Facebook Page


有建設必地回應網絡留言

哲學哲學雞蛋糕那兒借來的圖﹐雖說這是回應網路留言的方法﹐說穿了其實是寫哲學論文的規格。有建設性的網路留言﹐其實與研究哲學一樣﹐是很好的思辯訓練。

The power of posture

According to this research, how your posture affect your projection of power and how other people perceive it. It is interesting to note the powerful sitting posture is regard as bad sitting manner in traditional Chinese culture. Another evidence for my theory that manners are simply rules set by the authority to make people easier to rule.

How you hold yourself affects how you view yourself
Jan 13th 2011, Economist

“STAND up straight!” “Chest out!” “Shoulders back!” These are the perennial cries of sergeant majors and fussy parents throughout the ages. Posture certainly matters. Big is dominant and in species after species, humans included, postures that enhance the posturer’s apparent size cause others to treat him as if he were more powerful.

The stand-up-straight brigade, however, often make a further claim: that posture affects the way the posturer treats himself, as well as how others treat him. To test the truth of this, Li Huang and Adam Galinsky, at Northwestern University in Illinois, have compared posture’s effects on self-esteem with those of a more conventional ego-booster, management responsibility. In a paper just published in Psychological Science they conclude, surprisingly, that posture may matter more.

The two researchers’ experimental animals—77 undergraduate students—first filled out questionnaires, ostensibly to assess their leadership capacity. Half were then given feedback forms which indicated that, on the basis of the questionnaires, they were to be assigned to be managers in a forthcoming experiment. The other half were told they would be subordinates. While the participants waited for this feedback, they were asked to help with a marketing test on ergonomic chairs. This required them to sit in a computer chair in a specific posture for between three and five minutes. Half the participants sat in constricted postures, with their hands under their thighs, legs together or shoulders hunched. The other half sat in expansive postures with their legs spread wide or their arms reaching outward.

In fact, neither of these tests was what it seemed. The questionnaires were irrelevant. Volunteers were assigned to be managers or subordinates at random. The test of posture had nothing to do with ergonomics. And, crucially, each version of the posture test included equal numbers of those who would become “managers” and “subordinates”.

Once the posture test was over the participants received their new statuses and the researchers measured their implicit sense of power by asking them to engage in a word-completion task. Participants were instructed to complete a number of fragments (for example, “l_ad”) with the first word that came to mind. Seven of the fragments could be interpreted as words related to power (“power”, “direct”, “lead”, “authority”, “control”, “command” and “rich”). For each of these that was filled out as a power word (“lead”, say, instead of “load”) the participant was secretly given a score of one point.

Although previous studies suggested a mere title is enough to produce a detectable increase in an individual’s sense of power, Dr Huang and Dr Galinsky found no difference in the word-completion scores of those told they would be managers and those told they would be subordinates. The posture experiment, however, did make a difference. Those who had sat in an expansive pose, regardless of whether they thought of themselves as managers or subordinates, scored an average of 3.44. Those who had sat in constricted postures scored an average of 2.78.

Having established the principle, Dr Huang and Dr Galinsky went on to test the effect of posture on other power-related decisions: whether to speak first in a debate, whether to leave the site of a plane crash to find help and whether to join a movement to free a prisoner who was wrongfully locked up. In all three cases those who had sat in expansive postures chose the active option (to speak first, to search for help, to fight for justice) more often than those who had sat crouched.

The upshot, then, is that father (or the sergeant major) was right. Those who walk around with their heads held high not only get the respect of others, they seem also to respect themselves.

LapGear Deluxe Computer LapDesk

Since I have hooked up my old computer to my big screen TV in the living room, I have been facing a problem, how can I use the wireless keyboard while sitting comfortably in the couch. If I put the keyboard on my lap, I have to sit up tight or the keyboard will move around. Moreover, the position of the keyboard is too low to type and there is no place for the mouse. An alternatively solution is put the keyboard and mouse on the coffee table, but I then can’t lay back on the couch and defeat the purpose of setting up the computer in the first place.

Then I come across the LapGear Deluxe Computer LapDesk in Staples when it’s on sales for $24.99. The LapDesk is very comfortable, it has micro-bean pad on the bottom and the lap desk sits comfortably and stable on my lap. It has a large surface big enough for the wireless keyboard and a mouse. It also come with mouse pad on both side for right handed and left handed mouse users. It has two small pockets to store the mouse and some pens. Now I can sit back and relax on my crouch while I am surfing the net on my big screen TV.

