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.)

I went back to read VDH's article: typical: lots of erudite scholarship and historical references backing up overheated political opinionizing.....
But, among the other numerous nits to pick: I think his reference to "the fate of the Great Mahdi's resting place" may be more to the fact that the Mahdi's tomb was part of, IIRC, a mosque complex in Khartoum, capped by large and prominent dome. Winston Churchill, in his excellent dispatches from Omdurman, makes note of the fact that the Sudanese Mahdists believed that the Mahdi's tomb was protected by Allah and so invulnerable. British gunboat crews on the Nile thus made the dome one of their first targets, and its destruction by shellfire was supposed to have serious punctured the Sudanese' morale (which the slaughter of their fighters at Omdurman completely shattered).
I am guessing this is Hanson's oblique reference to the fact that Moqtada al-Sadr's "mahdist" insurgents are holed up in a sacred Shiite mosque in Najaf - however, I am not sure this would be a good analogy to want to promulgate as a hopeful outcome: Najaf 2004 is not Khratoum 1898 - not least in that there are no Kitcheners in charge!

Re Fallujah:

Fallujah is surrounded. They can't get resupply which means that those rockets, mortars and RPGs they're firing at long range against dug in Marines can't be replaced. That ammo can't be fired against Marines when they move in to close range. Fallujah is a true source of a lot of this, and it will be taken.

I have a friend who in 1968 was part of a platoon that went into Hue City, and had a few attachments and Marines he'd picked up for that fight. Forty of them got off the landing craft that took them across the Perfume River. At the end of the fight there were eleven of them still on their feet. They went in a heavy platoon, they left a squad.

This is a far bigger conflict than Vietnam. Iran, Syria, Algeria, Morocco, Indonesia, the Philippines--all of these have jihadist nests which must be destroyed at some point.

Canada, the US, and especially France (and other European countries) are heavily infiltrated by the enemy. That is a much more intractable problem than Fallujah. You can't exactly start randomly kicking in doors in New Jersey or Toronto. However this war will eventually end, as long as we can get a handle on the other enemy, the "Transnational Progressives" (i.e., recrudescent communism). The TPs and the Islamists form a Red/Brown (communist/Nazi) union which is absolutely dangerous

Testing this

Hmmm I test it and get an ancient Minigun post. Damn ;).

I guess there has been a data base screw up. They can probably repair this, assuming the data is still uncorrupted.

  PenGun
 Do What Now ???

 Guy Simonds is my choice

TM Lutas said:
 (talking about the PRC)
The US military may end up having to fight there after all, in the end. The only difference is that it'll be in a Barnett style weak, disconnected China and not the strong near-peer that currently figures in medium range Pentagon plans.

 You see the GWOT as a war of US global conquest? It would seem so. If I could be sure that was in the plans I would switch sides.

 I want _one_ government for this planet. We have much to do and the nation state deal is a failure. I am a pragmatist and if the US wants the world as it's states count me in.

 The United States of Earth. I like it.

  PenGun
 Do What Now ???

Edited by author 05-10-2004 02:02 PM
From Quicktopic

"I've got it working, but apparently about 300 messages are lost. Sorry for
the inconvenience."

 "Moan" and my long reasons post is gone ... damn.

  PenGun
 Do What Now ???

Condolences to all who have lost old threads. If any were addressed to me, resubmit.

PenGun /m4643 - No, I don't see the GWOT as US conquest. The DoD has to plan against an enemy. Pentagon planners look out and see who are likely military challenges and structure the force to successfully meet those challenges over the short, medium, and long terms. The DoD has looked at the PRC as a medium to long-term possible near peer competitor for some time and are trying to gather a force that could take it on if the politicians called them to do it.

What I said was that if the PRC blows up and you end up with a resurgence of warlordism in a post-communist China, with several of the warlords being nuclear, we might end up having to go in to restore stability but not as the DoD was planning it, to restrain PRC aggressive expansionism but rather to fix a failed state.

TM Lutas said

"We've had some reverses but the successes are real and they will be of lasting consequence."

 What successes would those be? Oh yeah ... you did get Sadam. Any more?

TM Lutas also said:

"The forces of disconnection are in their "Battle of the Bulge" phase. They are expending all because they know that once sovereignty is restored and elections become the main preoccupation of the country, they are history. Stand fast for the few months more until we get there."

 No the uprising is just getting started. They have had some success, Fallujah, and with the massive stupidity (it's a feature) at Abu Ghraib, they have the bit in their teeth. This is the _people_ of Iraq you are fighting. Make no mistake.

 Your military is starting to assert it's self. They are not prepared to see the despicable people in the white house (it's kinda grey now eh') ruin their toy.

  PenGun
 Do What Now ???