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Cake day: October 29th, 2024

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  • On one hand I agree with you. This won’t only impact the US. Perhaps we’ll get hit harder than the Americans (at least some parts of the world).

    On the other hand I would argue the rest of the world is much more connected on a visceral level. The Americans have their feet and legs, when the world uses meters and centigrade. American prices are always provided on a list basis (and local oligarchs and their shills constantly lie that modern software solutions can’t apply local tax adjustment algorithms on a dynamic basis), the rest of the world has true prices (only in English would one have to clarify what you mean by true prices).

    I am not saying that only Americans will get fucked, but the rest of the world has a measure of dynamism that Americans don’t (not to mention a much higher tolerance to challenges).

    Perhaps there are some long terms benefits to Trump’s behaviour. We can find alternative to American-style corruption and degeneracy. While there are many sane Americans, they also need to take a more sober attitude to their current situation and be willing to take risks and be less arrogant about “home of the brave” and similar polemics.


  • I hate the CCP, with the number one reason being that they support the russians (I am Ukrainian).

    That being said I also oppose their imperialism, authoritarianism and social conservatism.

    But I find myself considering whether China is perhaps (as a matter of a lack of choices) a better option than the US. It genuinely pains me to say this.

    I empathize with the population of Taiwan. I remember Jan 2022 and Dec 2021 when everyone in Ukraine was contemplating the potential (for that time) for a full scale russian invasion. And then the full scale invasion happened in late Feb 2022.

    But the Americans leave me no option. One third of their population are deeply corrupt and dishonest, they are proto-fascist, if not outright fascist. On some level it is worth considering whether they are a “lost cause”. Another third might not be openly fascist, but they will support any evil (if it doesn’t immediately impact them directly) for a discount coupon at the local McDonalds. They are the textbook definition of nihilists.

    And then you have the final third part of the population. They know something is wrong, but they are too conformist and lack the risk tolerance to make a move. For better or for worse they are too well off (in the global sense) to be willing to take risks. American fascists will take them down one by one, until there is no leadership left.


  • The moves offer a new challenge to the Trump administration, which had previously cited lowering Treasury yields as a key policy aim, and could mark a loss of investor confidence in the world’s largest sovereign debt market.

    “The sell-off may be signalling a regime shift whereby US Treasuries are no longer the global fixed-income safe haven,” said Ben Wiltshire, a rates strategist at Citi.

    This is potentially a seismic shift in global finance/economics.

    If US treasuries are no longer considered the “investment of last resort” (which they shouldn’t be, since even sane Americans lack the commitment and risk tolerance to fight corruption and degeneracy in their own country), this may result in the dollar losing its status as the global reserve currency.

    If that happens, the Americans will be fucked.


  • Let’s go with what you are saying, even though you didn’t address a single point that I mentioned. Define what you mean by “rule of law”, be clear and specific, don’t hide behind polemics! What is your definition of rule of law? You brought it up, define it. I never acted high and mighty and brought up “rule of law”. I said the Americans need a taste of their medicine.

    Back to your example.

    You have 3 polish companies that interact with a US corp. One is the actual subsidiary and two other are clients.

    You’re saying you can audit ABC, but you can’t figure out which one is the subsidiary and which ones are clients? Are you serious? I have zero professional experience in accounting and even I would be able to tell the difference between a client and subsidiary if I had access to their internal accounts (P&L, balance sheet, cash flow statement over multiple quarters).

    I am not an expert on tax scamming methods, but I would argue I may have more knowledge than the average person (or not).

    Why would Corp D even use the model you describe? Why would they try and hide within Polish ABC? Why not just openly say C is our subsidiary, make it a cost centre and redirect the actual money to Company E in Luxembourg or Isle of Mann. Subsidiary C always fails to make any profit. Top American brand D that everyone in the world knows, has a poor subsidiary C in Poland that is never able to make a profit. The crocodiles are crying about poor Polish subsidiary C. You ask a crocodile about subsidiary C and the crocodile says “it is such a gross oversimplification that subsidiary C’s losses are a tax scam. We are trying to develop professional experience in Poland via subsidiary C. Don’t you believe in the rule of law?”

    You have no way of verifying it.

    This is where your lack of imagination and inability to think beyond rules set by American oligarchs comes into play.

    Let’s say we made a thought experiment and assumed your ABC model is viable (it is not viable because the profits will be re-directed to a tax shelter jurisdiction and Company D won’t bother with local-only schemes because they are not efficient). Nevertheless, you do have a way of verifying the total sales by company D in Poland. This applies to both B2C (shipments into channel, POS data) and B2B sales (VAT calculations, government stats agency research).

    What you are arguing is nothing can change, nothing should change and we should always kiss the feet of the oligarchs that run company D.

    I am saying the arguments by the army of lawyers are bullshit and if you really want to, you can make their jobs redundant. It’s all about gumption and willingness to rock the boat.



  • I want my government to work within the rules. I don’t want my government to be able to tax people on "strongly hold opinion"s and "everybody knows"es.

