Skip to Main Content
 

Tax Notes Today Quotes David Rosenbloom: EBay Accepts 'Buy It Now' Tax Price on $9 Billion Repatriation

May 1, 2014, Tax Notes Today

Tax Notes Today spoke with H. David Rosenbloom concerning the $3 billion tax bill paid by eBay Inc. for repatriating $9 billion during the first quarter of 2014, making it one of the largest repatriations in recent years. For the complete article, please visit Tax Notes Today's website (subscription required).

Excerpt taken from the article "EBay Accepts 'Buy It Now' Tax Price on $9 Billion Repatriation" by William R. Davis for Tax Notes Today.

H. David Rosenbloom of Caplin & Drysdale speculated that eBay may have repatriated the earnings to address "pressing needs in the United States such as executive compensation and stock buybacks."

Companies with large offshore earnings make regulatory statements about their intentions of keeping the earnings overseas for investment, and auditors often acquiesce, Rosenbloom said; however, those companies can repatriate the cash whenever they want.

"There's the downside of needing to accept the previously ignored U.S. tax cost as an earnings hit, but if [the companies] want cash badly enough, they swallow hard and go for it," Rosenbloom added. He said that that is likely how eBay got to the point where it had to repatriate $9 billion.

"Everyone in the tax community thinks the world turns according to the tax laws," Rosenbloom said. He said that instead, financial accounting is what "ultimately determines compensation and, of course, compensation determines everything else."

 

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2018 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)