Tag Archives: google

拉開智能家居科技大戰的序幕,試玩Google Home Mini

智能電話市場接近飽和,手機在功能上的創新已漸漸走到盡頭,蘋果和Google成為這場科技戰役的贏家。下一個科技戰場將會是智能家居,那間科技公司能攻佔你的客廳,便是新一代科技市場的霸主。Sony和微軟曾經幻想用遊戲機打入客廳,不過遊戲機價格昂貴,除了死忠玩家外一般家庭不會買,此路不通註定失敗。早兩年Amazon異軍突起,靠著智能喇叭Alexa殺出藍海,高規格的大喇叭才買二百美元,吸引不少科技發燒友買來玩。去年推出的低價Echo和Dot,才買幾十美元一個,一時間差不多人手一部獨佔市場。

到今年Google和蘋果也不今後人,相繼推出自家的智能喇叭。Amazon的智能喇叭是玩物,基本上沒有多大實際用途。雖說可以控制家居電器開關,但智能電器價錢高昂,買個智能燈膽仲貴過個Echo,市場目前還未成氣候。Alexa是唯一用途就是聲控聽歌,不過首先你要是Prime會員。Google和蘋果在電話上早有聲控系統,把Siri和Google Assistant移植去智能喇叭相對容易,還有讓智能喇叭與電話功能連結,比起Alexa更有買點。可惜蘋果臨門甩腳,HomePod要明年才出貨,還要買成三百幾美元,結果讓Google先飲頭淡湯,在今個聖誕購物檔期,趁機搶佔智能家居的市場。

一舊圓碌碌

Google與Amazon的定價策略一樣,大舊靚聲喇叭做生招牌,主力是靠平價細喇叭搶市場。今個感恩節黑色星期五做特價,Google Home Mini大平買,三十美元有找。買個普通藍芽喇叭也是差不多價錢,想也不用想便買了Mini來試玩。開箱沒有什麼可以報告,一舊圓碌碌布面Home Mini,加多一舊圓碌碌的叉電器。安裝十分容易,插電,等四粒LED閃下閃下,在手機上下載Google Home個App,開app立即自動pair up,登入你個Google account,幫Mini入Wi-Fi密碼,之後對住電話講幾次「OK Google」和「Hey Google」,咁就可以用。

Google Home基本上同手機版的Google Assistant沒有分別,你可以問Google Search,問天候,問新聞,問股市,問交通消息,可以口講寫短訊電郵,更新行事日曆,設定提示或鬧鐘等等。我是Spotify會員,可以叫Mini播歌,又可以叫佢播收音機,北美當地的電台故然有,想不到有香港電台同新城聽。我沒有買Chromecast不能叫佢播Youtube或Netflix(Chromecast都有做特價,攪到我又想買添),我家又沒有智能電器,沒有什麼可以操控。目前Google Home不支援中文,不過Google的語音識別非常強勁,完全聽得明我的香港口音英文。

Google Home Mini放在電視機前面

Google Home還有兩項殺手鐧。第一是它可用來打電話,免費任打北美任何號碼,Mini當免提電話使用。第二是它支援不同家庭成員的聲音,我老婆用iPhone,下載了iOS版本的Google Home App,設定好她的account後,Mini認得出我和她不同的聲音,問它行事日曆或叫打電話時,懂得使用不同人的account,這點比起Alexa更勝一籌。我把Mini放在客廳電視機前,它的音質清楚夠大聲,但不要有不切實際的期望,始終只是一個細喇叭。收音非常準確,在有播放背景音樂的情況下,可以坐在沙發上以普通說話的聲線發號司令。

智能家居這一場科技大戰,今個聖誕購物檔期正式拉開序幕。目前Amazon排頭位領先,不過Google憑著手機和Gmail的生態系統,配合割價速銷搶佔市場,坐穩第二位然後急起直追,有望重現當年Andriod強攻打下iOS的情況。蘋果還在起跑線準備開砲,不知道一出閘狀態會如何。論佈局Amazon和Google最好,把語音技術開放授權給其他喇叭廠商使用,買喇叭從來不是重點。把用家綁定在他們的生態系統才是重點。蘋果把HomePod定位為高級無線喇叭,而非智能助理,是否看錯了市場趨勢呢?

Google Daydream VR 初玩感想 – 虛擬實境會步3D的後塵嗎?

