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PRE (Permanently Reinvested Earnings)
(1) A U.S. company gives a foreign subsidiary the license to use its intellectual property (patents, designs, etc.) to make money overseas. (2) This unit collects all foreign earnings. (3) Those earnings, subject only to (lower) foreign tax rates, can be reinvested anywhere in the world; the only place they can’t go is back to the U.S. company as cash profits.

Double Irish
(1) A U.S. company licenses an Irish subsidiary to use its intellectual property abroad. (2) Irish No.1 moves, for Irish tax purposes, to tax-free Bermuda, becoming Bermuda No.1—but U.S. tax law still identifies it as Irish No. 1, thus masking the amount of taxes the company is avoiding (Ireland has low, but not nonexistent, corporate taxes). (3) Bermuda No.1 sub-licenses another Irish company to manage the original intellectual property. (4) Irish No.2 sends earnings to Bermuda No.1 as “royalties” for the licensing rights. These payments are tax-deductible, so Irish No. 2 avoids most taxes, too.

Killer B
Here’s one simple method, named after the section of the tax code it exploits, to bring foreign earnings home as cash. (1) A U.S. corporation gives some of its stock to a subsidiary in another country. (2) The subsidiary pays the U.S. company cash for the stock. (3) The U.S. company pays no taxes on the cash because it was received in exchange for stock. (The IRS has, of late, started cracking down on this technique.)

Deadly D
Another way of getting money back to America. (1) A U.S. company buys another company (one that it wants to buy anyway). (2) It then transfers ownership of that company to a foreign subsidiary. (3) The foreign subsidiary “pays” the U.S. parent for the new company in cash, which, because it’s entering the country in exchange for the transferred ownership, is (4) not taxed by the IRS.

Keith Powell (left) Avenue L and East 92nd Street, Canarsie. On August 20, 2006, Powell was on his way to visit a brother when he was struck by a drag-racing car. Witnesses said the driver ditched the stolen car and fled.

Jian-Lan Zhang Allen and Hester Streets. Zhang, a 55-year-old Chinatown resident, was struck and killed by a delivery truck on April 16, 2008.

Alvaro Francisco Olsen (left) West 36th Street and Broadway. On April 16, 2008, Olsen, an El Salvadoran immigrant living in Jackson Heights, was killed by a DHL truck.

Flaco East 153rd Street and Melrose Avenue, the Bronx. On May 18, 2007, a thief known as Flaco stole a fourteen-karat-gold cross from a jewelry store on Elton Avenue. He was struck by a city bus as he fled. The necklace was never recovered.

Unknown (left) Utica Avenue and Fulton Street, Bed-Stuy. On October 18, 2007, an unidentified 25-year-old was killed by a speeding van. The driver pled guilty to criminally negligent homicide.

Andrew Ross Morgan Houston and Elizabeth Streets. On June 22, 2005, Morgan was biking to Blue Ribbon Bakery Market, where he worked as a manager, when he was pinned under the axle of a furniture delivery truck.

Jerome Allen (left) Hylan Boulevard and Lipsett Avenue, Staten Island. On April 26, 2005, during a daily sunset ride near his home, Allen was struck from behind by a Lexus SUV. He was a member of the Staten Island Bicycle Association.

Eric Ng West Side Highway and Clarkson Street. On December 1, 2006, Ng was struck by a BMW on the Hudson River Park bikeway. According to police, the driver reached 60 mph.

Carl Henry Nacht (left) West Side Highway and 38th Street. After dinner on June 22, 2006, Nacht, a doctor who often cycled to make house calls to his elderly patients, was hit by an NYPD tow truck crossing the Hudson River Park bikeway.

Shamar Porter Linden Boulevard near Williams Avenue, East New York. On August 5, 2006, Porter’s Little League team won its playoff game. He was struck by a minivan after leaving the field.

Reginald Chan (left) Third Avenue and 17th Street. On September 15, 2006, Chan was hit by a flatbed tow truck while making a delivery of Chinese food.

Brandie Bailey Houston and Essex Streets. On May 8, 2005, Bailey was struck by a private sanitation truck while on her way home to Williamsburg after waitressing at the West Village restaurant Red Bamboo. Bailey was a regular at CBGB, where a memorial was held in her honor.

Craig Murphey (left) Ten Eyck Street and Union Avenue, Williamsburg. Early in the morning of October 18, 2007, Murphey was biking home from escorting his date to her South Williamsburg apartment. According to police reports, Murphey attempted to outrun a gas truck turning left on Ten Eyck Street. His pelvis shattered on impact, and he was pronounced dead at the scene. In his honor, over 40 friends have since received tattoos that read BE BETTER.

