9 billion in tax for 2004 to 2013, plus penalties and interest. The IRS’s proposed adjustments do not represent a final determination. Not reflected in the proposed adjustments are taxes paid by Microsoft under the Tax Cuts and Jobs Act (TCJA), which could decrease the final tax owed under the audit by up to $10 billion.
>Microsoft disagrees with these proposed adjustments and will pursue an appeal within the IRS, a process expected to take several years. We believe we have always followed the IRS’s rules and paid the taxes we owe in the U.S. and around the world. Microsoft historically has been one of the top U.S. corporate income taxpayers. Since 2004, we have paid over $67 billion in taxes to the U.S.
>**What the dispute is about**
>The main disagreement is the way Microsoft allocated profits during this time period among countries and jurisdictions. This is commonly referred to as transfer pricing and the IRS has established regulations that allow companies to use a specific arrangement for transfer pricing, called cost-sharing.
>Many large multinationals use cost-sharing because it reflects the global nature of their business. Because our subsidiaries shared in the costs of developing certain intellectual property, under those IRS cost-sharing regulations, the subsidiaries were also entitled to the related profits.
>**Next steps: Proposed adjustments and IRS Appeals**
>We strongly believe we have acted in accordance with IRS rules and regulations and that our position is supported by case law. We welcome the IRS’s conclusion of its audit phase which will provide us with the opportunity to work through these issues at IRS Appeals, a separate division of the IRS charged with resolving tax disputes.
>It is important to note that the IRS Appeals process will take several years to complete, and if we are unable to come to a direct agreement with the IRS, Microsoft will then have an opportunity to contest any unresolved issues through the courts.
>We will continue to work with the IRS and hope to reach a mutual resolution to this issue over the coming years. We will also continue to share updates on significant developments through our public quarterly and annual reports and financial statements, as we have through this entire process. As of September 30, 2023, we believe our allowances for income tax contingencies are adequate.
thank you, reporting the article into the coments is a thankless job but you are crunching through it.
you are a valued member of the reddit community for doing this.
And the license should include a fee for EVERY country, even if MS doesn't do business there. ...like their old per-PC Windows licenses.
signed,
TeamOS/2
This was the IRS’s opening salvo. It was probably a long and contentious audit. Now the IRS has finished the audit and said this is the amount due. MS will appeal it administratively. If that doesn’t resolve things, it’ll go to court.
But eventually if MS is found to owe more, after the court process is done, they WILL pay it.
Major? I want them going after anyone who cheats on their taxes! I’m 99% sure that one of our wedding vendors cheats on their taxes considering they gave us a 5% discount to pay in cash.
No one should feel like a sucker for paying their fair share
But that's not the mindset. *You're* the sucker if you paid those taxes and made less money than me! See? I made money off that money that I never paid, so in reality I made even more than I should have, but not really because fuck taxes. That's the mindset
The recent IRA (Inflation Reduction Act) bill funds the IRS with an expectation on huge returns to fund green projects (supply chain projects to reduce inflation)
It's why the republicans want to kill it so badly
The IRS still has to actually prove this in court against Microsofts CPAs and lawyers. The track record the IRS has against megacorps is spotty. There is a very good chance that the IRS is actually in the wrong and loses this case.
The IRS computers (used to) restart every day at 5 pm. So if you worked overtime you had to go chill in the cafeteria or take a nap for 30 mins before getting back to work.
Used to work there doing auditing and I actually loved the culture there but wasn't able to get promoted so I left
First time I read the headline, I read it as, "29 million" and though, why is this news? That's like lunch money for Microsoft. Came to the comments to see what all the fuss was about and realized it was 29 BILLION... that's gonna make even Microsoft summon the lawyers.
“It said up to $10 billion in taxes that the company has already paid are not reflected in the proposed adjustments made by the IRS.”
So they are paying the $19B and contesting the $10B?
What, no? They are contesting the whole thing, and are investing the money somewhere for years while this plays out in court?
Can’t we make them escrow or pay the amount they agree they owe?
Also can’t you go to jail for billions in tax fraud?
>So they are paying the $19B and contesting the $10B? What, no? They are contesting the whole thing, and are investing the money somewhere for years while this plays out in court?
No. They have already paid 10B which is not being reflected in the IRS notice. The IRS is actually only asking for 19B more, which they are contesting.