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買了Pixel電話,沒有理由不買Daydream View。Daydream未推出時已經預定,美國出了好幾個星期,等到頸到長終於收貨。急不及待,馬上開來玩。身在公司,為免玩VR的傻樣被拍下來公諸於世,當然不能在座位玩,book間會議室躲起來玩。返工時玩耍倒沒有所謂,在高科技公司工作,只要準時交到貨,基本上不返工也沒有問題。開盒沒有什麼驚喜,未到手前上網早已看過不少開盒報告,不過VR這玩意,讀他人的文字完全不能身同感受,要自己試過才有知好壞。

15192556_10154552264280269_1350863380915190959_n 布織VR眼罩和遙控器

15284180_10154552264295269_1647874060556351606_n 可以把遙控器放入眼鏡收藏

15220178_10154552264340269_5049843559083814150_n 外觀有點像滑雪鏡

除了在商場試過三叔的VR Gear幾分鐘外,我沒有玩過其他VR,所以無從比較優劣。Daydream眼鏡十分輕盈,初戴時覺得對焦不準,後來上網看正確的戴法,才知那條帶不是放在耳仔上,而是要像戴滑雪鏡般放在額旁。下載Daydream的App後,把部電話放入去作螢幕。我的Pixel不是XL,解像度不是最高,放入去看VR會看到LCD點陣的網紋,看多一陣眼睛自動適應,除非特別去留心看,玩時腦袋會自動無視網紋。據網上說用XL也會看到網紋,只是網點細些比較難察覺。玩VR原來是要帶眼鏡,雖然個電話放得很近,但那塊鏡片把焦距拉遠,大約等於平時看書的距離。如果你近視深,不帶眼鏡看不到字,那玩VR時就要帶眼鏡。由於Daydream用布做,可以在VR內戴普通眼鏡,戴時有少少技巧,把眼鏡放入VR對正才戴上面,就不會不舒服。那其他用硬膠殼的VR系統,是否要戴隱形眼鏡才可以玩?由於Daydream用布做,VR眼罩鼻位有空隙會漏光(大慨設計要照顧鬼佬的高鼻樑),解決方法很簡單,把房間的燈關掉了就可以,反正玩VR都係一個人自己玩。

15235359_10154558287445269_1304156188857872367_o 系統教學模式

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初次使用時有教學模式,基本上是在show off技術。把玩家放在一個虛擬森林內,叫玩家轉頭追看蝴蝶飛夢,抬頭看天上的星星,又把遙控器當電筒用,照森林中的各種動物。畫面非常流暢,轉頭時完全感覺不到有lag,同三年前用Nexus 5玩Cardboard有天淵之別,當年lag到頭暈。遙控器手感還可以,主要是用來指畫面當mouse用,靈敏度大慨和Wii控制器差不多。目前Google的VR平台並只有很少app,最失策是不支援舊有的Cardboard apps。我看了不少Youtube VR的360影像,下載了幾個免費VR App來玩,還買了一個恐怖類遊戲,然後趕在半小時內退貨不收錢。玩了個多小時,眼睛便已十分疲累,好像開通宵長途車般辛苦,該是時候休息回去工作了。玩VR十分食電,電話非常溫暖,不過這都是意料中事。有點意外是玩VR不能用藍芽耳機,因為藍芽同樣食電,玩了十幾分鐘後Daydream自動提示電話過熱,要我轉回用有線耳筒。

15304628_10154558287420269_4668906876678167971_o 虛擬博物館

15259209_10154558287430269_5260076932932947002_o 360度看球賽

15259499_10154558287585269_8143722669207502736_oBBC的怪獸VR遊戲

親身深度試玩過VR後,我預測VR將會是另一個3D,在一輪hype過後,市場便會尋找更新奇好玩的東西。事實上VR有著3D相同的死症,就是看得長時間眼睛會很累。有些所謂的「大屏幕」的VR app簡直是除褲放屁,戴著VR眼罩文字或2D影片很辛苦,我寧可在廿四吋大芒看得舒服。看360度影像很有趣,頭鱷鱷可以看鏡頭後面,但新鮮感過後,其實鏡頭後面沒有什麼好看。例如看球賽當然是向前望看比賽,擰轉頭看其他觀眾來幹什麼。VR唯一的生存空間是打機,開賽車,揸飛機用VR玩很有代入感。恐怖遊戲與VR簡直完美結合,坐在梳化對著電視玩不會太驚,始終你知道電視入面是另一個世界, 用VR玩則完全不同感覺,真的以自己處身遊戲之中,好驚驚。至於其他遊戲類別,我想不到VR有什麼優勢,電子競技類的講操控準確,VR對一心求勝的玩家只是分心負累。運動類遊戲走Wii和Kinect的老路,新鮮感過後不能留著玩家。戴VR的膠樣和眼罩的衛生問題,VR也吃不到Wii和Kinect的party game市場。至於動作射擊類遊戲,對於玩開實彈射擊的我,射擊遊戲根本是個笑話,感覺與現實相差太遠了。只靠模擬和恐怖類遊戲,市場夠不夠養起VR開發商呢?我不太樂觀。