Frank C. Simpson Linden Boulevard near 175th Street, St. Albans. Simpson, a janitor returning from the evening shift at a Con Edison facility, was hit by a Dodge Stratus on November 9, 2006.

Jose Mora (left) North Conduit and McKinley Avenues, Cypress Hills. On September 4, 2006, 11-year-old Mora was on his way to the barber for a back-to-school haircut; that week, he was to start the sixth grade at nearby Junior High School 302. He was struck by a Honda while walking his bike across an intersection.

Jonathan Neese South 4th Street and Roebling Street, Williamsburg. On August 12, 2006, Neese, a bike messenger known as “Bronx Jon,” was struck by a livery cab while cycling from Brooklyn to Manhattan.

Sam Khaled Hindy (left) Base of the Manhattan Bridge. On November 16, 2007, Hindy was run over after mistakenly entering a Manhattan Bridge lane reserved for cars.

Habian Rodriguez Main Street and Horace Harding Expressway, Flushing. On September 1, 2007, Rodriguez collided with a city bus and died 30 minutes later.

Elizabeth Padilla (left) Fifth Avenue and Prospect Place, Park Slope. Commuting to the Brooklyn Bar Association on June 9, 2005, Padilla swerved to avoid the open door of a parked P.C. Richard’s truck. She lost control of her bike and fell underneath the wheels of an ice-cream delivery truck.

Juan Luis Solis East Gun Hill Road and Bouck Avenue, the Bronx. Attempting to pass a double-parked car on June 22, 2007, Solis was struck by a box truck and died of severe head trauma. The truck did not stop.

Jeffrey Moore (left) Chauncey Street and Rockaway Avenue, Bed-Stuy. According to witnesses, on May 29, 2007, Moore was run over (twice) by his girlfriend Jeanine Harrington. She was indicted on charges of murder and criminal possession of a weapon (her Nissan Pathfinder).

Derek Lake Houston Street and La Guardia Place. On June 26, 2006, Lake reportedly skidded on a steel construction plate and was crushed underneath the wheels of a passing truck.

Elijah Armand Wrancher (left) Springfield Boulevard and 130th Avenue, Springfield Gardens. On August 28, 2007, 12-year-old Wrancher attempted to ride his bicycle while holding onto a moving truck. He lost his grip and fell under the truck’s rear wheel.

David Smith Sixth Avenue and 36th Street. On December 5, 2007, Smith was biking up Sixth Avenue when the passenger-side door of a parked pickup truck opened unexpectedly. He was knocked into the path of an oncoming truck.

Anthony Delgado (left) Palmetto Street and Central Avenue, Bushwick. Shortly after midnight on April 29, 2007, 13-year-old Delgado borrowed a bike to head home from his friend’s baptism party. As he crossed the intersection, he was struck by an SUV.

Carolina Hernandez 57th Avenue and Junction Boulevard, Elmhurst. On August 16, 2007, Hernandez was riding to a mall when she was struck and killed by a Chevy truck. The driver pled guilty to driving with a suspended license.

Anthony Delgado (left) Palmetto Street and Central Avenue, Bushwick. Shortly after midnight on April 29, 2007, 13-year-old Delgado borrowed a bike to head home from his friend’s baptism party. As he crossed the intersection, he was struck by an SUV.

Carolina Hernandez 57th Avenue and Junction Boulevard, Elmhurst. On August 16, 2007, Hernandez was riding to a mall when she was struck and killed by a Chevy truck. The driver pled guilty to driving with a suspended license.

Anthony Delgado (left) Palmetto Street and Central Avenue, Bushwick. Shortly after midnight on April 29, 2007, 13-year-old Delgado borrowed a bike to head home from his friend’s baptism party. As he crossed the intersection, he was struck by an SUV.

Carolina Hernandez 57th Avenue and Junction Boulevard, Elmhurst. On August 16, 2007, Hernandez was riding to a mall when she was struck and killed by a Chevy truck. The driver pled guilty to driving with a suspended license.

Anthony Delgado (left) Palmetto Street and Central Avenue, Bushwick. Shortly after midnight on April 29, 2007, 13-year-old Delgado borrowed a bike to head home from his friend’s baptism party. As he crossed the intersection, he was struck by an SUV.

Carolina Hernandez 57th Avenue and Junction Boulevard, Elmhurst. On August 16, 2007, Hernandez was riding to a mall when she was struck and killed by a Chevy truck. The driver pled guilty to driving with a suspended license.

Fall Fashion Features

The Beefcake in the Backcourt
Big, fake, and fully able to outshine its surroundings.Big, fake, and fully able to outshine its surroundings.

 

The Beefcake in the Backcourt
Big, fake, and fully able to outshine its surroundings.Big, fake, and fully able to outshine its surroundings.
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