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Comment Re:The IRS keeps its hooks in US citizens who leav (Score 5, Interesting) 365

You've provided reasonable links, but you simply haven't read that information correctly. Here's how the U.S. Expatriation Tax actually works (assuming your net worth exceeds $2 million or that you otherwise are subject to the Expatriation Tax), oversimplifying only slightly:

1. Take your total worldwide net worth at fair market value as if all your assets were sold the day before your expatriation date.
2. Subtract your total worldwide cost basis from your net worth. The result is your total gain from your mark-to-market "deemed sale."
3. Subtract $690,000 (tax year 2015, adjusted annually for inflation) from your total gain. The result is your total taxable gain. If your total taxable gain is zero or negative, stop: you do not owe any Expatriation Tax.
4. Otherwise, pay ordinary capital gains tax rates on your total taxable gain, with a current top marginal tax rate of 23.8% (if the NIIT applies, and I'm not sure it does, but let's assume that). This is your total U.S. Expatriation Tax.

If you owe Expatriation Tax your cost basis is reset. Any subsequent capital gains on U.S. assets will only be taxed based on your new, reset cost basis. Note that "wash sale" rules do not apply when making the Expatriation Tax calculation, so deemed sale capital losses are not limited within the calculation. To some degree you can pay your Expatriation Tax in installments if you wish and only pay statutory interest on deferred payments (currently 3%). If your assets are generating a higher after-tax rate of return (quite likely) then stretching out your Expatriation Tax payment to the maximum extent allowed by law is a good idea. You may also wish to stretch out your Expatriation Tax payments if you prefer to raise funds more slowly, perhaps as in the form of interest, dividends, royalties, and/or earned income.

The U.S. Expatriation Tax is not a hardship by any reasonable definition of hardship, and it's quite disingenuous to complain about not getting a $250,000 capital gains exclusion on a home when you're getting a $690,000 blanket exclusion. But if it were a hardship, there's a simple, 100% effective solution to avoid the U.S. Expatriation Tax: don't renounce or relinquish U.S. citizenship.

Comment Nokia's S40-Based Services Also Dying/Dead (Score 1) 77

Microsoft is also ending/has ended the few important cloud-based services that support Nokia's S40-based devices. As of mid-2015, S40 still had almost double Windows Phone's global mobile user marketshare (according to StatCounter), so Microsoft's sunsetting of S40 services has a bigger global impact.

Both S40 and Windows Phone are in decline, though S40's bigger share is declining somewhat faster. Regardless, it's probably not good business strategy to upset over 4% of the world's mobile device users (S40) with premature termination of the few Microsoft/ex-Nokia services they do use. As far as I can tell, Microsoft is really not doing anything to help S40 users get to Windows Phone even if they wanted to go there. It's a major lost opportunity. For example, Microsoft could have: (1) held onto the Ovi Store (instead of outsourcing it to Opera where it's even more moribund); (2) provided a reasonable set of core, basic Microsoft services for S40 (notably Skype Chat, OneDrive with basic document viewing, and a basic client); (3) provided an S40 on-device application that keeps basic phone settings (contacts, calendar, bookmarks/favorites, text messages, etc.) synced across devices to smooth the path to Windows Phone; and/or (4) provided an S40 emulator for Windows Phone so that users could migrate as much or as little as they wanted. None of that would have cost very much to do or been hard to do, but as far as I know Microsoft took none of those steps. Consequently S40 device users are not switching to Windows Phone when they get new devices. It appears that, among S40 device users who are in the market for a new device, more of them are choosing new (or newer) S40 devices than are choosing Windows Phone devices! Google is winning most of them, though, primarily with Android One devices.

Of all the companies that should understand this phenomenon, you'd think Microsoft would. Don't orphan users! Give them realistic options to continue doing business with you, and they very well might! And if a 2.3% global marketshare business makes sense (Windows Phone), then keep shipping one or two S40 devices every year to hang onto as much of that ~4% marketshare as possible for as long as possible, with the sensible/inexpensive transition offerings I described. There is an ongoing market for a relatively simple mobile device with a truly long battery life and a more pocketable form factor, the segment of the market that Nokia dominated with S40. There's nothing wrong with that, and Microsoft should keep at it. (Microsoft is sort of doing that -- they still have a couple S40 devices on sale -- but they're not executing well.)

Comment Re:Security is also about design (Score 1) 108

I completely agree. I'm afraid that was not one of the smarter things Linus -- an otherwise routinely brilliant guy -- has said. Outlook is a good example. As another example, if you look at the (continuing) evolution of mainframes and their operating systems -- and you must if you want to understand IT security fully, competently -- one interesting bit of history is that IBM had to rewrite OS/360 MVT in the early 1970s. That rewrite (OS/VS2 Version 2 MVS, later evolving through several MVS releases into OS/390 then z/OS) notably included adding what became SAF to get the security design right, though there were many other security design-related decisions in that massive rewrite effort. IBM, with all its resources -- and with ostensibly a less complex base -- couldn't stomp out all the bugs in OS/360, and there were lots of ongoing security and integrity problems in OS/360. (The two are closely related.) The z/OS security subsystem, RACF, uses SAF interfaces, and so do other security subsystems/providers such as ACF2 and TopSecret. Yes, you can choose your preferred security subsystem on this most popular mission-critical operating system. The security architecture is that clean and separated, as it should be.

Comment Not with Asymmetric Information (Score 4, Interesting) 83

Asymmetric information is a classic market failure, and automotive engineering is full of asymmetric information. Moreover, there are externalities, another classic market failure. Your Jeep's loss of control can cause my Chevrolet's trip into a brick wall, for example. Your Jeep's unregulated tailpipe emissions cause smog. Markets don't always (or even frequently) work well. But if you disagree, there are a few countries that offer unregulated free markets. I suggest moving to Somalia if you're an enthusiastic fan of free markets.