Oculus,Vive和PS4 VR那些獨立VR系統,除非真是深度玩家發燒友,買了回來若覺得不好玩,幾百美元就浪費了。用手機為平台的VR,過多兩年入門級手機也合乎Daydream的規格,Daydream View一百美元不到,遲些第三方廠商或山寨貨肯定更平,如果手機技援VR的話,不妨平平地買個VR眼罩回來試玩。只要每次不玩多過半小時,玩VR應該不會傷眼吧。

Google Pixel 第一天實戰測試

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望穿秋水,終於等到Google Pixel寄到。我是Google手機的忠實擁躉,先後擁有平價王Nexus 5,和Mo記大機Nexus 6。三叔,小米那些不是純正統血的Andriod,只有Google原味版才是正宗。開盒報告不用我寫,網上有很多影片可以看。有趣是跟機有兩條USB-C線,一條兩邊都是USB-C頭,用來插叉電器,另一條是舊USB-A大頭,用來插電腦。有一舊細USB-A to USB-C dongle,說明書是用來駁iPhone條lighting線,讓iPhone用家可以一鍵把資料轉到Pixel上。盒內沒有耳機,其實那些跟電話的平價耳機大部份是垃圾,家中堆了不少,Google索性不送,一來可以省成本,二來減少癈物,夠環保。

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開機亳無驚喜,與其他Andriod機一樣,登入Google賬戶,自動把你用開的apps裝過來。我買細芒32GB最平價的型號,夠用就可以了。我喜歡五吋機,大機放入褲袋梗著不舒服。以前用Nexus時,大部份storage都是用來裝相片和影片,Pixel送無限Google Drive相片和影片原size儲存,除非長時間offline才需要128GB。雖說是32GB機,但除去OS後,還有27GB左右。我部Nexus跌爛了後,用了先後用了兩台16GB的平價Andriod機(Moto E2和Samsung某平價型號),完全滿足到日常工作需要,只是沒有空間安裝遊戲,電話不能打機。我不是重度手機遊戲玩家,同一時間只會玩一兩個遊戲,玩完就刪,32GB夠用有餘。

昨晚安裝好apps後,沒有什麼時間測試。今天如常用了一天,早上七點斷電,整天正常用量,開車時聽下Spotify,無聊時上網,正常用量講幾個電話,不過影了好多相測試功能,又成日玩OK Google語音助手,五點回家還有50%電。與我以前的電話比較,部Nexus 6很大食,用一日只剩30-40%,而四吋芒的Moto E2非常省電,用一日還有70%,Pixel中中間間,不算很大食,但亦不是省電。網上廣告主打的Google Assistant,老實說我不覺得有什麼特別,不就是上一代的Google Now換了新衣,以前好用現在一樣好用,新功能不用開機都可以聽指令就真係幾方便。

Pixel的賣點只有一個,就是部相機非常強勁,冠絕所有Andriod機,同iPhone7可以一較高下,所以與iPhone7同價亦非無道理。電腦雜誌甚至給Pixel相機的評分比iPhone7還高幾分,不過我就看不出有什麼分別。天朗氣清影靜態畫面,任何中價手機以上沒有分別。Pixel的相機勁在,低光暗的環壞下,拍出的照片非常清晰。第一張相是昨晚隨手影阿仔的Lego,客廳沒有開大燈,只有一盞LED裝飾燈,暗到看書都看不到,影出來顏色很清楚。第二張相是返工地下停車場影,影出來的效果與其他手機拍戶外差不多。最後一張是放工停紅燈,見到運車車覺得有趣,拿起手機便拍,打開相機app和快門都非常快,用以前的手機架車走了個app都未load完。另外一秒十二張HDR連環快拍超強,按著個相機製便擦擦聲不停拍,張張都拍得非常清楚,不過拍完後感覺到部機有點暖,因為HDR要用很多CPU。

