Google to end 'Double Irish, Dutch sandwich' tax scheme - Reuters

Google to end 'Double Irish, Dutch sandwich' tax scheme - Reuters


Google to end 'Double Irish, Dutch sandwich' tax scheme - Reuters

Posted: 31 Dec 2019 06:51 AM PST

AMSTERDAM (Reuters) - Google parent Alphabet (GOOGL.O) will no longer use an intellectual property licensing scheme, known as the "Double Irish, Dutch sandwich", which allowed it to delay paying U.S. taxes, 2018 tax filings show.

FILE PHOTO: The logo of Google is seen at the high profile startups and high tech leaders gathering, Viva Tech,in Paris, France May 16, 2019. REUTERS/Charles Platiau/File Photo

A Google spokesman on Tuesday confirmed it would scrap the licensing structure, saying this was in line with international rules and followed changes to U.S. tax law in 2017.

Dutch filings, which were seen by Reuters, showed that in 2018 Google moved 21.8 billion euros ($24.5 billion) through its Dutch holding company to Bermuda, up from 19.9 billion in 2017. Google said it would end the practice after 2019.

"A date of termination of the Company's licensing activities has not yet been confirmed by senior leadership, however management expects that this termination will take place as of 31 December 2019 or during 2020," the Dutch filing said.

"Consequently, the Company's turnover and associated expense base generated from licensing activities will discontinue as of this date," the filing with the Dutch Chamber of Commerce added.

Google, like other multinationals that make use of international tax minimization strategies, has always said it pays all its taxes.

"We're now simplifying our corporate structure and will license our IP (intellectual property) from the US, not Bermuda," a spokesman said in a statement.

"Including all annual and one-time income taxes over the past ten years, our global effective tax rate has been over 23%, with more than 80% of that tax due in the US."

For more than a decade, Dutch, Irish and U.S. tax law allowed Google to enjoy an effective tax rate in the single digits on its non-U.S. profits, around a quarter the average tax rate in its overseas markets.

The subsidiary in the Netherlands was used to shift revenue from royalties earned outside the United States to Google Ireland Holdings, an affiliate based in Bermuda, where companies pay no income tax.

The tax strategy was legal and allowed Google to avoid triggering U.S. income taxes or European withholding taxes on the funds, which represent the bulk of its overseas profits.

Under pressure from the European Union and the United States, Ireland in 2014 decided to phase out the arrangement, ending Google's Irish tax advantages in 2020.

The Trump administration's Tax Cuts and Jobs Act, which came into effect in January 2018, ended the reason for U.S. companies to hoard foreign profits offshore. Now profits that have been made and taxed abroad are not subject to taxation when returned to the U.S.

In the Bermuda filing for 2018, Bermuda-based "Google Ireland Holdings Unlimited Co." said in the future it would no longer continue licensing intellectual property or holding debt securities, but it would continue equity investment operations.

($1 = 0.8913 euros)

Reporting by Toby Sterling; editing by David Evans and Alexander Smith

Huawei's 4 big issues in 2020 — from the blacklist to the decision over its operating system's future - CNBC

Posted: 30 Dec 2019 04:40 PM PST

A Huawei logo is displayed at a retail store in Beijing, China on May 27, 2019.

Fred Dufour | AFP | Getty Images

It's been a tumultuous year for Huawei.

On one hand, the Chinese technology giant has faced continued pressure from the U.S. which has accused Huawei of being a national security risk, and led to its blacklisting by Washington. On the other hand, the company has continued to increase revenue and strike deals to be part of next-generation mobile internet infrastructure known as 5G.

For 2019, Huawei said its estimated sales revenue will top 850 billion yuan ($121.66 billion), up about 18% on-year but still lower than the company's initial projections.

Heading into 2020, Huawei will face a number of big challenges.

Potential block from more markets

While Huawei has signed a number of 5G commercial contracts, there are still some significant markets that have not yet decided on whether to let the Chinese giant into their next-generation mobile networks.

While Australia and Japan have effectively blocked Huawei from their 5G networks, some countries are still undecided. Germany and the U.K., seen as crucial markets for Huawei, have yet to make a decision.

Any ban from either of those countries will be closely watched to see if other major markets follow suit.

President Donald Trump has reportedly been pressuring allied countries to ban Huawei from their 5G networks. Washington maintains that Huawei is a national security risk because its equipment could be used for espionage by the Chinese government. Huawei has repeatedly denied those allegations.

