And so it is that I’ve moved on to a different job with my long-time employer. No longer will I have to study reams of flowcharts that describe how payables are processed; no longer will I have to delineate the reasons why gross income and interest expense vary from the annual budget. Leave that to people with sharper eyesight and the willingness and expertise to plow through dozens of journal entries and unearth the details behind the lines on the financial statements.
Instead I will ponder whether a lease into a foreign jurisdiction triggers local taxes by creating a deemed permanent establishment. Perhaps a loan structure or asset-value guarantee will solve the problem; that depends on what the tax treaty says. (My employer pays me a decent wage to be conversant with what sounds to some like gobbledy-gook, but after a while the subject matter grows on you.) Well, we’ll soon see whether the transplant takes or whether it’s all just a bunch of fertilizer. © 2006 Stephen Yuen
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