In fact the LapDesk is so comfortable that when my friends visiting my place who has a similar setup at home, not one but two friends like it so much that they went out to buy one for themselves.

Product website

To Really Learn, Quit Studying and Take a Test

That’s why the most effective way to learn is taking a course with the home work assignments and exams that force you to learn.

By Pam, Belluck, New York Times, January 20, 2011

Taking a test is not just a passive mechanism for assessing how much people know, according to new research. It actually helps people learn, and it works better than a number of other studying techniques.

The research, published online Thursday in the journal Science, found that students who read a passage, then took a test asking them to recall what they had read, retained about 50 percent more of the information a week later than students who used two other methods.

One of those methods — repeatedly studying the material — is familiar to legions of students who cram before exams. The other — having students draw detailed diagrams documenting what they are learning — is prized by many teachers because it forces students to make connections among facts.

These other methods not only are popular, the researchers reported; they also seem to give students the illusion that they know material better than they do.

In the experiments, the students were asked to predict how much they would remember a week after using one of the methods to learn the material. Those who took the test after reading the passage predicted they would remember less than the other students predicted — but the results were just the opposite.

“I think that learning is all about retrieving, all about reconstructing our knowledge,” said the lead author, Jeffrey Karpicke, an assistant professor of psychology at Purdue University. “I think that we’re tapping into something fundamental about how the mind works when we talk about retrieval.”

Several cognitive scientists and education experts said the results were striking.

The students who took the recall tests may “recognize some gaps in their knowledge,” said Marcia Linn, an education professor at the University of California, Berkeley, “and they might revisit the ideas in the back of their mind or the front of their mind.”

When they are later asked what they have learned, she went on, they can more easily “retrieve it and organize the knowledge that they have in a way that makes sense to them.”

The researchers engaged 200 college students in two experiments, assigning them to read several paragraphs about a scientific subject — how the digestive system works, for example, or the different types of vertebrate muscle tissue.

In the first experiment, the students were divided into four groups. One did nothing more than read the text for five minutes. Another studied the passage in four consecutive five-minute sessions.

A third group engaged in “concept mapping,” in which, with the passage in front of them, they arranged information from the passage into a kind of diagram, writing details and ideas in hand-drawn bubbles and linking the bubbles in an organized way.

The final group took a “retrieval practice” test. Without the passage in front of them, they wrote what they remembered in a free-form essay for 10 minutes. Then they reread the passage and took another retrieval practice test.

A week later all four groups were given a short-answer test that assessed their ability to recall facts and draw logical conclusions based on the facts.

The second experiment focused only on concept mapping and retrieval practice testing, with each student doing an exercise using each method. In this initial phase, researchers reported, students who made diagrams while consulting the passage included more detail than students asked to recall what they had just read in an essay.

But when they were evaluated a week later, the students in the testing group did much better than the concept mappers. They even did better when they were evaluated not with a short-answer test but with a test requiring them to draw a concept map from memory.

Why retrieval testing helps is still unknown. Perhaps it is because by remembering information we are organizing it and creating cues and connections that our brains later recognize.

“When you’re retrieving something out of a computer’s memory, you don’t change anything — it’s simple playback,” said Robert Bjork, a psychologist at the University of California, Los Angeles, who was not involved with the study.

But “when we use our memories by retrieving things, we change our access” to that information, Dr. Bjork said. “What we recall becomes more recallable in the future. In a sense you are practicing what you are going to need to do later.”

It may also be that the struggle involved in recalling something helps reinforce it in our brains.

Maybe that is also why students who took retrieval practice tests were less confident about how they would perform a week later.

“The struggle helps you learn, but it makes you feel like you’re not learning,” said Nate Kornell, a psychologist at Williams College. “You feel like: ‘I don’t know it that well. This is hard and I’m having trouble coming up with this information.’ ”

By contrast, he said, when rereading texts and possibly even drawing diagrams, “you say: ‘Oh, this is easier. I read this already.’ ”

The Purdue study supports findings of a recent spate of research showing learning benefits from testing, including benefits when students get questions wrong. But by comparing testing with other methods, the study goes further.