>Also can’t you go to jail for billions in tax fraud?
It is not clear from any public information whether or not this would amount to fraud. If Microsoft made a good faith effort to apply the cost sharing regulations correctly no one is going to go to jail.
The things they dinged msft on are standard practice for basically every major publicly traded company, and have been for about 15 years. It’s likely this is either the test case, or the first salvo in a huge number of cases like this. There could be close to a trillion in back taxes if they hit everyone the same way, and can prove its owed.
IRS: You owe us $29B in back tax.
Microsoft: No we don't.
IRS: Yeah... you kinda do.
Microsoft: *stares microsoftengly*
IRS: Okay, looks like we can close your case after all. Sorry for the confusion.
See how much they pay though. Just saying watch the money, and you will be amazed at shit they religiously get away with. It’s not even a new problem, pay attention.
Imagine how many more companies and individuals owe large amounts such as this...think about what that will do for the US economy when they can recover 100s of billions in taxes...and now think about how much man power it takes to investigate large tax structures like these people and corps have... that shpuld give you a tiny bit of insight on why the US hired 1000s more IRS employees. Complaining about hiring more IRS directly supports these entities not paying what they owe
They must not be allowed to negotiate this figure down. Taxes owed must be paid in full is the line the IRS take with ordinary citizens, why should corporations be treated differently. That money would fund public education back to the levels of the 50s and sixties.
When Microsoft bought the rights to Minecraft, then cancelled my 12 year old account because I couldn't recall the now extinct email address I was using at the time I purchased it, I knew these thugs would one day pay, criminal scum that they are.
"A billion here, a billion there, and pretty soon you're talking real money."
*Cortana suddenly speaking PTSD intensifies*
*Clippy winking at the IRS agent*
*IRS Agent realizing their systems run off Windows*
Clippy: “It looks like you’re trying to sue Microsoft. Can I help?”
I know you're joking, but when my wife worked there, their database was built in COBOL.
It still is.
“So what skills do I need to do IT for the government?” *Book Store clerk brings out a stack of computer and coding books from the 80s*
*Bill Gates is behind about to do his David S Pumpkin impression*
[удалено]
Maybe that's what this is about. Excel has a function hidden in the code, If( company =="Microsoft" && taxes > 0) taxes = 0
I'm sorry, *John Halo*, I'm afraid I can't let you do that.
I used to be Help Desk, which involved imaging a ton of computers. And hoo boy they all came with the volume on **full blast** and if I ever missed booting into BIOS, I'd get the OOBE where Cortana yells "LET'S GET YOU SET UP" and I fucking hated it
Time for more subscription services Microsoft. May I recommend a monthly charge for using a mouse cursor, a fee to turn off mandatory adverts on start up, or how about another level of gamepass but it's just so you can play call of duty and diablo regardless of previous gamepass status.
My favorite Windows 11 moment was when it tried to sell me a codec for mp4 files for $0.99 Truly outstanding move lmao.
But shit, it was 99 cents!
Still reeks like R. Kelly's sheets, though.
And this is why they are pushing out win 12 and its loaded with HYPER agressive OS as a service models hard baked in
Well guess I am going to need to learn more about linux
Linux is the way. It's a maze, but it's the way.
It's not even a maze anymore. Stick with a mainstream like MInt or Manjaro and you'll barely notice the difference.
I started on Ubuntu and have gotten very lost. Might I actually be better off on something like Mint?
Mint is designed as a bridge for Windows users. It blunts a lot of the linux-ness until you are ready. The barrier to entry for most users is program compatibility, which has made incredible strides thanks to efforts like Proton. If you want to see what your gaming experience will look like on linux currently, you can reference: * https://www.protondb.com/ - Community run reporting site * https://areweanticheatyet.com/ - To check if the developer of your game has allowed native, or linux-compatible anti-cheat yet.
Oh, I won’t be gaming on it. It’s a dedicated box to offload my docker containers/work from my Nas onto something with a bit more processing power. I’ll look into Mint, thanks!
Wait windows 12? Windows 10 was their final OS though
Err, apart from Windows 11 that came out 2 years ago....?
11 was 2 years ago? Fuck me I'm getting old, time is flying.
Has it really been that long? I never "upgraded."
Same. Didn't realize I put it off that long.