Comment Alternative to Oracle Database (Score 2) 184

IBM's DB2 is the most prominent, most direct, most capable alternative. DB2 ranges from the zero license charge DB2 Express-C all the way up to the true continuous business service, mission critical DB2 for z/OS (that even Larry Ellison says nice things about). There's even a DB2 database cum tightly coupled operating system (IBM i). IBM publishes an Oracle to DB2 Conversion Guide and associated migration tools, and IBM has done a lot of work to implement technologies (e.g. PL/SQL) that make it easier to move to DB2. I don't know of any other realistic options because they have various shortcomings such as poor cross-platform support (notably Microsoft SQL Server), questionable SQL and/or ACID attributes, poor application support, and/or questionable enterprise support. In some cases you might be able to get away with MariaDB, for example, but you're probably going to need at least some DB2 to clear out Oracle completely -- and that's what you really need to do if you've got an abusive relationship. You'll also have to clear out some Oracle applications and middleware, but IBM is an obvious competitor there, too.

Comment Pleaded Guilty, Broken Link (Score 1) 312

The link to the article is broken (of course).

If the first charge wasn't a crime then Amin had the option not to plead guilty to it. On the other hand, if he's satisfied with the plea deal his attorney presumably negotiated (presumably heavily based on the other charge), then maybe a guilty plea was his best option. Absent evidence to the contrary, one has to assume his attorney properly assessed whether that first charge could have been beaten in court and weighed that factor in advising his client.

Comment Only One Immediate Question, Really (Score 1) 743

The Greek government can never repay its current debt obligations, primarily held now by public sector international creditors that bailed out their own reckless and very poorly capitalized private banks to keep them on life support. (It takes two parties to accumulate debt: creditor and debtor. Greece's creditors shared at least as much blame as Greece's prior governments.) That's just a simple mathematical fact. The only remaining salient question in this tragedy is whether the European Central Bank (ECB), and specifically one very democratically unelected banker (Mario Draghi), will take affirmative action to destroy Greece's banking system solely because some other party (the Greek government) cannot and will not, in fact, repay its (euro-denominated) debts. As an approximate analogy it'd be as if the U.S. Federal Reserve decided to destroy Citibank, J.P. Morgan Chase, and BNY Mellon by terminating their loan facilities from the lender of last resort, even via nationalization, if the State of New York, where those banks are based, were to default on its bonds. Yes, that's *crazy*, that the Federal Reserve would act in such a way, yet here we are with the ECB.

Comment Among the Many Big Questions (Score 1) 72

1. Customer opt in or opt out? Binary control, or more fine grained control?
2. Security? Liability?
3. Will the "financial tech incubators, accelerators, and startups" be held to the same requirements and same standards? If not, why not?
4. How will API evolution and versioning work? Who's responsible?
5. How will compliance with the standard(s) (and service levels) be enforced?

Comment Smartphone Stability Nominees (Score 1) 484

1. Apple's iOS compares quite well, but if you want to maximize stability be cautious about updates until there are some reports (some of the 7.x and 8.x releases were clunkers, though the current 8.3 seems quite good now), and turn off features you don't need, especially the privacy-invading ones.

2. Blackberry. They're still around, and they're rather solid -- provided the device is. (Some of their devices have been clunkers, others solid. Again, take a look at consensus reports.)

3. Nokia/Microsoft S40 devices. You can still find some S40 devices (unlocked and inexpensive), though they are not as feature rich and stretch the definition of "smartphone" downward. I've got an S40 device that, at least once updated to the latest S40 release, is rock solid -- and lasts a long, long time per battery charge. The S40 devices are not long for the world, though, so don't get too attached.

4. If you experiment with Android, I'd stick to the purest form of it: Google's Nexus devices. If Google cannot make Android work well on its own branded devices then nobody can.

Comment IBM's Tape Capacities Are Largest Available (Score 1) 229

I think you're out of date by several months. IBM TS1150 holds 10TB uncompressed per tape cartridge, not 8.5TB (or 8.0TB -- to get up to 8.5TB is a little "weird"). Sustained data rate is 360MB/s, not 252MB/s. Yes, LTO state-of-the-art is well behind both IBM TS1150 and Oracle STK T10000D.

Comment Yes: Free Money from the IRS! (Score 1) 734

Let's suppose you have two children and your U.S. Adjusted Gross Income (AGI) is about $75,000 or less. (If you earn more the math *might* change.) When you file your U.S. tax return (filing status Single, or Head of Household if you qualify), as a resident of Belgium (a comparatively high income tax jurisdiction) you should NOT take the Foreign Earned Income Exclusion or Foreign Housing Exclusion (IRS Form 2555). Instead you should only take the Foreign Tax Credit (IRS Form 1116). You should also take the Additional Child Tax Credit (IRS Schedule 8812). Follow that particular path, preferably using your favorite tax preparation software (even the free ones like TaxAct or TaxSlayer), and you should see a REFUND at the bottom of your tax return. Yes, the IRS will send you $1000 per U.S. citizen child per year in free money. Really. (In tax years 2009 and 2010 there was another $400 in free money available as a special refundable tax credit, but maybe you missed that.)

Take the money and save it for your kids, or spend it on your kids, or some of both. That's about $17,000 per child in free money over their childhoods. When they turn 18, THEY can decide whether they wish to terminate their U.S. citizenships or not. I'd advise them not (under present conditions at least), but under current law it's free to do so before age 18 1/2. Even if it's not free, they've started with $17,000 in free money plus interest.

No brainer, here: get your kids' U.S. citizenships documented. U.S. citizenship literally pays.

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