“It really bumps it up a level of importance by contrasting it with concept mapping, which many educators think of as sort of the gold standard,” said Daniel Willingham, a psychology professor at the University of Virginia. Although “it’s not totally obvious that this is shovel-ready — put it in the classroom and it’s good to go — for educators this ought to be a big deal.”

Howard Gardner, an education professor at Harvard who advocates constructivism — the idea that children should discover their own approach to learning, emphasizing reasoning over memorization — said in an e-mail that the results “throw down the gauntlet to those progressive educators, myself included.”

“Educators who embrace seemingly more active approaches, like concept mapping,” he continued, “are challenged to devise outcome measures that can demonstrate the superiority of such constructivist approaches.”

Testing, of course, is a highly charged issue in education, drawing criticism that too much promotes rote learning, swallows valuable time for learning new things and causes excessive student anxiety.

“More testing isn’t necessarily better,” said Dr. Linn, who said her work with California school districts had found that asking students to explain what they did in a science experiment rather than having them simply conduct the hands-on experiment — a version of retrieval practice testing — was beneficial. “Some tests are just not learning opportunities. We need a different kind of testing than we currently have.”

Dr. Kornell said that “even though in the short term it may seem like a waste of time,” retrieval practice appears to “make things stick in a way that may not be used in the classroom.

“It’s going to last for the rest of their schooling, and potentially for the rest of their lives.”

Kirby’s Epic Yarn 毛線卡比

卡比曾經是任天堂的招牌電玩角色之一﹐可惜上一次出遊戲已經是十年前的事。這次在Wii上推出「毛線卡比」﹐遊戲最大特色是可愛萬分的畫面﹐人物以毛線﹐鈕扣和布碎貼圖效果組成﹐軟綿綿給人毛公仔的感覺。加上粉紅色的主角卡比﹐連老婆也奇怪我怎麼玩女生遊戲。

我沒有玩過舊版卡比﹐無從比輕新舊版之別。「毛線卡比」與瑪利奧同類﹐都是2D橫向捲軸動作遊戲﹐從左到右走過關然後打大佬。操控方式也很懷舊﹐十字按鈕控制方向﹐AB掣則分別跳和攻擊﹐差不多完全沒有運用Wii的體能功能。與瑪利奧最大的分別﹐是卡比擁有不死身﹐死掉了只會扣寶石﹐並在原地重新開始。所以若不求分數只求破關不難﹐只要試多幾次一定可以過關﹐又不用重覆已經通過的地方。這樣每天打一兩關輕鬆一下﹐玩了幾個星期不知不覺便打爆機了。

雖說是打爆機完成故事﹐但遊戲玩成度只有50%。遊戲中有很多寶物可以收集﹐可以用來佈置遊戲中的房間﹐大慨為照顧女孩子市場。另外還有很多隱藏關卡﹐要超過某個指定績分或收集某些寶物才能開啟﹐我可沒有心機去全攻略了。其實玩到後半也有點悶﹐關卡的設計變化不出那幾款﹐卡比的變身模式甚至出現重覆﹐不過竟然開了頭便繼續玩下去。

每次破關﹐便會有隻粉藍色王子出來﹐與粉紅色的卡比跳舞。初時我以為一隻粉藍一隻粉紅﹐想必然他們是一對情人﹐公主救王子之類的結局。到後來網上看資料﹐才發現原來卡比是男兒身。噢~ 這個遊戲豈不是宣揚同性戀。

It pays to give

I highly doubt this scheme will work with engineers, we are trained to rationalize our decisions. If free is an option, why pay? Donating the money to the same charity separately yields better return, at least you can get the tax credit.

Economist, Jan 13 2011
Allowing consumers to set their own prices can be good for business; even better if the firms give some of it to charity

IN OCTOBER 2007 Radiohead, a British rock group, released its first album in four years, “In Rainbows”, as a direct digital download. The move drew a fair bit of attention (including from this newspaper) not only because it represented a technological thumb in the eye to the traditional music industry, but also because the band allowed listeners to pay whatever they wished for it. Some 60% of those who seized the opportunity paid nothing at all, but the band seemed pleased with the result; one estimate had it earning nearly $3m from the experiment.

One group outside the music industry taking an interest was a trio of professors then at the Rady School of Management at the University of California, San Diego: Ayelet Gneezy, Uri Gneezy and Leif Nelson (who is now at the Haas School of Business at the University of California, Berkeley). Inspired, they designed a series of experiments to gauge whether pay-what-you-want pricing would work for other businesses. Their most recent experiment, co-authored with Amber Brown of Disney Research and published in Science, also stirred in a new element: would it make any difference if firms donated some of the pay-what-you-want fee to charity?