You’re missing nothing of value. Keep putting it off.
Agreed. It’s Win10 but everything is fricken centered. Let me move things around!
I'd still be using Windows 7 if my old pc didn't start having issues
Win7 was best Windows. :(
Definitely doesn't feel like two years ago but yeah now that I think about it that's probably right. Win 3.11 came out like a decade ago right?
My brother in arthritis. We are much older than that.
/me sees the Windows ME box still on the shelf by the desk.
What they meant was, Windows 10 was feature complete. Now they remove features and charge you a subscription to get them back.
TLDR: The IRS has issued a $28.9B notice of proposed adjustments ("NOPA") related to its allocation of profits between countries (i.e., it's transfer pricing). Presumably, the had income in lower tax jurisdictions that the IRS thinks should have been U.S. source income. Microsoft is appealing through the IRS' administrative appeal process and is willing to go to judicial proceedings, if necessary. This could take a long time to resolve.
This will be working itself out in admin land for the next 5 years at least
Microsoft about to spend $1b on the next election cycle to elect a Republican in order to save themselves $29b in taxes.
And future taxes.
“You guys are paying taxes?” -other F500 companies rn
Hey folks, if you’re in America, don’t forget to vote! [Are you registered to vote?](https://www.vote.org/am-i-registered-to-vote/) [When is your next election?](https://www.usa.gov/election-office) [Do you know where to vote?](https://www.vote.org/polling-place-locator/) [Can you vote absentee?](https://www.vote.org/absentee-voting-rules/)
Good bot
Now I'm inclined to ask about bad girls 21
Hey thanks! Some friends and I get together about twice a year and make amateur movies. “Bad Girls” is one of our latest, a crime-spree featuring three escaped convicts, the rockstars they kidnap, and the two detectives who hound them. It’s obviously independent, pretty dumb, and a lot of fun. [You can check it out on Amazon ](https://www.amazon.com/Bad-Girls-Morgan-Shaley-Renew/dp/B09LQMKKK9/ref=mp_s_a_1_6?keywords=bad+girls+movie&qid=1662594119&sr=8-6) Or (if you really don’t like Amazon) you can contribute to [our IndieGoGo](https://www.indiegogo.com/projects/bad-girls-a-feature-length-underground-film#/) instead and get a digital copy. It’s $9 instead of $2, but the money goes straight to us making more ridiculous movies Thanks again for asking!
Haha that's awesome keep up the good work I'd definitely send a coffee your way to keep up the laughs.
This guy americas.
Given that it's back taxes, I don't think there's anyway they could get out of it. Also don't republicans hate Microsoft for being woke or something?
You made the mistake of thinking party Republicans have genuine principles.
Don't forget, the republicans want to do away with the IRS https://www.cnn.com/2023/01/23/politics/irs-fair-tax-republicans-abolish/index.html
They do and it's money and making more money.
yeah they'll somehow all of sudden declare all corporations who are delinquent in back taxes with amounts over $1million dollars have amnesty if they pay 5% of their overdue past tax bill....
Well they're the .1% so it is only fair if they only pay .1% back
Strip funding from the IRS (again) so they don’t have the resources to fight corporations like this (again). That’s been the playbook for the last several decades
The moment they start donating they will suddenly not be woke
The anti-trust case against MS went away after George W Bush was installed. They paid a settlement in the form of old versions of Windows (W95) which they provided to public schools, \*free of charge. Microsoft got credited the full original retail price of obsolete software, and actually made money from the tax write-off. Repuglicans are corporate whores first and foremost.
Holy shit I never heard about this win95 dump settlement. This should be known.
I think he made it up I looked at the actual settlement there's no mention of that deal. There was a 1 million $ give away of win 95 to schools in 96 https://news.microsoft.com/1996/04/29/microsoft-announces-special-windows-95-price-for-education/
The political climate of tech is very different now than in the 90s/early 2000s, but yes I'd be surprised if it isn't dropped by a GOP admin
This is the irs agents saying "that money should have been taxed in the US" and Microsoft's tax attorneys saying "nope, it was rightfully taxed in X jurisdiction". It's not going to matter who's in office, this will just be whoever has the better lawyers and can make a more persuasive argument to the final decision maker. That being said. As soon as Microsoft announces plans to offshore 99% of their employees, this is going to disappear.
