Cool logic... the money you have in your savings account that you haven't touched for two years should be given to charity. Thank you for your donation.
Elaboration time... I did this in the UK, similar likely applies in the states.
I used to be an 'independent contractor'. I work for companies doing ecommerce / Java / Consulting work. I work a fixed term contract and leave when the project is complete.
I set up a limited liability company with me as the director and the only employee. When I get a contract (work), the client hires my company rather than hiring me directly. Depending on your specific tax laws, you pay a lot less tax using this kind of setup i.e. you pay yourself a low salary and the rest in (low tax) dividends.
This is the standard way most IT contractors operate.
There is another trick not mentioned here. If you live outside US and have an LLC with only one person you don't pay taxes in US. This works assuming your work is done outside US.
So, say you live in a very relaxed tax environment, you can incorporate your LLC, sell software services to US companies and pay small taxes in your country.
It's not a CFC. He's described an NRA residing in a foreign country selling software to US customers from a location outside the US. This is foreign-source income that is generally not taxed in the US unless you have citizenship or tax residency (i.e., a green card, or a company that is incorporated or physically does business in the U.S.).
In fact, what he's described works even better without the LLC, as the organizing an LLC in a state gives that state jurisdiction to tax sales to customers in that state! (State tax laws work differently than federal tax laws and are generally not affected by tax treaties.)
NAME_OF_COMPANY LLC is a single member LLC, and as such disregarded for federal tax purposes as a separate entity from its owner, FULLNAME, a resident of COUNTRY and a nonresident alien for US tax purposes. According to Section 1.1441-1 of Treasury Regulations (page 3 of the attachment) , payments made to a whole owned domestic entity that is disregarded for federal tax purposes and whose single owner is a foreign person, shall be treated as payments made to the owner of the entity. This means that payments made to NAME_OF_COMPANY LLC for federal tax purposes are considered to have been made to FULLNAME. The Regs go on to explain that the single owner of the US disregarded entity must furnish a From W-8 with his name and address to the US payor . An ITIN is required only to claim a reduced rate of withholding under treaty, but since in this case the payments were made for income from sources WITHOUT the United States, no withholding is required to begin with, so there is no need to claim any treaty benefits at all and provide an ITIN as a result.
If you want I can contact you with an specific accountant and you can discuss the details with her.
Are you talking about a non citizen doing this, or a citizen/permanent resident?
A noncitizen actually can use the USA as a tax haven in ways similar to this (I'm not sure of the specifics of this particular situation). IMO there isn't a whole lot special about non US people not owning US taxes when outside the US.
A US citizen or permanent resident is taxed on global income (you do get around your first 95k/yr deducted if you are out of the country enough, which is why I went diving for 4 months at the end of a contract and net made more money than returning to the US that year). A corporate entity being treated as disregarded just exposes that income the us person's global us tax liability.
(Again, I am absolutely not a lawyer; this is not tax advice)
Noting that if you're expecting to lose money on the business initially, I believe you can't write that off on your personal taxes if you're not taxed as a partnership. I think it is common to have an LLC taxed as a partnership initially and switch to being taxed as a corporation (which you can do I think within the first few months of each year) after it becomes profitable.
It's common to have cameras mounted to record you typing your PIN along with skimming your card. It's good practice to cover the pad with your other hand.
I have never put this card in an ATM. It must have been skimmed from a swipe machine in a restaurant.
I still don't know how they got my pin. I can't imagine anyone looking at my pin in a restaurant. It seems like such a hard and non-scalable way to do this kind of thing.
I think that a pinpad is not that hard to hack. OTOH whenever I read about skimmers getting caught, they seem to use really low tech methods - keen eye, perhaps aided with a mirror or a small camera.
What does 'fix deployed' mean? How do you actually update pacemaker software? Are you going to wait for 100% of the deployed pacemakers are fixed? What is an acceptable fix rate before you release the exploit?
Pacemaker firmware can almost always be updated using inductive or rf telemetry. In most cases it still requires an appointment with a cardiologist or similar physician though.
And many can now be monitored by the cardiologist from their office as the device uploads data to a server, or can even be reached directly from the physician's console. And both cardiologists and pacemaker companies generally have a pretty good bead on who's walking around with which serial numbered device.
I think you should assume people will reverse engineer patches as soon as they are public. People should treat this like any urgent medical care and address it within hours or days of the patch being available. I don't know much about that area of the industry, but I don't envy it at all. Imagining being the person responsible for a) enabling remote communication, b) allowing updates via remote communication, and c) securing it. What a nightmare situation.
If a large enough majority of people get their pacemakers fixed, it greatly lowers the chances that you'll encounter someone with a defective pacemaker that you can exploit.
I work with a very well known Java and Spring based ecommerce platform. I find that people new to the platform, regardless of Java and Spring experience, take a while to produce really good design and code.
You might know the frameworks and languages but sometimes you need experience in the specific platform.
I work in consultancy so I rarely have time to up skill someone into the platform.
That sounds like the platform is relatively complex.
I've seen Java/JavaEE/Spring code where it was easy to get started, since the platform was built as simple as possible. I've also seen Big Balls of Mud where a developer needed months to be somewhat productive. So the question shouldn't be: "Is my platform brown?" But rather: "Have you ever worked on a freaking castle with hundreds of secret passages?".
Sometimes complexity is unavoidable. The interviewer may ask a question like: "What are your experiences with complex code/legacy code?" (If the interviewer is able to accept the reality of course)
I wouldn't say that was brown exactly, but I know exactly what you mean with big ecommerce platforms and all kinds of other vertical-market software. It can take months or even years to learn all of the tricks.
That being said, it is always a gamble. A great programmer might pay off in the long run more than a mediocre programmer who already knows the platform... or not!
My point still stands. How do you know that I didn't hire you because I hate gays but I tell everyone I didn't hire you because of that one Java question you got wrong. It's very very hard to prove and can be expensive to take to take to court.
People like you with your rosy view of the world make it hard for people with real problems to get by.
No really, The IRS will use something like Red Hat and the Red Hat Corporation will be providing a level of guarantee which the IRS can fall back on should they need to.
If they just pull patches from the community themselves, when something goes wrong they will have to take the blame themselves and people will think they are foolish being so reckless. As a techie, this option may seem feasible to you but then again you're just some random guy on HN who probably thinks node.js is the be all and end all of IT. I doubt you've got the intelligence (cleary) or the experience (very cleary) to understand how the IT industry works at a human, risk management and legal level.
It's funny how you talk about me without knowing me. You don't even made a background check to see if I adjust to your node.js bias.
No, my company sells hard core technology to big vendors and sign the kind of corporate contracts that you refer in your comment. Since the IRS will not solve the issue there is another route: selling a hotpatch service to another vendor who sells to the IRS.
Something tells me you did not understand the above comment... He's saying the IRS could shift responsibility based on the fact they paid the worlds biggest software vendor 11mil... Switching to Linux puts the responsibility back in the IRS's court...
Most people on here will push you towards the over-saturated market of JavaScript (insert framework of the week here). Personally, I would get to grips with something with a less hispter vibe that is oversaturated with devs taking low pay.
Learn Java, learn the Spring framework, learn Tomcat. These enterprise standard java based technologies will set you up for a solid and well paid career.
Java has many many more jobs than there are good developers. The three buzz word frameworks will stick you in smaller projects that will ultimately pay less. Don't get sucked into the hype.
If you want to see big projects where you will be able to accelerate your career, I would definitely be looking towards the enterprise and consultancy space.