The authors set up their pricing experiment at the exit of a roller-coaster ride at a large amusement park. Riders were offered a photograph of themselves, snapped mid-coast. The usual price was $12.95, but on one day riders were told they could pay what they wished, including taking the photo for free. A second group was charged the full price but told that half the money would go to a well-regarded health charity. Yet a third group could set the price and see half of their chosen amount donated.

Allowing customers to set the price dramatically increased the percentage of buyers—from less than 1% to 8%. Even accounting for those who took a free photo, the amusement park collected more revenue on the pay-what-you-want day than when selling for the usual fixed price.

The authors also found that of the customers who were allowed to pay what they want, those who were told that half the money would go to a good cause paid substantially more than those who were not told about the charitable donation—to the point that revenue more than tripled. (The charity did, indeed, get its promised cut.) The smallest number of purchases, meanwhile, came the day that customers had to pay the full $12.95 but half was donated.

Therefore more than simple altruism was motivating the customers who gave money for a photo they could have had for free. “One of the quirks about paying what you want,” suggests Mr Nelson, “is that it starts to signal something about who you are. Every dollar you spend is a direct reflection of how much you care about this charity and what kind of person you are. No one wants to go cheap with a charity.” He calls this phenomenon “shared social responsibility”: instead of passively accepting a firm’s assertion of its charitable donations, the customer must actively agree to give money to charity, and determine how much.

But how widespread could shared social responsibility be? Ms Gneezy is the first to point out that customer-determined pricing works best for products with low marginal costs. Since publishing their findings, the researchers have spoken to several companies interested in pursuing similar experiments with their products, including software developers and video-game designers. But offering flexible pricing on a virtual product online, instead of in person at an amusement park, may make it easier for people to “go cheap” even if a charity is involved. Combining customer-determined pricing, corporate social responsibility, and increased profits will be tricky to pull off, and not every company will be able to do it—just like not every band can put their album online for free and still profit.

年輕彗星的肖像

在一般情況下﹐主角通常是一套動畫最受歡迎的角色。在高達UC系列中﹐駕高達的才是主角﹐但演反派的紅彗星馬沙﹐論人氣肯定比眾主角高出很多﹐甚至連他駕的機體也比高達受歡迎。他那個假面的經典造型﹐更成為了後來高達系列中﹐反派角色標準服飾。漫畫「年輕彗星的肖像」﹐便是講述一年戰爭完結到Z高達之間﹐他在那空白七年中的故事。當了這麼多年大配角﹐這次終於輪到馬沙擔正做主角﹐亦是少數以從自護角度﹐去看殖民衛星獨立運動。

在UC歷史中這空白的七年相對和平﹐漫畫不能過份歪曲正史的事件﹐所以沒有大規模的戰鬥場面。漫畫中的戰鬥場面﹐只限於幾台MS之間的游擊戰﹐連最後那場阿古捷斯內亂﹐參戰機體數目也只有十數台。每場戰鬥有點像自護MS博物館巡禮﹐所有一年戰爭的經典機體也有出場﹐還有一些當年只出過MSV模型的機體﹐裝上腳的完全自護號﹐黑色三連星高機動渣古﹐搭載卡碧尼系統的大魔試作機﹐京寶梵改良型等等﹐讓老高達迷可以懷舊一番。

故事的主線﹐當然是細說馬沙和哈瑪嘉的情史。一年戰爭後﹐馬沙逃到地球圈外圍﹐自護在小行星帶的阿古捷斯基地。哈瑪嘉當年只是個十四歲情竇初開的少女﹐還未成為日後新自護的女魔頭﹐只是阿古捷斯提督的千金少姐。這套漫畫終於為馬沙一洗蘿莉控的污名﹐哈瑪嘉單戀馬沙﹐但他卻選擇成熟的女軍官。說不定馬沙如果接受哈瑪嘉﹐她便不會後來性格乖張﹐奧干與新自護談判就不會破裂。在奧干與新自護聯手下﹐泰坦斯和哥洛斯大慨不堪一擊﹐Side 3再獨立也不是沒有可能。後來到馬沙之反擊的年代﹐兜兜轉轉馬沙又回到阿古捷斯﹐那當初又何必離開呢。倒不如留在哈瑪嘉身旁﹐以男色迷惑小女孩﹐自己當個攝政皇﹐可以更快建立新自護的勢力。