    How is it a strongly held opinion and “everyone knows”? Various tax avoidance schemes are extremely well documented both in general media reporting, NGO reporting and even academia. Are you saying that even something as simple as the wikipedia article on the Dutch Sandwich was just made up on the spot? Did the Wikipedia editors find a local hardcore alcoholic that is known for making up crazy stories and decided to document one of his claimed escapades where he got wasted with a recently divorced senior financial accounting executive who told him about the dutch sandwich?

    You say “rule of law” is relevant to you. What does this mean? Can you define this specifically.

    You are acting somewhat high and mighty on this topic (just a little bit, although I will admit such a rhetorical approach is fair considering the topic), but on what basis should one take your alleged commitment to “rule of law” at face value?

    What you are saying is that we must tolerate corporate criminality no matter what. We are not allowed to challenge their methods and any and all information on corporate tax avoidance is inherently hearsay.

    I will admit I am being a little bit hyperbolic, but how else should once interpret "strongly hold opinion"s and "everybody knows"es?

    Everytime someone say “the should just…” it’s a gross oversimplification that present reality where solution is obvious and everyone not implementing it gave bad will or lack competency or gut.

    What’s the gross oversimplification? Perhaps the gross oversimplification is your "strongly hold opinion"s and "everybody knows"es? Have you thought about that?


  • I would argue “rule of law” is not relevant to American oligarchs. There is no difference between say a russian oligarch and an American oligarch with the exception that American oligarchs have a stronger preference for theatrics/PR and copytext that references terms like “freedom” and “rule of law” and “personal responsibility”. Russian oligarchs just don’t bother because paradoxically they are more honest than American oligarchs.

    It’s not a matter of knowing how much they REALLY earned. It’s about telling them that they will pay this much and if they don’t, they are welcome to go along with lawsuits or whatever they feel like.

    They can make a statement in the UN about discrimination against the most discriminated group in the world; freedom loving American billionaires. Tell them they can get Ariana Grande, Taylor Swift and Snoop Dog to perform a modern supergroup track as a legacy to the 40th year anniversary of We are the World called “We are Silicon Valley” (or “We are Wall Street”).

    Just warn them that if “We are Silicon Valley” doesn’t change the course of human history (let alone become #1 in every single country in the world), things might not work out for them as they would like.




  • See, you’re still thinking on their terms. It’s a fundamentally a reactive approach. You let American oligarchs (and their supporters among the American population) define the rules of the game. I will note that I agree with you that you’ll never beat their army of lawyers (on their own terms).

    I am saying develop and implement approaches where the lawyers don’t matter. You tell the US oligarchs that they must pay X billion additional tariff fees based on data that identifies their commercial activity in Europe (I worked in tech market research at one point and there are reliable private data sources that allow you to make relatively accurate estimates around US company sales in Europe; irrespective of legal structure).

    You tell them that they are welcome to say no and you’d happy for them to engage in lawsuits or bawsuits or do whatever they want. But you warn them that they might not like the outcome.

    When they do say “no!” you go all in and de facto ban all American IT services and shut down their business in Europe.

    Now I am not saying this has to be done immediately (or done at all). You can initially try and work with them for a long time, but all throughout this process you keep a full menu of options open, including de facto seizing their assets and implementing a blanket ban (either explicit or a fee structure that makes their business non-viable) on all American IT services.

    I am just saying that we need to expand our horizon of capabilities beyond the rules set by Americans. It stupid to come to a gun fight with boxing gloves.


  • As I said, no disrespect to sane Americans.

    I’ve lived in the US and travelled extensively around the country (not only Manhattan and north-western part of LA), there are many sane Americans even in provincial pro-corruption hotspots.

    But until the sane Americans implement true anti-corruption, judicial and election reforms (no Obama style “hope and change” bullshit), it is reasonable to expect nothing good to come out of the US. Even if a hypothetical Michelle Obama administration takes power in the next election (which is a giant if), that’s not going to change anything until the Americans stop treating their oligarchs and criminal groups as sacred cows.


  • I definitely agree, I work in the industry so I have no childish illusions about how painful this would be.

    That being said, it is not completely out of the realm of reality. China still uses Windows/Android/iOS, but they have their own cloud providers and they are making massive inroads with respect to semiconductors and homegrown components. And they are working on getting rid of American operating syste6m and I think in ~10 years they will succeed.

    At some point you need to make a call around whether using American tech is in your interests. Moving off American tech will never be easy, the question is when and how you do it and how you manage the pain.

    And mark my words, the Americans are only going to get even volatile and chauvinistic. Unfortunately, the sane Americans lack risk-tolerance and motivation (they are in a broad sense too well off to care if their country moves from current early proto-fascism to full on facism).



  • I recognize that this is not exactly a reasonable approach.

    But sometimes (when the situation is dire and you’re dealing with unreasonable, profoundly corrupt individuals that lack humanity) you need to take an active (not reactive) approach.

    Literally just say “You made $20B (revenue) in Europe as per your 10-K, you will pay $4B and we don’t care what you have to say because we both know you are dishonest and corrupt. Lying is not going to work!”

    I am not saying that now is the time to use such measures. But to completely deny any active postures and solely leverage a reactive approach does not work.