Pixel值不值得買?如你好似我,是Google的死忠,一定要買。如果你用開Android機又有錢,這部是最好沒有第二的Android機,好過用會爆炸的三叔,唔知有冇偷你資料的大陸機。果粉當然一定不會買,Pixel目前還未目超越iPhone的必殺技,不過下個月Daydream出街,有可能靠VR一起蘋果尾注。至於不介意手機OS用什麼的朋友,通街都係iPhone亳無新意,出部Pixal可以扮hi-tech友以示與眾不同,至少別人問你點解買Andriod機,不用答因為買不起iPhone咁失禮。

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Nexus 5

My old first generation Samsung Galaxy S is at the end of its life, it is so slow that it becomes unusable. I have been waiting for the new Nexus 5 since rumors shows up in the summer. The Nexus 5 exactly fit my need. a no-frill unlock phone at a very reasonable price. The hardware specification of Nexus 5 is comparable to flagship phone from Samsung, HTC or Sony, but it’s almost $200 cheaper. The best of all, I know I will always have the latest Android OS update.

When Google announced Nexus 5 on Halloween, I ordered it once it is available on the Play Store. I believe my order is one of the first shipment. I got my Nexus 5 last Friday. Before I had my new phone, I already read tons of review on the web, so nothing comes up as surprise since I know exactly what to expect. The phone has the fastest CPU in the market, it runs very fast compare to my old Captivate, but I couldn’t tell much speed difference from my Nexus 7.

The battery capacity is not as big as Samsung or HTC, but good enough. On the first day after I got the phone, I unplugged it at 7am and it runs out of juice around 6pm after of a full day almost non-stop use. Today is a normal work day, I left the WiFi and LTE enabled, made a few phone calls, go online a little bit during breaks, and I still 70% of battery at the end of the day. No bad.

The major disadvantage of Nexus 5 is the camera. It is good, but not great. Definitely not as good as other flagship photos. The optical image stabilizer works well when you are taking still photos and try to hold your hand steady, but it not so useful if you are taking action shot. The auto-focus is very slow, can’t really capture my son’s movement fast enough. I read on the web it is a software problem, so hopefully it will be fixed in the next update.

I don’t see any special feature of Android 4.4 KitKat. Google changed the home screen again, and make it fully integrated with Google Now. I can say “OK Google” to the phone under home screen and it will start Google Now automatically, no need to press any button. I think it is more like a gimmick and it only works on English(US), not even English(Canada). Does “OK Google” sounds very different in Canada compare to the States? I really miss the customization enhancement of the Cyanogenmod, I am so used to the short cut icons on the lock screen and configurable docks screen in the launcher. The true gem of Android 4.4 is the ART compiler hidden under developer features, which runs much faster than the Dalvik pre-compiler in other Android. Too bad that it crashes WhatsApp, so I can’t turn it on until WhatsApp fix the problem.

The lack of a SD-card slot is always a sore point in Nexus line of devices. But base on my previous experience with my old Captivate, which has support SD-card, I probably won’t miss it that much given that I ordered the 32GB model. The internal memory is more than enough for photos and mp3. After 3 years of use, I didn’t even fill up the internal 16GB of memory of my old phone. The external SD-card ends up being used as a dump for mp3s that I rarely listen and too lazy to delete. The only scenario I would ever need more storage space is storing movies during flight, but I can always solve the problem by using an OTG-USB SD card reader.

Overall, I am very happy with my new Nexus 5, but it is not a phone for everyone. It lacks the bells and whistles of Samsung or HTC, it is not an exciting phone, it is just a plain work horse phone. It totally does not make sense to get a subsidize Nexus 5 from the carrier and lock yourself into a 2 years contract. The last bit of dilemma of owning a Nexus 5 is about to flash or not to flash, that is the question. Since I am always getting the new OS upgrade, I don’t have a need to flash the phone. On the other hand, I do miss the enhancement of other customer ROM. I guess I just need to find a way to install launcher and lock slider from Cyanogenmod without replacing the OS. I tried install the launcher from CM10.2, which is based on Android 4.3, but it does not work well, it crash when I tried to configure the screen size.  I guess I have to wait until CM11 is released and try again.

Nexus 7 (2013)

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Finally the wait is over, I bought my first tablet. I’ve been waiting for the right one for over a year, I want a tablet with powerful specification and yet at a reasonable price. The iPad is way over my budget, and I don’t like the gimmicky line-up from Samsung. The first Nexus 7 almost meet my requirements, but I want a better display and a more powerful CPU.