萌是現今漫畫的主流﹐連走軍武派路線的UC高達也不能幸免。漫畫中新人類泛濫﹐更巧合全部都是美少女。看Z高達那個哈瑪嘉﹐完全想不到在她剪招版冬菇頭前﹐竟然也有可愛的一面。那個駕三連星機的女生﹐除了不能用浮炮外﹐大慨新人類能力是UC之冠﹐可以用一發子彈角決一台高達。可惜她拋下一句她不管奧干和泰坦斯之間聯邦內戰便走了﹐要不然在Z高達或馬沙之反擊中出場﹐阿寶和嘉美尤也得靠邊站。至於駕黑色白雪號的女生﹐戲份不多像是臨完場才安排出來﹐與哈瑪嘉做場對手戲﹐好襯托她的新人類能力。

笨大拍完獨角獸的OVA﹐如果想繼續在UC世界淘寶﹐不妨考慮把這套漫畫動畫化﹐相信會有很多UC老餅支持。

Gunpla Builder Beginning

高達三十週年﹐笨大當然要做宣傳﹐放是便拍了這套「高達模型戰士」的動畫短片。三集每集十五分鐘﹐片中明目張膽地賣廣告﹐劇中每個角色都表達同一個中心思想﹐就是砌高達模型很快樂﹐不需要高超的技術﹐看自己完成的作品﹐便已經很心滿意足。既然是廣告不妨無視動畫的故事﹐雖然我也搞不清楚劇本只是單純的不合理﹐還是其實那是編劇刻意惡搞的惡趣味。令老一輩高達迷興奮的是﹐片中大量UC舊的機體出場﹐還有一些久違了的MSV謎之機體。片中的動作場面非常流暢﹐機械人一對一的對決精彩萬分﹐絕非雙蛋劇場版那些軟手軟腳的無力打鬥可比擬。

劇中有很多讓高達迷會心微笑的地方﹐編劇在有意無意間﹐勾起高達迷的美好回憶。第一集的戰場是笨大靜岡玩具廠﹐最一集的戰場卻是所羅門要塞﹐但四週卻佈滿不同UC年代的軍艦。在戰鬥中模型機械人被打中不是爆炸﹐而是手腳的模型組件散開﹐露出模型內的球型關節。除了主角機設計有點囧樣外﹐其他出場的機體皆叫人津津樂道。亞寶的最後機體Hi-Nu完成版﹐高渣古重武裝改造版﹐Astray決戰The-O﹐MA-04口中塞隻渣古扮GP-03D。魔霸原本應是龐然大物﹐但近看原來只是1/550版﹐比1/144的高達還細小﹐那一幕讓我嘿笑了出來。最讓人眼前一亮是龜霸改造的熊霸﹐背著個書包手持牧童笛﹐簡直可愛到殺死人。

動畫中的電腦遊戲比賽﹐集合「戰場之絆」的球型駕駛倉﹐高達VS系列的小隊對戰模式﹐再把玩家製作的模型立體素描進遊戲中﹐讓玩家駕駛自己的模型出戰﹐如果能夠在現實中造出來的話﹐大慨會是每個高達迷的夢想。以前小時候玩高達﹐會拿著玩具跳上跳落﹐幻想自己駕著機械人作戰﹐當然玩具最後少不免甩手甩腳。現在人大了玩高達﹐最多也是擺姿勢拍照﹐更多只是放在玩具櫃中齋看矣。雖然現在的模型玩具更加精美細緻﹐亦有能力買以前只望著玩具店櫥窗流口水的大型玩具﹐但已經不復童年總覺得失去了點什麼。這齣動畫正好讓我們這班大人UC迷﹐重捨小時候玩高達的歡樂。

復仇者之死

我很好奇有多少人﹐入場看「復仇者之死」是因為女主角蒼井空﹐日本最紅AV女優﹐第一套拍的香港三級片。不過我看這齣電影﹐主要是因為導演黃精甫。自他初出道拍攝「江湖」﹐我便十分欣賞他攝影手法。可惜上一套「阿嫂」過份玩弄﹐故事完全不之所謂﹐叫觀眾看到扯火爆粗。我還以為他從些人間蒸發﹐想不到竟然還有老闆肯出錢給他再搏一舖。