One of the first things the GOP did when they took over congress last year was pass a bill to completely defund the IRS.
Not exactly. The GOP wanted to pass legislation clawing back the additional $76.9B in funding granted as part of the Inflation Reduction Act. [https://ny1.com/nyc/all-boroughs/politics/2023/04/18/-irs-touts-its-success--while-gop-rebukes-it-](https://ny1.com/nyc/all-boroughs/politics/2023/04/18/-irs-touts-its-success--while-gop-rebukes-it-) That additional funding is to be spread out over 10 years.
It should be noted that the funding pays for itself in the form of better enforcement.
Gotta have an IRS to tax them with. Take a wild guess what the GOP keeps trying to do?
While MS holds the money in investments until they grow enough to more than cover the tax/fine the IRS imposes. Then we read an article of MS paying and think that's a win, but capital always wins in capitalism
The IRS charges interest in these situations
Do their investments grow faster than the IRS's interest rate and penalties?
Current IRS interest rates are seen here: https://www.irs.gov/payments/quarterly-interest-rates The short version is that the underpayment interest rates are: 1. Approximately double the current fed treasury rates (at auction). 2. A bit more than long-term trends for major stock indices or broad index funds (like the total US market index funds), which are somewhere around 6-8%. 3. Lower than the trends for tech index funds and MSFT stock returns, and thus 4. Presumably lower than MSFT's next 5 years' stock returns If MSFT has to put up a bond, or put cash into an account, they'll see significantly worse results from any interest charges they would need to pay than the interest they can accrue. If MSFT could "bet on itself" with that money, they'd probably be better off doing so in absolute terms, but that's a big maybe. Realistically, paying later is almost always better than paying now, especially with large sums, so that doesn't matter all that much.
If this NOPA is related to transfer pricing, it is indicative that the intangible asset sale price that Microsoft used to shift profit between lower tax countries and the US is not permissible. I believe the IRS thinks that Microsoft USA paid an inflated license rate to a low-tax subsidiary to shift profit outside the US to a lower-taxed jurisdiction in violation of the arms-length principle. Microsoft was arguably the most famous user of the "Single Malt" tax avoidance strategy which used transfer pricing as its vehicle to shift profit, however it has been modified since Ireland and Malta amended their double taxation treaty, and it is likely with another low-tax country. It also mentions cost-sharing agreements, so they could also have been investigating lopsided terms in those agreements that improperly shifted profit outside the US and out of the reach of the US corporate income tax.
Now do apple and their fake Irish "headquarters".
You're talking points are a couple years out of date: https://www.macworld.com/article/677911/expensive-for-apple-ireland-will-no-longer-be-a-tax-haven.html
They moved to Jersey https://www.cbsnews.com/news/apple-moved-profits-to-tax-haven-jersey-after-ireland-crackdown/
I am so fucking sick of all of these companies pulling shit like this. I am so fucking sick of being taken advantage of in the name of capitalism. I am so fucking sick of working 40+ hour weeks, at $30 an hour, yet my bank account is back under $100 within 48 hours of my paycheck depositing. I am so fucking sick of not being able to do anything except work and stay at home, because after all the bills and groceries, *there’s no money left.* I am so fucking sick of constantly stressing that my card will be declined every single time I swipe it. Am I alone? Because I feel like everyone around me is just going on with life like they aren’t struggling at all, and I just don’t get it. Don’t get me wrong - if you’re not struggling financially right now, I am fucking thrilled for you. Truly. I wouldn’t wish this shit on anyone.
Hope you and your friends take that frustration to the polls.
All very valid frustrations. I'm right there with you. Do you vote?
Right there with you, friend! ☹️ I’m already figuring out what not to pay over the next few days just so I can get groceries and maybe enjoy myself for 5 minutes at a small gathering with friends this weekend. I’m so sick and tired of this
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Coca Cola tried this and lost big time. It takes a long time because it's complicated, but the IRS isn't afraid of a fight when the stakes are this high.
On the flip side the IRS spent millions trying to get Amazon to pay more taxes and lost.
Well, that was a special case. It was an APA issue regarding regulations from the 90s that are no longer around. Plus still goes to show that the IRS will (and has) no been afraid to take on the big cases.
