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发帖数: 7021 | 1 【 以下文字转载自 USANews 讨论区 】
发信人: Daos (刀丝斋), 信区: USANews
标 题: 看看沃伦·巴菲特的纤巧的税收漏洞 - 巴伦周刊zz
发信站: BBS 未名空间站 (Mon Oct 3 11:10:41 2016, 美东)
有人无知,说巴菲特不享受税务优惠。看看沃伦·巴菲特的纤巧的税收漏洞 - 巴伦周刊
Warren Buffett's Nifty Tax Loophole - Barron's
http://www.barrons.com/articles/warren-buffetts-nifty-tax-loophole-1428726092
(If you google Warren Buffett's Nifty Tax Loophole - Barron's, you will be
able to read it. If you click the link, it seems to ask you to subscribe.
Let me copy and paste it here for your reference.)
巴菲特支持较高的单独税率，同时确保他的巨额财富在伯克希尔哈撒韦公司几乎是免税
的。他的公司从来没有在合法不交税时交过税。关于纳税问题，请见我的评论。
OTHER VOICES
Warren Buffett's Nifty Tax Loophole
Warren Buffett has backed higher individual tax rates–while ensuring that
his vast wealth in Berkshire Hathaway is almost immune.
By
MORRIS PROPP
April 11, 2015 12:21 a.m. ET
Warren Buffett is fond of saying his tax rate is lower than his secretary’s
. He does not publicize his tax returns, but for the tax year 2010, he paid
$6.9 million on taxable income of $39.8 million, according to partial
disclosures he made in 2011.
What is astounding about those numbers is not the 17.3% tax rate, but that
Buffett’s $39.8 million of taxable income is only about 0.05% of his
reported net worth ($71 billion according to Forbes, which put him third on
its list of the 400 wealthiest people in the world for 2015).
Proportionately, that’s like someone with an ever-expanding net worth,
currently $10 million, reporting taxable income of only $5,000 and paying a
federal tax bill of only $900.
So, how does he do it? Buffett’s principal holding is an economic interest
of about 20% of Berkshire Hathaway, the huge conglomerate he has been
building since the 1960s. It has a market value of about $350 billion.
Berkshire hasn’t paid any cash dividends since 1967. Rather, the company
accumulates its prodigious after-tax income ($19.9 billion in 2014) and cash
flow ($32 billion in 2014) to get bigger by buying companies, lots of
companies. Among its large recent acquisitions were Lubrizol, Burlington
Northern Santa Fe, and a shared acquisition of H.J. Heinz.
The Berkshire Model is to buy companies rich in cash flow with histories of
paying dividends, then cancel those dividends and retain the cash flow going
forward for future acquisitions.
HOW MUCH TAX is Warren Buffett able to avoid by fixing Berkshire’s dividend
at zero? The dividend yield of the Standard & Poor’s 500 is about 2%. The
price/earnings ratio of the S&P 500 is about 18. Thus, for the S&P 500,
approximately 30% of earnings are paid out to shareholders. These dividends
are taxable at a current maximum rate of 23.8%.
Enlarge Image
Illustration: Dan Picasso for Barron's
If Berkshire followed the average of the S&P 500, it would have paid out
about $6 billion in dividends in 2014, and Buffett’s share would have been
about $1.2 billion.
At a 23.8% tax rate, that would have given Buffett a tax bill of $280
million, or about 40 times the taxes he said he actually paid in 2010.
Thus the Treasury has been getting exiguous tax revenue from one of its
wealthiest citizens. Buffett is virtually immune to higher individual income
-tax rates, while he promotes higher rates for other rich people, who may
have a net worth a hundredth of 1% (0.01%) of his own.
Since, according to his publicly stated plans, Buffett intends to leave the
bulk of his estate to charity, his estate won’t be paying much tax, either.
The Buffett Loophole and the Berkshire Model are allowing one individual to
build one of the great American fortunes while avoiding individual taxes.