據聞劇本是麥俊龍自己編寫﹐主線十分簡單﹐鄉下青年愛上弱智少女﹐少女慘遭警察強姦﹐少年被警察誣告入獄。出獄後少年實行復仇計劃﹐以極血腥殘忍的手法﹐制裁當日犯下獸行的警察。本劇被電檢處列為三被﹐有割喉殺人血漿泛濫﹐有非常恐怖駭人的生劏孕婦剖肚取胎。反而萬眾期待﹐空姐被姦的祼露鏡頭﹐與她平常的演出比較實屬小兒科。

「復仇者之死」的影像凌勵﹐鏡頭表達手法剛勁有力﹐說故事像仍然是他的弱項。不過看黃精甫的電影﹐一向也是影像先行﹐每場戲獨立來看很有風格﹐但串連起卻完全迷失了觀眾。雖然故事不合理之處極多﹐但總算交代到一個完整故事﹐勉強合格吧。最後一場眾小孩一湧上前﹐蟻多螻死像的撲殺麥俊龍﹐是近年我看到最震撼的畫面﹐為電影挽回不少分數。其實黃精甫乃可成大器之材﹐他只是久缺一個好戲本。

Google 2.4% Rate Shows How $60 Billion Lost to Tax Loopholes

Corporate tax law just create jobs for tax lawyers and accountants and won’t bring in much revenue to the government. Why don’t they simply scrape corporate tax and tax personal income of the executives instead. The executives cannot move away and any transfer of wealth between the company and individual is more traceable.

By Jesse Drucker, Bloomberg, Oct 21 2010

Google Inc. cut its taxes by $3.1 billion in the last three years using a technique that moves most of its foreign profits through Ireland and the Netherlands to Bermuda.

Google’s income shifting — involving strategies known to lawyers as the “Double Irish” and the “Dutch Sandwich” — helped reduce its overseas tax rate to 2.4 percent, the lowest of the top five U.S. technology companies by market capitalization, according to regulatory filings in six countries.

“It’s remarkable that Google’s effective rate is that low,” said Martin A. Sullivan, a tax economist who formerly worked for the U.S. Treasury Department. “We know this company operates throughout the world mostly in high-tax countries where the average corporate rate is well over 20 percent.”

The U.S. corporate income-tax rate is 35 percent. In the U.K., Google’s second-biggest market by revenue, it’s 28 percent.

Google, the owner of the world’s most popular search engine, uses a strategy that has gained favor among such companies as Facebook Inc. and Microsoft Corp. The method takes advantage of Irish tax law to legally shuttle profits into and out of subsidiaries there, largely escaping the country’s 12.5 percent income tax. (See an interactive graphic on Google’s tax strategy here.)

The earnings wind up in island havens that levy no corporate income taxes at all. Companies that use the Double Irish arrangement avoid taxes at home and abroad as the U.S. government struggles to close a projected $1.4 trillion budget gap and European Union countries face a collective projected deficit of 868 billion euros.

Countless Companies

Google, the third-largest U.S. technology company by market capitalization, hasn’t been accused of breaking tax laws. “Google’s practices are very similar to those at countless other global companies operating across a wide range of industries,” said Jane Penner, a spokeswoman for the Mountain View, California-based company. Penner declined to address the particulars of its tax strategies.

Facebook, the world’s biggest social network, is preparing a structure similar to Google’s that will send earnings from Ireland to the Cayman Islands, according to the company’s filings in Ireland and the Caymans and to a person familiar with its plans. A spokesman for the Palo Alto, California-based company declined to comment.

Transfer Pricing

The tactics of Google and Facebook depend on “transfer pricing,” paper transactions among corporate subsidiaries that allow for allocating income to tax havens while attributing expenses to higher-tax countries. Such income shifting costs the U.S. government as much as $60 billion in annual revenue, according to Kimberly A. Clausing, an economics professor at Reed College in Portland, Oregon.

U.S. Representative Dave Camp of Michigan, the ranking Republican on the House Ways and Means Committee, and other politicians say the 35 percent U.S. statutory rate is too high relative to foreign countries. International income-shifting, which helped cut Google’s overall effective tax rate to 22.2 percent last year, shows one way that loopholes undermine that top U.S. rate.