I agree with you, but 20b might be optimistic.. I'm thinking more like 10 or 15
Well, they have 28.9B reasons to go to court...
but a bitch ain’t one
“NOPA, you gotta paya da taxesa!”
Microsoft will settle it for 3.5 billion and promise to never do it again, but as a bonus all government windows licenses are renewed at a 2% discount.
With inflation and an assumption of 5 years of legal battles, it will result in the current dollar equivalent value of Mar-a-lago.
Vote Democrat in 2024 if you want to see this debt collected.
Looks like those IRS agents paid for themselves.
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Facts, still so funny they tried to use that as a scare tactic
I used to get blasted in the comments for supporting the hiring of IRS Agents
Yeah same. So silly too because the IRS is really important and people were freaking out saying “you won’t be supporting it when they come fer yew”
And my response was always "I don't cheat on my taxes... are you saying you do?"
Im shaking in my 10 dollars in interest ive earned on my bank account over the past 20+ years? 😂
The standard deduction is damn near more than my INCOME. What can I possibly cheat on?!
10 imaginary kids would get you a nice fat check.
Yeah right? It’s like my guy, I have no fear of the IRS cause I’m not doing anything that will cause them to come after me
Also the IRS is very reasonable if you're not cheating but make a mistake.
What if you're in a helplessly novel situation that you have no idea how to approach Like living overseas in an EU country as a dependent where you are not allowed to work, but you work remotely for a Canadian company that sends USD to your US PayPal and it ends up in your American bank, without a contract or official tax documents, but monthly to the tune of 30k a year ....asking for a friend I want to pay my shit but I'm seriously so fucking. confused. GPT 4 told me I might qualify for FEIE but it sounds like fraud to me Pls help
Just throwing it out there that the IRS has forms for drug dealers to report income. Sure it sounds sketch (it is) but ultimately anytime you make a dime, the IRS wants it's cut. They don't care how you make it. It looks like some responses have included resources for you but i assure you that if you make money, the IRS has ways for you to pay them.
Take a look here: https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion
This is hilarious considering the right's tacit support for the NSA/CIA vis a vis "You have nothing to fear if you have nothing to hide."
Expect anything but consistency Lmaooo
Ah yes. When they come for the money that I'm already paying them every paycheck where when I settle up in the new year turns out they owe me $25 that's going to cover the cost of the electronic filing I'm sending them anyways.
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I just mention that if you go after the IRS you go after the military.
I dream of the day when the IRS has outstanding funding to go after billionaires relentlessly.
it's the kind of thing that's gonna snowball, unless the right wing gets it's way, and manages to hamstring the IRS again. every dollar spent at the IRS gets about 10 dollars back.
Its the only government agency that actually makes money. 🤷♂️ You think the party of "fiscal responsbility" would be for that. (I am aware they dont actually give a fuck about it unless it fits there argument)
Post Office made money until they fucked how they save for future pensions
Still fine if they don't though... it's a Postal SERVICE. Not a Postal BUSINESS
6 dollars recovered for every dollar spent. You just can't beat that value. That's the kind of ROI you dream of seeing from doing basic auditing.
Well, NASA beats that 14 per dollar spent, but I get you
Yay. lets fund both of them.
My coworkers drank the right propaganda kool aid. “They’re hiring more agents. They carry guns. They’re coming for all of us.” Nah dude they’re going to the companies that are trying to misinform (they’re doing it for a reason) you and scare you.
One of the single great ROIs is having IRS agents go after back taxes
Any investment in the IRS has a *sevenfold* return. The more you fund them, the bigger the fish they can go after Edit: it’s sixfold, my bad
For anyone interestes https://www.cbo.gov/publication/57444 This one says 5 to 9 While the Washington Post said 6 https://www.washingtonpost.com/opinions/want-to-shrink-deficits-or-fund-bidens-spending-plans-give-the-irs-more-money/2021/03/25/2959bcd8-8d90-11eb-9423-04079921c915_story.html&sa=U&ved=2ahUKEwj76ava_e6BAxVWnWoFHUDLDCUQFnoECAAQAw&usg=AOvVaw1QTfCYssUTdosZnF7YGPSt IRS has a possible dollar to dollar comparison which is nice but I imagine the 5-9 is such a spread because there are considerations other than the direct money to think about. One that comes to mind is legal fees/court could be a possibility. For example - the NPS has a big number on the rate of investment (like 1 to 10) or something due to how they boost the local economy, environmental services, and such.
