is facebook founder a traitor?
- Thread starter Free Thinker
- Start date
http://www.hantzmonwiebel.com/live_data/documents/ruling-59-60.pdf
Read Section 8: Restrictive Agreements.
This is a estate planning strategy: Facebook has a restrictive repurchase agreement setting a price of $0.01 per share. This restrictive agreement expires upon IPO.
"Frequently, in the valuation of closely held stock for estate and gift tax purposes, it will be found that the stock is subject to an agreement restricting its sale or transfer. Where shares of stock were acquired by a decedent subject to an option reserved by the issuing corporation to repurchase at a certain price, the option price is usually accepted as the fair market value for estate tax purposes. See Rev. Rul. 54-76, C.B. 1954-1, 194."
Future claims or litigation brought on by the IRS will have jurisdictional issues. The key for him is to renounce citizenship while these restrictions are in force and prior to the IPO.
Singapore is a country with No Capital Gains Tax. The government of Singapore would intervene in any IRS claims against its citizens.
Really is a brilliant move...
You tell me you wouldn't take the same path/chance of cashing out tax free?
Read Section 8: Restrictive Agreements.
This is a estate planning strategy: Facebook has a restrictive repurchase agreement setting a price of $0.01 per share. This restrictive agreement expires upon IPO.
"Frequently, in the valuation of closely held stock for estate and gift tax purposes, it will be found that the stock is subject to an agreement restricting its sale or transfer. Where shares of stock were acquired by a decedent subject to an option reserved by the issuing corporation to repurchase at a certain price, the option price is usually accepted as the fair market value for estate tax purposes. See Rev. Rul. 54-76, C.B. 1954-1, 194."
Future claims or litigation brought on by the IRS will have jurisdictional issues. The key for him is to renounce citizenship while these restrictions are in force and prior to the IPO.
Singapore is a country with No Capital Gains Tax. The government of Singapore would intervene in any IRS claims against its citizens.
Really is a brilliant move...
You tell me you wouldn't take the same path/chance of cashing out tax free?
in order for a business to succeed you need a lot of things. you need infrastructure ,security, an educated workforce, a court system to enforce contract law, patent protection, access to capital. all of this is provided at a cost to the public in the us. so now he wants to move to Singapore. how far do you think he would have made it if he had attempted to start a business like that in Singapore?
I think we as a country have a right to expect some payback for his ability to succeed. really he is screwing the other taxpayers
Who cares? Why dont you take a look at all the people YOU voted for and see if they are paying their taxes.
who cares? most thinking people do.
I notice you didn't answer the man's question about whether you'd do the same thing, you just blathered about what you think this other guy should do, according to what you think is best in the abstract.
Hundreds of millions of people share the infrastructure in the US. 1% of them make it into "the 1%". Seems to me that those individuals should get the lion's share of their success since they CLEARLY are doing something that only they, out of the hundreds of millions who could do it, can do.
Also, how many of those resources did this guy actually consume above and beyond the taxes he had ALREADY paid? Unless you can put a number on that, the idea that he owes US citizens anything is a fallacy.
But, moochers don't care about fallacies, they care about mooching.
for a person calling themselves logic man you seem to be lacking in that quality.
if you know anything about business(doubtful) you would know that owners of startups probably pay little if any taxes. there are too many ways to hide income. the payoff is cap gains which is already taxed at a low 15%. 15% does not sound like too much for the oppertunity he was given.
it really doesnt matter how much he consumed. the business climate is priceless. he probably would have failed from Singapore and now he wants to run there for protection. shameful.
I was talking about his income tax already paid. Assuming he's been taking an income of over $130K/year in his position at Facebook, he's already paid for what he's consumed. Are you prepared to say that he's been taking a salary of less than $130K?
And, for your information, I have an MBA from a b-school here in the US (hint, the b-school in question is located in Chicago) and I've consulted to the CEOs of some of America's largest corporations, so I probably have forgotten more about business than you will ever know, even if you live 10 lifetimes.
Maybe it doesn't matter to a moocher like you how much he's consumed, but to a fair-minded person like me, that's exactly what matters. I see no reason to make someone pay more in taxes than what they consume. That's the precise definition of fairness. I know that charlatans such as yourself want to make the definition of fairness equivalent to something like "pays enough in taxes so that I can consume more than I produce", but that's a BS definition of fairness.
Actually, the business climate in the US, rather than being "priceless" is becoming more expensive thanks to moochers and the moocher enablers like yourself. Notice that I'm charitably assuming you make over $130K/year and are not yourself a moocher, which is probably an incorrect assumption. In fact, the main problem in the US right now is that idiots like you have been told that you aren't idiots all of your lives, which is giving you way more self-esteem than you actually merit. It sucks and, if you don't find your way back to a rational level of self-esteem, it's going to end up biting you in the ass.
BTW, weren't you the same stupid f-ck who didn't know the difference between a bond and an annuity the other day?
Jesus, you really do fall into the "stay silent and be thought a fool, rather than speak and remove all doubt" segment of the population, don't you? I hope your gift to your mother this Mother's Day is to kill yourself because that's pretty much the only thing of value you could do in this world.