Two thousand U.S. companies paid a median effective cash rate of 28.3 percent in federal, state and foreign income taxes in a 2005 study by academics at the University of Michigan and the University of North Carolina. The combined national-local statutory rate is 34.4 percent in France, 30.2 percent in Germany and 39.5 percent in Japan, according to the Paris-based Organization for Economic Cooperation and Development.

The Double Irish

As a strategy for limiting taxes, the Double Irish method is “very common at the moment, particularly with companies with intellectual property,” said Richard Murphy, director of U.K.- based Tax Research LLP. Murphy, who has worked on similar transactions, estimates that hundreds of multinationals use some version of the method.

The high corporate tax rate in the U.S. motivates companies to move activities and related income to lower-tax countries, said Irving H. Plotkin, a senior managing director at PricewaterhouseCoopers LLP’s national tax practice in Boston. He delivered a presentation in Washington, D.C. this year titled “Transfer Pricing is Not a Four Letter Word.”

“A company’s obligation to its shareholders is to try to minimize its taxes and all costs, but to do so legally,” Plotkin said in an interview.

Boosting Earnings

Google’s transfer pricing contributed to international tax benefits that boosted its earnings by 26 percent last year, company filings show. Based on a rough analysis, if the company paid taxes at the 35 percent rate on all its earnings, its share price might be reduced by about $100, said Clayton Moran, an analyst at Benchmark Co. in Boca Raton, Florida. He recommends buying Google stock, which closed yesterday at $607.98.

The company, which tells employees “don’t be evil” in its code of conduct, has cut its effective tax rate abroad more than its peers in the technology sector: Apple Inc., the maker of the iPhone; Microsoft, the largest software company; International Business Machines Corp., the biggest computer-services provider; and Oracle Corp., the second-biggest software company. Those companies reported rates that ranged between 4.5 percent and 25.8 percent for 2007 through 2009.

Google is “flying a banner of doing no evil, and then they’re perpetrating evil under our noses,” said Abraham J. Briloff, a professor emeritus of accounting at Baruch College in New York who has examined Google’s tax disclosures.

“Who is it that paid for the underlying concept on which they built these billions of dollars of revenues?” Briloff said. “It was paid for by the United States citizenry.”

Taxpayer Funding

The U.S. National Science Foundation funded the mid-1990s research at Stanford University that helped lead to Google’s creation. Taxpayers also paid for a scholarship for the company’s cofounder, Sergey Brin, while he worked on that research. Google now has a stock market value of $194.2 billion.

Google’s annual reports from 2007 to 2009 ascribe a cumulative $3.1 billion tax savings to the “foreign rate differential.” Such entries typically describe how much tax U.S. companies save from profits earned overseas.

In February, the Obama administration proposed measures to curb shifting profits offshore, part of a package intended to raise $12 billion a year over the coming decade. While the key proposals largely haven’t advanced in Congress, the IRS said in April it would devote additional agents and lawyers to focus on five large transfer pricing arrangements.

Arm’s Length

Income shifting commonly begins when companies like Google sell or license the foreign rights to intellectual property developed in the U.S. to a subsidiary in a low-tax country. That means foreign profits based on the technology get attributed to the offshore unit, not the parent. Under U.S. tax rules, subsidiaries must pay “arm’s length” prices for the rights — or the amount an unrelated company would.

Because the payments contribute to taxable income, the parent company has an incentive to set them as low as possible. Cutting the foreign subsidiary’s expenses effectively shifts profits overseas.

After three years of negotiations, Google received approval from the IRS in 2006 for its transfer pricing arrangement, according to filings with the Securities and Exchange Commission.

The IRS gave its consent in a secret pact known as an advanced pricing agreement. Google wouldn’t discuss the price set under the arrangement, which licensed the rights to its search and advertising technology and other intangible property for Europe, the Middle East and Africa to a unit called Google Ireland Holdings, according to a person familiar with the matter.

Dublin Office

That licensee in turn owns Google Ireland Limited, which employs almost 2,000 people in a silvery glass office building in central Dublin, a block from the city’s Grand Canal. The Dublin subsidiary sells advertising globally and was credited by Google with 88 percent of its $12.5 billion in non-U.S. sales in 2009.

Allocating the revenue to Ireland helps Google avoid income taxes in the U.S., where most of its technology was developed. The arrangement also reduces the company’s liabilities in relatively high-tax European countries where many of its customers are located.

