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蘋果避稅祕訣 去年省24億美元 April 30, 2012

Posted by Ian Cheng in Funding.
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2012-04-30 01:11 工商時報 【記者李鐏龍/綜合外電報導】

 紐約時報披露美國科技巨擘蘋果公司能夠在全球合法避稅多達數十億美元的訣竅:將數位產品的銷售轉移至國外低稅率地區,將獲利轉移至國外低稅率地區或國內無資本利得稅的州,以降低應納所得稅及規避資本利得稅。

 紐約時報指出,據曾任美國財政部經濟學家的蘇利文(Marth Sullivan)研究後發現,若沒有這些避稅手法,則蘋果去年非常可能需要多繳24億美元的美國聯邦稅。

 按照專家及蘋果前高階主管所描述,蘋果避稅的手法十分綿密細膩,主軸則是在國內選擇企業所得稅率及資本利得稅率較低的州、在國外選擇企業所得稅率較低的國家或地區,設置蘋果子公司,然後將獲利轉移過去,以降低或規避稅負。

20120430-091846.jpgBraeburn Capital, an Apple subsidiary in Reno, Nev., manages and invests the company’s cash. Nevada has a corporate tax rate of zero, as opposed to the 8.84 percent levied in California, where Apple has its headquarters.

 國內部分,蘋果的總部設在加州,但同時則在內華達等其他州設立子公司,將美國銷售獲利中的相當部分轉移至子公司所掌控的帳戶,再投資於股市、債市及其他金融商品,其利得即不受加州管轄,在內華達州則可完全免稅。

 國外部分,蘋果在盧森堡設子公司,做為歐洲、非洲、中東或基本上任何地方所銷售數位產品的下載地,則其獲利即按盧國稅率課稅。

 蘋果是善用「雙重愛爾蘭」或「荷蘭三明治」等會計技巧的先驅及高手。

 在愛爾蘭設2家子公司,將加州所開發專利的權利金,進行內部移轉至其中之一,稅率即由美國的35%降至愛爾蘭約12.5%。

 蘋果事先已將其愛爾蘭子公司的部分所有權轉讓給蘋果設在維京群島的紙上子公司,因此將部分獲利轉至在愛爾蘭的子公司,即轉至免稅的維京群島。

 蘋果聲稱其去年全球獲利342億美元中,有240億美元或約70%是來自國外,即國內部分僅占30%。

 但蘇利文認為,考量蘋果產品的設計及行銷大都在美國,專利也是在美國研發,因此蘋果美國獲利在總獲利中的占比最少應達50%。

 蘇利文強調,這意味蘋果去年應有更多的獲利應按美國的企業所得稅率課徵,亦即蘋果去年的美國聯邦所得稅應再增加約24億美元。

 不過據報導指出,企業採用將獲利轉移至海外的方法避稅,有一大缺點,就是若要將這些獲利再轉回美國,仍必須再課稅。

Forget the data: VCs brace for the Instagram aftereffect April 20, 2012

Posted by Ian Cheng in Funding.
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By Stacey Higginbotham

Venture capitalists greeted the new year with fewer overall deals and dollars invested during the first quarter, but in the rapid-fire world of investing in web startups this first-quarter data is about as relevant as a day-old newspaper. There are two things to know as an entrepreneur looking at the latest MoneyTree Report from PricewaterhouseCoopers LLP and the National Venture Capital Association. The idea that the VC business is contracting as the NVCA and news reports imply is laughable in a post-Instagram world and it’s still a hard time to raise a Series B unless you’re a firm like Pinterest.

During the first quarter of the year VCs invested $5.8 billion in 758 deals, a 19 percent decrease in dollars from the previous quarter and a 15 percent decrease in deals. This isn’t unexpected as the industry has also seen its ability to raise funding from its investors drop after the financial crisis in 2008 and 2009, and because the first quarter is historically the weakest one for VCs. The VC industry moves in five-to-seven-year cycles, so anticipated trends from even a few years back can take a while to be felt, and then they can change on a dime. Or a deal.

But this trend won’t be felt for long, and there’s one huge reason why: Instagram. The sale of that photo-sharing site to Facebook for $1 billion in funny money and cash caused every single venture firm to sit up and take notice. And behind Instagram are several successful exits with LinkedIn, Yelp, Zynga and Splunk going public.

Facebook has filed to raise capital on the public markets and that should lead to more interest in the asset class, plus it will also have the stock to do crazy inflated deals such as Instagram. Zynga’s assertion this week that it planned to make more acquisitions is only the start of an all-out race to the top to be the king of the consumer web. So entrepreneurs can expect more opportunities to raise capital and the anticipated shrinking of the industry won’t last long.

On the funding side, the dollars flowing into seed and Series A deals also dropped to 45 percent of total deal volume, while the average size of such deals increased to $2.7 million. Again, this doesn’t reflect the change in the market post-Instagram and as VCs start doing deals again in the second quarter. In fact, it’s getting frothy out there with some startups commanding crazy post-round valuations of up to $7 million after taking on a Series A/seed round of $1.5 or $2 million.

In January I pointed out that the trends in early stage funding indicated that the Series B rounds were when entrepreneurs were feeling squeezed. VCs were willing to toss money at any deal in the early stages as a way of claiming their territory. However, if those investments didn’t show significant traction, revenue or product development, they weren’t getting their Series B dollars. Venture firms want a Pinterest by the second round, so entrepreneurs should use their Series A rounds prudently.

The hunt for whales at the Series B level concerns Chris Dixon, a co-founder of Hunch who wrote last week:

The problem with this model of Series A and B investing is that, in reality, many of the companies with big hits weren’t overnight successes. Pinterest, OMGPOP, Twitter, and Tumblr were around for years before taking off and all benefited greatly from having patient investors. In the current financing environment, a lot of good companies won’t live to get Series As and Bs and big VCs will pay valuations on hits that are priced to perfection.

The question that remains to be seen is if the Internet has crossed over so totally into a consumer-market story that venture success and returns drop to reflect the crazy competition that’s endemic in the consumer marketplace. A home run is only a home run if your returns are high, and paying too much to get into the round can give a venture firm a publicity win, but less of a monetary one.

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