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by anomaly_ 4671 days ago
I found this statement interesting - "Microsoft will draw upon its overseas cash resources to fund the transaction." I've seen it mentioned quite a few times that tech companies end up with massive overseas cash reserves they can't repatriate for tax reasons. Anyone with better knowledge of finance/tax want to chime in with whether this makes the deal even more attractive for MS?
2 comments

The corporate tax rate in the United States is 35%. The corporate tax rate in Ireland is 12.5%. (This is why multinationals like to incorporate their European subsidiaries in Ireland.)

If Microsoft moved money in the United States, it would pay the difference in taxes -- namely, 22.5%. But if Microsoft spent the money outside the United States, then it would not pay this difference.

Incidentally, Finland will be reducing its corporate tax rate next year, from 24.5% to 20%.

A summary of the tax arrangements used by some large American multinationals, including Microsoft, Google, Facebook, Apple, Oracle and Adobe:

http://en.wikipedia.org/wiki/Double_Irish_arrangement

As I understand it, these international profits remain in the tax-haven-resident Irish company, and cannot be repatriated to the US parent without incurring an undesirable taxation event.

It's highly likely that Finland-based Nokia is a fiscally efficient purchase for Microsoft. Both Finland and Ireland are EU countries, are in the Eurozone, and have a customs union.

(It would be interesting to compare this to Google's purchase of Motorola Mobility, which was an American company.)