The profits don’t stay with the Dublin subsidiary, which reported pretax income of less than 1 percent of sales in 2008, according to Irish records. That’s largely because it paid $5.4 billion in royalties to Google Ireland Holdings, which has its “effective centre of management” in Bermuda, according to company filings.

Law Firm Directors

This Bermuda-managed entity is owned by a pair of Google subsidiaries that list as their directors two attorneys and a manager at Conyers Dill & Pearman, a Hamilton, Bermuda law firm.

Tax planners call such an arrangement a Double Irish because it relies on two Irish companies. One pays royalties to use intellectual property, generating expenses that reduce Irish taxable income. The second collects the royalties in a tax haven like Bermuda, avoiding Irish taxes.

To steer clear of an Irish withholding tax, payments from Google’s Dublin unit don’t go directly to Bermuda. A brief detour to the Netherlands avoids that liability, because Irish tax law exempts certain royalties to companies in other EU- member nations. The fees first go to a Dutch unit, Google Netherlands Holdings B.V., which pays out about 99.8 percent of what it collects to the Bermuda entity, company filings show. The Amsterdam-based subsidiary lists no employees.

The Dutch Sandwich

Inserting the Netherlands stopover between two other units gives rise to the “Dutch Sandwich” nickname.

“The sandwich leaves no tax behind to taste,” said Murphy of Tax Research LLP.

Microsoft, based in Redmond, Washington, has also used a Double Irish structure, according to company filings overseas. Forest Laboratories Inc., maker of the antidepressant Lexapro, does as well, Bloomberg News reported in May. The New York-based drug manufacturer claims that most of its profits are earned overseas even though its sales are almost entirely in the U.S. Forest later disclosed that its transfer pricing was being audited by the IRS.

Since the 1960s, Ireland has pursued a strategy of offering tax incentives to attract multinationals. A lesser-appreciated aspect of Ireland’s appeal is that it allows companies to shift income out of the country with minimal tax consequences, said Jim Stewart, a senior lecturer in finance at Trinity College’s school of business in Dublin.

Getting Profits Out

“You accumulate profits within Ireland, but then you get them out of the country relatively easily,” Stewart said. “And you do it by using Bermuda.”

Eoin Dorgan, a spokesman for the Irish Department of Finance, declined to comment on Google’s strategies specifically. “Ireland always seeks to ensure that the profits charged in Ireland fully reflect the functions, assets and risks located here by multinational groups,” he said.

Once Google’s non-U.S. profits hit Bermuda, they become difficult to track. The subsidiary managed there changed its legal form of organization in 2006 to become a so-called unlimited liability company. Under Irish rules, that means it’s not required to disclose such financial information as income statements or balance sheets.

“Sticking an unlimited company in the group structure has become more common in Ireland, largely to prevent disclosure,” Stewart said.

Deferred Indefinitely

Technically, multinationals that shift profits overseas are deferring U.S. income taxes, not avoiding them permanently. The deferral lasts until companies decide to bring the earnings back to the U.S. In practice, they rarely repatriate significant portions, thus avoiding the taxes indefinitely, said Michelle Hanlon, an accounting professor at the Massachusetts Institute of Technology.

U.S. policy makers, meanwhile, have taken halting steps to address concerns about transfer pricing. In 2009, the Treasury Department proposed levying taxes on certain payments between U.S. companies’ foreign subsidiaries.

Treasury officials, who estimated the policy change would raise $86.5 billion in new revenue over the next decade, dropped it after Congress and Treasury were lobbied by companies, including manufacturing and media conglomerate General Electric Co., health-product maker Johnson & Johnson and coffee giant Starbucks Corp., according to federal disclosures compiled by the non-profit Center for Responsive Politics.

Administration Concerned

While the administration “remains concerned” about potential abuses, officials decided “to defer consideration of how to reform those rules until they can be studied more broadly,” said Sandra Salstrom, a Treasury spokeswoman. The White House still proposes to tax excessive profits of offshore subsidiaries as a curb on income shifting, she said.

The rules for transfer pricing should be replaced with a system that allocates profits among countries the way most U.S. states with a corporate income tax do — based on such aspects as sales or number of employees in each jurisdiction, said Reuven S. Avi-Yonah, director of the international tax program at the University of Michigan Law School.

“The system is broken and I think it needs to be scrapped,” said Avi-Yonah, also a special counsel at law firm Steptoe & Johnson LLP in Washington D.C. “Companies are getting away with murder.”