Talk about someone not paying his share!
FOR 2014, BERKSHIRE ITSELF recorded a provision for $7.9 billion in taxes,
most of which was “deferred.” In fact Berkshire, like many other companies
, is able to defer much of its taxes, in its case $61 billion. This is money
it acknowledges it owes the government but has yet to pay.
Deferred tax liabilities are the difference between taxes that will come due
in the future and what the company owes today. Accounting rules require
this difference to be recognized as a liability, but it ultimately acts as a
sort of “float” that the government allows companies in the midst of an
acquisition—which Berkshire almost always is.
In 2012, the year before it was acquired for $28 billion by Berkshire (and a
Brazilian partner), H.J. Heinz paid more than $600 million in dividends.
Those dividends were taxed and provided revenue to the U.S. Treasury. After
the acquisition, the dividends stopped. Tax revenue from those dividends
stopped.
In 2010, the year before it was acquired by Berkshire for $9 billion,
Lubrizol paid $90 million in dividends. After the acquisition, the dividends
stopped, as did tax revenue on the dividends.
In 2009, the year before it was acquired by Berkshire for $44 billion,
Burlington Northern Santa Fe paid $546 million in dividends. After the
acquisition, the dividends stopped, as did tax revenue on the dividends.
LAST YEAR, Berkshire entered into what became known as a “cash-rich split-
off” that, according to the New York Times, might have allowed it to avoid
$1 billion in taxes. Berkshire traded its stock in Procter & Gamble, which
carried a low cost basis of $336 million, for P&G’s Duracell unit plus $1.7
billion in cash, a total value of $4.7 billion. The point was to reduce
capital-gains taxes that would have been due on a sale of Berkshire’s P&G
stock.
It seems that Buffett and his businesses are serial deprivers of tax revenue
to the U.S. Treasury. Yet that does not deter him from loudly advocating
higher income tax rates for others.
However unethical the Buffett Loophole and the Berkshire Model may seem,
however much they may appear to be gaming the tax code, no one has claimed
they are illegal.
Now consider Section 531 of the Internal Revenue Code, which imposes a 20%
tax on the accumulated but undistributed income of a corporation. And
Section 532 of the Code states that the tax shall apply to “every
corporation…availed of for the purpose of avoiding of the income tax with
respect to its shareholders…by permitting earnings and profits to
accumulate instead of being divided or distributed.”
The Buffett Loophole and the Berkshire Model provide clear examples of the
purpose of Sections 531 and 532. Buffett and Berkshire are accomplishing
precisely what the code is trying to prevent: shareholders getting away
without paying taxes.
Enforcement of these two sections has been sporadic, subject to the judgment
of the Internal Revenue Service. An official commentary on the code,
Federal Tax Coordinator 2d, D-3003, states that, for enforcement of the
accumulated-earnings tax, “Congress did not want the taxing authorities
second-guessing the responsible managers of corporations as to whether and
to what extent profits should be distributed or retained, unless the taxing
authorities were in a position to prove their position was correct.”
CAN THE IRS CONTEND that Berkshire’s purchase of Duracell was not essential
for its Heinz holding, for its Burlington Northern Santa Fe railroad, or
for its core insurance businesses? Of course.
Can the IRS see that by looking the other way it has unreasonably feathered
Buffett’s nest, allowing him to avoid paying reasonable taxes? Of course it
can. It chooses not to see anything.
The relationship between the Wizard of Wall Street and our president is
symbiotic. The two scratch each other’s back at the expense of the
commonweal. How nice for our president, who is so eager to spread the wealth
around, to have one of our richest citizens militating for higher taxes on
the rich. How nice for Buffett to play to an adoring crowd of wealth-
spreaders. How strange that it’s not his wealth that they are spreading
around.
MORRIS PROPP, a former aerospace scientist and options pioneer, is a private
investor.
Other Voices essays should be about 1,000 words, and e-mailed totg.donlan@
barrons.com. | y***r
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