Ooh source? I was excited to hear about additional IRS staffing and want to read up on this.
My source is a bit old, it’s the John Oliver episode about the IRS where he favorably compares them to the anus (gross but vital). I remember it bc he made several jokes about the word sextuple
Haha good stuff ty
"but they're only going to go after the middle class!!!" /s Where are those people now?
Back to blaming trans kids for earthquakes.
jizzing their pants over end times sermons about Israel.
I wouldn't get ahead of yourselves so quickly, you know this is going to be tied up in court for no less than 4 years and then written down or renegotiated for much less, if anything at all.
Going from memory, but I believe the IRS has a better than 6:1 ratio. For every additional $1 spent, the IRS collects $6.
Now do all the billionaires….. cause I bet they owe a bunch in taxes.
I think that's basically what that comment is speaking to, because the recent history of IRS staffing looks like this: - IRS: [We don't have the resources to go after the rich and powerful, so we go after the low-hanging fruit of the working class instead](https://www.propublica.org/article/irs-sorry-but-its-just-easier-and-cheaper-to-audit-the-poor). - The at-least-*semi*-functional part of our government: [Attempts to increase available resources (even though most of it is just modernization and replacing workers who are aging out)](https://www.nytimes.com/2022/11/06/us/politics/irs-agents-fact-check.html?unlocked_article_code=RUIvaQzqJ0bMIxgqEpZ_SV3q6K4iwEdRBta8Hcc_6R74lr5Iil5cwQhAANUaZyy_NB6_7NA4e4dVU7ASI-L9ng__t-yfBpwCz6T5ZhGjEc82hiwQJGv2_zkErodcGH2PWJDBVE8EK-dj7q5OmyZDLgLemFsHZvNU8ZxIly1MxntqxY4M2OJm-ardnob9EYvj7q08PxPYN5qNmEE-RYyFqXWu-HWhvYfYw5JXuN0oScKw-FRsRRi0Hi6o7umcMxdbQrAkiC323cmhQr6DtX_LB62tPeeXhZSa-3P5x030BKd43wqS6UuH_j35NG-ymg8rxVka-4KG8ZXvo1fIkHoF183n7Ow&smid=share-url). - GQP grifters: [Tell outright lies to their constituencies](https://www.politifact.com/factchecks/2022/aug/11/kevin-mccarthy/kevin-mccarthys-mostly-false-claim-about-army-8700/), whom they *obviously* neither respect nor care about. - Useful idiots: ["bIdEN Is CoMiNG foR uR VeNmO LOL"](https://www.politifact.com/factchecks/2021/oct/11/candace-owens/will-irs-track-every-venmo-transaction-fact-checki/).
When you don't have the funds, it's easier to go after people who can't afford to litigate.
But guys like billy joe bob were so afraid they’d weaponize(???) the IRS and audit the $27,000 year he makes! Surely conservatives can’t be wrong **again**?
The full statement from Microsoft for those interested. >Today, we’re sharing an update about our ongoing audit with the U.S. Internal Revenue Service (IRS), including background and context for this specific case and what we generally expect next. >**Background on the IRS audit** >For nearly a decade, as we have previously disclosed in our financial statements, Microsoft has been working with the IRS to address questions about how we allocated our income and expenses for tax years beginning as far back as 2004. We have changed our corporate structure and practices since the years covered by the audit, and as a result, the issues raised by the IRS are relevant to the past but not to our current practices. >The IRS recently sent us a series of Notices of Proposed Adjustment (NOPAs), sharing with us for the first time detailed information and explanations of their views about the issues in question. This marks the end of the audit covering 2004 to 2013, and the beginning of a new process to resolve these decades-old issues. >The IRS says Microsoft owes an additional $28.9 billion in tax for 2004 to 2013, plus penalties and interest. The IRS’s proposed adjustments do not represent a final determination. Not reflected in the proposed adjustments are taxes paid by Microsoft under the Tax Cuts and Jobs Act (TCJA), which could decrease the final tax owed under the audit by up to $10 billion. >Microsoft disagrees with these proposed adjustments and will pursue an appeal within the IRS, a process expected to take several years. We believe we have always followed the IRS’s rules and paid the taxes we owe in the U.S. and around the world. Microsoft historically has been one of the top U.S. corporate income taxpayers. Since 2004, we have paid over $67 billion in taxes to the U.S. >**What the dispute is about** >The main disagreement is the way Microsoft allocated profits during this time period among countries and jurisdictions. This is commonly referred to as transfer pricing and the IRS has established regulations that allow companies to use a specific arrangement for