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IRS Is Suing Facebook Over Asset Transfers In Ireland ( 97

An anonymous reader quotes a report from Fortune: The Internal Revenue Service (IRS) has sued Facebook on Wednesday to force it to comply with summonses related to a 2010 asset transfer. Fortune reports: "According to documents the IRS filed in San Francisco federal court, the agency suspects Facebook and its accounting firm, Ernst and Young, understated the value of intangible assets transferred to Ireland by billions of dollars. The IRS says it is seeking an order to enforce six summonses that asked Facebook to appear at the agency's offices in San Jose, Calif., and to produce papers and others records. According to IRS agent Nina Stone, Facebook failed to show up at the appointed date of June 17, and nor did it provide the documents. The dispute arose as a result of an ongoing audit of Facebook by IRS that stretches back to 2010. In that year, the company chose to designate Facebook Ireland as the rights-holder for its worldwide business outside of the U.S. and Canada, and also to transfer intellectual property assets such as its platform and 'marketing intangibles.' The crux of the disagreement between Facebook and the IRS turns on the arcane question of whether the assets in question could be transferred in their entirety or if, as the agency argues, they are 'interdependent.' [The agent's declaration can be found here.] Such arrangements are common among U.S. tech companies, and seek to reduce tax payments by scoring revenue in low tax jurisdictions like Ireland, while having higher tax countries (especially the U.S.) reduce profits by paying to license intellectual property from overseas subsidiaries."

Comment Re:There had to be a first case... (Score 5, Insightful) 379

The balance is that Tesla will learn from this accident. They will change the software on the existing vehicles to try to detect this situation better, and they will undoubtedly outfit the next generation of cars with improved sensors to avoid this specific accident.

In contrast, in a human-driven car, the only one who learned anything is dead, so the next person who gets in the same situation will likely react the same way and end up just as dead. At best, there might be a slight change to driver education because of it, but it isn't worth adding e.g. an extra lesson to the curriculum to avoid one specific accident.

Comment Re:how about 0 (Score 1) 455

A Danish driver was convicted forDUI after sharing a smoking area with marijuana smokers. In Denmark, the acceptable level is the detection limit, and blood tests are really really effective for marijuana. He was sentenced to lose his license for 3 years and 6 months.

However, it is worth noting that the police had stopped him for suspected drunk driving, and then decided to do a drug test since the alcohol level was below the legal limit and he seemed to be impaired.

Comment Re:Not Necessarily for the Benefit of Users (Score 2) 69

I do not think you are aware how Netflix actually distributes content.

Every reasonably-large ISP is offered a Netflix-cache which is a physical box they provide. The ISP then installs the box in their network, and the Netflix customers in that ISP now get their content from the box. Unless the content is too rare to be in the cache, in which case it flows over the regular network, like before. Now, for many smaller ISP's this is not worth it, since the box itself eats quite a large amount of bandwidth just to keep its cache updated. But for the medium-sized ISPs it is a great way to save on transit bandwidth, and Netflix loves it because they get the bandwidth for free as well.

The neat thing is that for participating ISPs, Netflix has no extra expenses when a customer picks a high bandwidth stream, and for the ISP it is great as well because they only have to transport the stream in their own network, which in many cases is close to free. As an extra bonus for the ISP, the customer might have a data quota or even pay per gigabyte.

Comment Re:The ultimate terror: Locked-in syndrome (Score 1) 119

There has been research showing that people previously thought to be brain dead could actually be communicated with using fMRI's combined with very specific setups (basically telling the person to think of something specific for yes and of something completely different for no, then analyzing the scans to determine the answer).

No. No there has not. Brain dead people really are brain dead, their brains are not showing activity on scans. Otherwise they wouldn't be brain dead.

There has been studies showing that locked-in people can actually communicate using fMRI scans. But they're locked-in, not brain dead.

Comment Doubtful (Score 5, Insightful) 230

There are two things I find unlikely about this story.

1. That Second Life is still a thing.
2. That these are actual Trump supporters.

It's just trolls getting a two-for-one deal. They get to disrupt the Bernie supporters while at the same time painting Trump supporters in a bad(worse?) light.


NASA Feed 'Goes Down As Horseshoe UFO Appears On ISS Live Cam' ( 412

schwit1 quotes a report from Mirror Online: NASA has been accused of an alien cover up after a live International Space Station feed appearing to show a horseshoe UFO suddenly went down. Conspiracy theorists are having a field day over the sighting of the strange U-shaped object hovering on the horizon of the the ISS. They claim NASA 'cut the live feed' after the glowing blue object flew too close to the space station. Some have even gone as far to say NASA's funding should be cut over their 'great alien deception.' Scott Waring of UFO Sightings Daily first discovered the UFO. He passed the footage on to Tyler Glockner who uploaded the video to his YouTube channel secureteam10. What do you think: is it an alien spaceship or something more likely such as a reflection from a station window?

Comment Carriers won (Score 2, Interesting) 60

LTE-U would have allowed yourphone to do 4G on unlicensed bands. That means you could legally make your own cell phone provider at home, and make your phone roam there for cheap calls.

LAA is a way for carriers to steal bandwidth from the public, without having to give anything back. They just squat on the public bandwidth for the actual data, but all control traffic is on licensed bands. This means you cannot set up a carrier without licensing.

The demise of LTE-U is very sad.

Comment Re:USB designed for semi-permanent peripherals (Score 1) 131

On the upside, traditional USB is so simple that it can be made reasonably secure, if anyone cares to do so. Devices can't really initiate anything, they can just wait for the host computer to get around to listening to them or assert a flag that they need servicing, hoping that the host computer cares. It is also slow enough that you can play microkernel and sandbox the USB device drivers, preventing them from messing up too badly. Once that is done, you "just" have to audit your USB host controller driver and make sure that you do not use native file systems on USB devices (instead going through FUSE or similar, with sandboxing).

This is a great situation compared to e.g. FireWire where you are owned by anything, even if you don't have a device driver for it.

Alas, with USB 3 comes DMA, and that means you need the same defences as FireWire -- IOMMU and such. Good luck getting that right.

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