The blacklist

Earlier this year, Huawei was put on a U.S. government blacklist, known as the Entity List. This prohibits U.S. companies from doing business with Huawei without a special license. Huawei relies heavily on American software and components.

Some U.S. companies however have continued to sell to Huawei, utilizing a loophole in the regulations. Bloomberg reported this month that the U.S. government was considering tightening the rules.

Over the past few years, Huawei has been diversifying its supply chain and focusing on in-house design of key components like chips. But the Entity List has hurt Huawei in one key area — smartphones.

The company released its flagship Mate 30 smartphone in September without a licensed version of Google's Android mobile operating system. That means users buying the new phone do not have Google apps pre-installed.

While globally, particularly in China, Huawei's smartphone shipments are growing, it saw a decline in the second quarter and no growth in the third quarter.

Google Android is not that important for Huawei in China because the U.S. firm's services — such as Gmail and search — are blocked there anyway. However, it's very important for international markets with users who rely on many of Google's apps.

For its part, Huawei said it expects to remain on the U.S. blacklist in 2020.

"We won't grow as rapidly as we did in the first half of 2019, growth that continued throughout the year owing to sheer momentum in the market," said Huawei's rotating Chairman Eric Xu in a statement on Tuesday.

"It's going to be a difficult year for us," Xu said about 2020, adding, "Survival will be our first priority."

Huawei's operating system

In August, Huawei introduced its own operating system called HarmonyOS. It touted the operating system as one that could be used across various devices from TVs to smartphones.

At that time, Richard Yu, the head of Huawei's consumer division, said the company could "immediately" switch to HarmonyOS from Android if it was permanently blocked from using Google's software. But so far, the company has indicated it will not use HarmonyOS on its smartphones.

All eyes will be on what Huawei does with HarmonyOS as it continues to launch new devices.

CFO on trial

Huawei's Chief Financial Officer Meng Wanzhou was arrested in Canada in December 2018 at the behest of the U.S. authorities.

The U.S. is seeking the extradition of Meng, who is also the daughter of Huawei founder Ren Zhengfei. The American government alleges that Meng committed bank fraud in relation to skirting U.S. sanctions on Iran. Meng has denied the allegations.

Her legal team has sought to get the case thrown out, and the hearings will continue into 2020.

— CNBC's Saheli Roy Choudhury contributed to this report. 

Google's top trends of the decade - WCBI

Posted: 31 Dec 2019 02:20 PM PST

Each year, Google rounds up the year in search trends and reveals the fastest-rising search terms people Googled that year. This year's list is topped by searches for Disney+, followed by late Disney star Cameron Boyce, late rapper Nipsey Hussle, Hurricane Dorian, and the former NFL player Antonio Brown. Here's a look at the top search terms on Google for every year of the past decade — some of them may surprise you.

2019: Disney+

As the streaming wars raged on this year, Google users were most curious about newcomer Disney+. After months of speculation, Disney+ finally launched in November, giving subscribers access to old Disney Channel shows, classic animated movies, newly-acquired properties like Marvel and Star Wars, original content and more.

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The highest-rising news event search in the U.S. in 2019 was Hurricane Dorian, which battered the Bahamas as a Category 5 in September. The most-searched person was Antonio Brown, the most-searched actor was Jussie Smollett and the most-searched baby was, of course, Baby Yoda.

Disney+ was the fastest rising search term in the U.S. this year, according to Google. "Baby Yoda," who took the world by storm after appearing in the original Disney+ series "The Mandalorian," was the most-searched baby. Disney/Getty

2018: World Cup

With soccer being one of the most popular sports in the world, it's no wonder "World Cup" is often on Google's most-searched list during tournament years. Last year, France defeated Croatia 4-2 in the World Cup final.

The World Cup was also Google's top news event in the U.S. last year, followed by Hurricane Florence.

France v Croatia - 2018 FIFA World Cup Russia Final
Kylian Mbappe of France celebrates with teammates after scoring his team's fourth goal during the 2018 FIFA World Cup Final between France and Croatia at Luzhniki Stadium on July 15, 2018 in Moscow, Russia. Catherine Ivill / Getty Images

2017: Hurricane Irma

Several islands in the Caribbean were reduced to rubble when Hurricane Irma tore through the region in September 2017. The powerful storm also caused widespread damage across Florida.

That year saw several unusually destructive hurricanes, including Hurricane Harvey, which hit Houston, and Hurricane Maria, which devastated Puerto Rico.