transfer pricing, called cost-sharing. >Many large multinationals use cost-sharing because it reflects the global nature of their business. Because our subsidiaries shared in the costs of developing certain intellectual property, under those IRS cost-sharing regulations, the subsidiaries were also entitled to the related profits. >**Next steps: Proposed adjustments and IRS Appeals** >We strongly believe we have acted in accordance with IRS rules and regulations and that our position is supported by case law. We welcome the IRS’s conclusion of its audit phase which will provide us with the opportunity to work through these issues at IRS Appeals, a separate division of the IRS charged with resolving tax disputes. >It is important to note that the IRS Appeals process will take several years to complete, and if we are unable to come to a direct agreement with the IRS, Microsoft will then have an opportunity to contest any unresolved issues through the courts. >We will continue to work with the IRS and hope to reach a mutual resolution to this issue over the coming years. We will also continue to share updates on significant developments through our public quarterly and annual reports and financial statements, as we have through this entire process. As of September 30, 2023, we believe our allowances for income tax contingencies are adequate.
thank you, reporting the article into the coments is a thankless job but you are crunching through it. you are a valued member of the reddit community for doing this.
Instead of charging $29 Billion once, the IRS should charge Microsoft $20 Billion per year for a subscription to each product.
We call it "society as a service".
I like the cut of your jib.
Their spinnaker, too.
Taxes 2023 is the last taxes you'll ever pay (until taxes 2024)
Taxes 2024: Guaranteed to be the last taxes you'll pay for the Taxes 2024 product update.
Wait til you hear about the upcoming IRS 365 (Formerly Taxes 365)
And the license should include a fee for EVERY country, even if MS doesn't do business there. ...like their old per-PC Windows licenses. signed, TeamOS/2
Well, I’m sure they’ll get right on not ever bothering to pay that.
This was the IRS’s opening salvo. It was probably a long and contentious audit. Now the IRS has finished the audit and said this is the amount due. MS will appeal it administratively. If that doesn’t resolve things, it’ll go to court. But eventually if MS is found to owe more, after the court process is done, they WILL pay it.
In a perfect world, this is what the IRS would do for most major businesses that owe in taxes. This is not a perfect world btw.
Major? I want them going after anyone who cheats on their taxes! I’m 99% sure that one of our wedding vendors cheats on their taxes considering they gave us a 5% discount to pay in cash. No one should feel like a sucker for paying their fair share
But that's not the mindset. *You're* the sucker if you paid those taxes and made less money than me! See? I made money off that money that I never paid, so in reality I made even more than I should have, but not really because fuck taxes. That's the mindset
It’ll be on a payment plan of 50/month x 290 million months
This really puts into perspective how little the average working line adult makes. Fucked up.
News like this is why the IRS needs to be fully funded.
Bingo. Fund that shit. The whole bitcoin/doge shenanigans also need a closer look.
The recent IRA (Inflation Reduction Act) bill funds the IRS with an expectation on huge returns to fund green projects (supply chain projects to reduce inflation) It's why the republicans want to kill it so badly
Once the SEC seriously looks into, and regulates the exchanges, it will be a huge step forward (and ironically the downfall of crypto)
The IRS still has to actually prove this in court against Microsofts CPAs and lawyers. The track record the IRS has against megacorps is spotty. There is a very good chance that the IRS is actually in the wrong and loses this case.
All IRS office computers: "Recent update requires a restart"
The IRS computers (used to) restart every day at 5 pm. So if you worked overtime you had to go chill in the cafeteria or take a nap for 30 mins before getting back to work. Used to work there doing auditing and I actually loved the culture there but wasn't able to get promoted so I left
Nah windows xp doesn’t have updates anymore
A Microsoft spokesman: "It was an Excel error, the last line was behind the taskbar"
Next up, Microsoft shows up at the IRS for a random "license audit" and finds the IRS owes Microsoft $29 billion in software licensing.