The new Nexus 7 is just the right answer. It has higher pixel density than Apple’s retina display, the same resolution as my 24″ monitor. The CPU is top of the line quad core Qualcomm processor, on par with the flag ship smartphones like Galaxy s4 or HTC one. I bought the 16G model since the 32G model is not yet available in Canada, and lack of a micro slot is probably the biggest down side of the nexus 7. I intend to use it mostly at home, where I can stream files directly from my computer, so I am not very concern about the storage size. When I am traveling, I am get an USB cable and use external thumb drive, it is not very elegant but it works fine.

I pre-order my Nexus 7 from Bestbuy.ca and I got my tablet delivered right on July 30th, the first day that the Nexus 7 is on sale. (It already sold out, for now) I ready have an Android phone, so setting up the Nexus 7 is pretty straight forward. Log into my Google account and all my existing apps are downloaded and installed automatically. The tablet is up and running within 10 minutes. It feels just like my old phone, except it runs much smoother and has a bigger screen. I can’t tell anything real different in the new Android 4. , in fact I miss those little handy customization of Cyanogenmod 10.1, such as lock screen shortcuts, scrollable dock bar, etc.

The Nexus 7 lacks the wow factor, when I show it off to my colleagues, their comment is yet another Android tablet. My wife is not impressed by its relatively small size, she thinks only a 10″ iPad is a real tablet. It seems the only person fascinated by the Nexus 7 is baby Marcus, he prefer it over my old Android phone and mom’s iPhone 5, probably just because the Nexus 7 is bigger. I am quite happy with my new tablet, I don’t have to sit in front of the computer to surf the web or watch video. I am actually writing this blog using the tablet lying on the sofa. Typing with the on screen keyboard is not as fast as using a real keyboard, but good enough for light usage.

I am looking for a few accessories for my Nexus 7. First I need case and cover if I want to carry it with me outside of the house. Then I need to get a Bluetooth keyboard, so I can replace my laptop for simple note taking or writing tasks. Last I want to get a USB docking station to charge the tablet on my desk.

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.”

Google 411

Whenever I used 411 to look up the phone number I need, I always feel being ripped off by the telephone company. The information is free out there on the internet, yet my mobile carrier charges me 50 cents for each call. Now, I don’t have to up with my frustration with the 411 operators anymore, here it comes the Google 411.

Call 1-800-GOOG-411 (1-800-466-4411), you are greeted with a computer voice asking for the business or phone number you are looking for. You simply say the location and business name, Google will redirect your call to the destination. No more long distance fee if you are trying to call a business out of town. Google 411 supports all US and Canada numbers but it only works in English. I tried calling my office with Google 411, it works like a charm. It can even understand my not so perfect Chinese-accented English. If you are calling form a smart phone, you can even ask Google 411 send you a map of the number you looked up.

I wonder how Google is making money off from this great service. It does not have any advertisement at the moment, but I think people won’t mind listening to a few seconds of advertisement before getting the number. I read a bit more about Google 411 and it turns out totally not what I expected it to be. Google has no intention to make any money from this service, they are not even consider selling advertisement. The service is a giant experiment to build a huge phoneme database to train their super voice recognition system. What else is better than giving a free service and get all sorts of people with different accents call and leave you their voice?

Google Wave

Google like to release their new service to the public while it is still in beta. Gmail and Google Talk was in beta for a few years before it finally make an official release. Google Wave is the latest invention from Google. It is aim to revolutionize how people communication. Google is looking forward to make it the next big success after gmail.

The concept of Google Wave is a bit hard to understand at first. I am still a bit confused after watching the introduction on Youtube. After playing with it for a few hours, I think in short it takes the best out of email, MSN, Wiki and merge it into one single service. It comes with a very clean web interface, as expected from Google. The basic function of wave is pretty simple, it allows multiple users edit the same “wave” at the same time and broadcast the change in real time. It saves the complete history, so any user can replay the changes step by step. I think the hidden jem would be the Wave API, it let user embed “wave” in any webpage and insert wave plugins or bot scripts in a “wave”. I am still exploring the Wave API. Google Wave is still in a very early stage, no one knows how can it change the way we communicate. Would it be a run away success like Gmail or just drop flat like Google Talk.

I would like to embed a wave in this post for demonstration. Unfortunately, I would not get the WordPress wave plug-in working after many tries.

BTW, I still have two invitation quota left. Any one interested please let me know.