David,

You said, "If the subsidiary/ affiliate companies share facilities or administrative personnel, the IRS will probably force you to treat them as one entity for tax purposes anyway)."

___

I don't think so. There are technical reasons for this that I am sure no one else here wants to here about, but I think this is wrong -- if I understand what you are saying.

The bottom line is the US will tax the lower tier subsidiary's income, the UK will tax the UK subsidiary corporation on its income, and the US will tax the US parent entity on both its own income and the income from its UK sub, including the UK sub's share of the lower tier sub's US income. The tax treaties and foreign taxes provision of the US won't necessarily prevent all double taxation that could result from this mess. A better structure would be for the US parent to have two subsidiaries: one US and one UK. This avoids the messy in-the-US out-the-US in-the-US structure. I can think of no tax advantage to such a structure -- or any other advantage for that matter.

Then again, I am not an international tax expert.

What do the rest of you think?

Bruce: As far as I can determine, Louis Riel never performed priestly duties, even though Archbishop Taché presumably funded Riel's seminary education in Montreal in the hopes that Riel would return to the St. Boniface diocese in such a capacity. As it turned out Riel concentrated on studying law, and other than a stint teaching at a mission school in Montana, he never worked for the Roman Catholic church. It appears that his mental illness first expressed itself during a mass in Washington D.C., but I won't bore everyone here with a rehash of the traitor/hero argument.

Edited by author 04-24-2004 02:45 AM
BruceR:

This is not "Peacekeeping". This is not about the UN. That model is on the scrapheap of history.

The model is this:

U.S. Soldiers Re-Enlist in Strong Numbers

If you think Ft. Campbell fucks around, you're dead wrong.

Obviously Canada intends to sit this one out. It's all blah blah blah. At least until the serious attacks come, which they most certainly will. "Multiculturalism" is a deep sham. All radical--and many moderate--Imams preach that it is the ultimate duty of Muslims to kill, convert or enslave infidels.

Don't blame be for saying this. I've seen too much to fall for "political correctness". I didn't create that reality. Centuries of backward, aggressive culture focused on conquest did.

I guess people thought I was being flippant when I told you below that we are doing the biggest recruiting drives since WWII. The Draft may well come back.

This is not Vietnam. If you mistake it for that you have totally missed the big picture. This is WWIII. It will take many years to win, but the American people are roused to fight, and the "little dogs" have to stand aside and stay in the yard for a while.

Virtually nobody on this board really "gets it" (I don't mean that as an insult, just a statement of fact). Even if the Democrats win in November (which is exceedingly unlikely), the branches now have serious momentum, and will be very difficult to recall at this point.

Stay tuned. We are going to mount the largest, most effective military force since Troy.

I like and respect you, BruceR, but your blog contains little of any weight any longer. World events are millions of times weightier than what blogs can deal with much longer. This could well go badly, depending on whether we decide to take down lit reactors (and I don't know if the Iranian plants are lit yet).

Diplomacy has been given every effort to succeed with the Islamists. Fallujah will fall next, I guarantee you that. I only wish I was there tonight.

Minigun

There are probably 1 - 1.2 billion muslims. Just so you have some idea of the scale of your task.

  PenGun
 Do What Now ???

TM Lutas

 Apple is just apple. There was essentially no real network functionality that ment anything until OS X. Now OS X is really freebsd 4.2+.

 You move the appleness out of the way, run it all from a terminal and lo the spiffiest tcp/ip network stack in the business (just ask M$) and all the rest of the BSD legacy, where networking was added to unix, is largly available.

 The problem here is freebsd does not scale really well as yet, so for 4 - 64 way machines you need linux or a *nix that will scale for the more ambitious applications.

 As for the VMS etc boys looking down their noses, well that _would_ be dumb. The reason all that stays where it is is that moving it is such a huge problem that they are gonna let the mainframes rust before they move ;).

  PenGun
 Do What Now ???

Wasn't the Mahdi's skull made into an inkwell?

Edited by author 04-25-2004 08:29 AM
It'll turn up on Antiques Roadshow someday and then we'll know for sure. (And CBC Newsworld will then finally have done something useful.)