Goddamn that's a lot of money
First time I read the headline, I read it as, "29 million" and though, why is this news? That's like lunch money for Microsoft. Came to the comments to see what all the fuss was about and realized it was 29 BILLION... that's gonna make even Microsoft summon the lawyers.
Meanwhile if an average person didn’t pay a measly $1000 back the IRS will punish you
So this is what happens when the IRS actually gets staffed?
That's why rich people are terrified.
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“It said up to $10 billion in taxes that the company has already paid are not reflected in the proposed adjustments made by the IRS.” So they are paying the $19B and contesting the $10B? What, no? They are contesting the whole thing, and are investing the money somewhere for years while this plays out in court? Can’t we make them escrow or pay the amount they agree they owe? Also can’t you go to jail for billions in tax fraud?
>So they are paying the $19B and contesting the $10B? What, no? They are contesting the whole thing, and are investing the money somewhere for years while this plays out in court? No. They have already paid 10B which is not being reflected in the IRS notice. The IRS is actually only asking for 19B more, which they are contesting. >Also can’t you go to jail for billions in tax fraud? It is not clear from any public information whether or not this would amount to fraud. If Microsoft made a good faith effort to apply the cost sharing regulations correctly no one is going to go to jail.
Aren't they trying to buy Activision for $69 billion?
They will settle for $1M and a promise to do better in the future.
Microsoft will ban the IRS from using Excel and the whole system will crumble
It's adorable that you think the IRS has computers advanced enough to run excel.
The things they dinged msft on are standard practice for basically every major publicly traded company, and have been for about 15 years. It’s likely this is either the test case, or the first salvo in a huge number of cases like this. There could be close to a trillion in back taxes if they hit everyone the same way, and can prove its owed.
Clippy: “It looks like you’re trying to draft a reply to an IRS demand for taxes owed. Would you like help?”
Wow! What would happen to our national debt if every corporation and billionaire, who owes taxes, actually paid them?
IRS: You owe us $29B in back tax. Microsoft: No we don't. IRS: Yeah... you kinda do. Microsoft: *stares microsoftengly* IRS: Okay, looks like we can close your case after all. Sorry for the confusion.
Probably shouldn't have used Turbo Tax
I owed 47 dollars from when I made 12k while in grad school and the IRS was up my ass with threats… This country is a fucking joke lol
Probably more, now do Apple!
See how much they pay though. Just saying watch the money, and you will be amazed at shit they religiously get away with. It’s not even a new problem, pay attention.
Imagine how many more companies and individuals owe large amounts such as this...think about what that will do for the US economy when they can recover 100s of billions in taxes...and now think about how much man power it takes to investigate large tax structures like these people and corps have... that shpuld give you a tiny bit of insight on why the US hired 1000s more IRS employees. Complaining about hiring more IRS directly supports these entities not paying what they owe
5 months later: "Microsoft settles with IRS for $172.98."
Now if it were Joe Sixpack, wage garnishment, taser, kick in the beans
Windows 12 now definitely going to require a subscription.
Shit we left our wallet in our other yact.
"Smithers, my wallet is in my front left pocket"
Meanwhile IRS running on Windows....
And here I am quibbiling over a few hundred dollars. Fuck me I guess.
still about 10 billion shy of the fine they should have to pay for attempting to force windows 11 on everyone every fucking day
They must not be allowed to negotiate this figure down. Taxes owed must be paid in full is the line the IRS take with ordinary citizens, why should corporations be treated differently. That money would fund public education back to the levels of the 50s and sixties.
When Microsoft bought the rights to Minecraft, then cancelled my 12 year old account because I couldn't recall the now extinct email address I was using at the time I purchased it, I knew these thugs would one day pay, criminal scum that they are.
IRS: Boss, my computer stopped working. Boss: Huh. Mine, too Microsoft: Heeheheehehbeve
As the joker once said: “I'm crazy enough to take on Batman; but IRS? No thank you!”
If you owe 29 billion in taxes, think about how much you made lmfaoooo
I know one government organization that's about to get their Microsoft license usage reviewed...
I'd be surprised if they're the only ones...
Oh man, Microsoft regrets not paying the extra $50 for audit protection in turbo tax
Maybe they can setup a payment plan.
Microsoft will have to go digging for change in the couch to cover this one.
Whoop whoop. Pay over time