052318-irma.jpg GOES weather satellites provide the hemispheric views familiar from nightly newscasts and also dramatic close-up looks at storms like Hurricane Irma, seen here, as it approached Puerto Rico in 2017. NOAA

2016: Powerball

The year in search got a bit of a curveball in 2016 — actually, it was a Powerball. The term skyrocketed in U.S. Google searches that year after the jackpot topped $1 billion.

Prince was the second highest trending search term of 2016, after the singer died suddenly at the age of 57 inside his Minnesota compound, Paisley Park.

2016 was also an Olympic year, and the Summer Games in Rio were the top news event searched in the United States.

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The more than $1 billion Powerball, Prince's death and the Summer Olympics in Rio were some of the stories that rocked the U.S. in 2016. Getty

2015: Lamar Odom

In 2015, the fastest-rising search term was a person, Lamar Odom. The NBA player joined a reality TV dynasty when he married Khloe Kardashian in 2009. By 2015, Odom and Kardashian were going through a divorce. That year, he was found unconscious in a Nevada brothel, suffering an apparent drug overdose. Kardashian and her family were by Odom's side during his recovery and she dismissed the divorce filing until he recovered.

Another Kardashian-Jenner family member made headlines that year. Also on the list of top Google search terms was Caitlyn Jenner, formerly Bruce Jenner, who introduced herself to the world as Caitlyn for the first time on the cover of Vanity Fair. Jenner had come out as transgender earlier that year and began to publicly transition from man to woman.

untitled-collage-24.jpg
Lamar Odom was both the highest-trending search term and the most-searched person in 2015. Caitlyn Jenner was the second-most searched person. Getty/Vanity Fair

2014: Robin Williams

2014 saw the loss of Robin Williams, who died by suicide in August. The actor was the fastest rising search term in the U.S. that year.

Williams first rose to fame from the stand-up comedy circuit in the 1970s, with a manic improvisational style all his own. He went on to become an Academy Award winner and three-time Golden Globe winner.

This was also a World Cup year, and that term was second on Google's list, followed by Ebola, as an outbreak of the deadly virus sickened thousands; Malaysia Airlines, after Flight 370 mysteriously vanished somewhere over the Pacific; and the viral video game Flappy Bird.

robin-willilams.jpg
Robin Williams died at age 57 in August 2014. He was the top trending search in Google that year.

2013: Paul Walker

Actor Paul Walker, who was best known for his role as Brian O'Conner in the "Fast and Furious" films, was killed in a car crash north of Los Angeles in November 2013 at the age of 40. Walker's name topped Google's list of search terms in the U.S. that year, according to several news outlets that reported on the list at the time.

The former anti-Apartheid leader and president of South Africa, Nelson Mandela, who also died in 2013, topped Google's global list.

32-franchise-fast.jpg
Paul Walker, who is known for his role in the "Fast and the Furious" film series, died in a car crash in 2013.

2012: Whitney Houston

Singer Whitney Houston passed away at the age of 48 in 2012, and topped Google's list for searches that year. Houston ruled as pop music's queen until her majestic voice and regal image were ravaged by drug use, erratic behavior and a tumultuous marriage to singer Bobby Brown.

The singer's cause of death was determined to be drowning along with "effects of atherosclerotic heart disease and cocaine use." She left behind one daughter, Bobbi Kristina Brown, who died just a few years later in 2016.

whitneycover.jpg
Whitney Houston performs on October 3, 2009 in Freiburg, southern Germany.  JOERG KOCH/AFP/Getty Images

2011: Rebecca Black

In the early part of the decade,13-year-old Rebecca Black became a music sensation in what was then a whole new way. The teen released a music video for her song "Friday" on YouTube and it took the world by storm. The repetitive tune went viral and became an ear worm stuck in the heads of millions of people.

Now, the song has 138 million views on YouTube, so it's not wonder that at the peak of her popularity, Black became Google's fastest-rising search term in the U.S.

Also in 2011, Americans were engrossed in the trial of Casey Anthony, a Florida mother charged in the 2008 death of her 2-year-old daughter, Caylee. After deliberating for more than 10 hours, a jury found Anthony not guilty of first-degree murder, a verdict that shocked millions of people. The whole drama made Anthony one of the most-searched people on Google that year.

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Singer Rebecca Black in 2011. Ethan Miller

2010: iPad

The iPad, which was released by Apple in 2010, was Google's fasted rising search query that year. Also new on the scene was Justin Bieber, who released his first studio album in 2010 and was the highest-trending person on Google's list.

untitled-collage-25.jpg
People were falling in love with Apple and catching Bieber Fever in 2010. iPad and Justin Bieber were Google's fastest-rising search terms that year.

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