Comment by jotras
1 month ago
Something nobody's talking about: OpenAI's losses might actually be attractive to certain investors from a tax perspective. Microsoft and other corporate investors can potentially use their share of OpenAI's operating losses to offset their own taxable income through partnership tax treatment. It's basically a tax-advantaged way to fund R&D - you get the loss deductions now while retaining upside optionality later. This is why the "cash burn = value destruction" framing misses the mark. For the right investor base, $10B in annual losses at OpenAI could be worth $2-3B in tax shields (depending on their bracket and how the structure works). That completely changes the return calculation. The real question isn't "can OpenAI justify its valuation" but rather "what's the blended tax rate of its investor base?" If you're sitting on a pile of profitable cloud revenue like Microsoft, suddenly OpenAI's burn rate starts looking like a pretty efficient way to minimize your tax bill while getting a free option on the AI leader. This also explains why big tech is so eager to invest at nosebleed valuations. They're not just betting on AI upside, they're getting immediate tax benefits that de-risk the whole thing.
> For the right investor base, $10B in annual losses at OpenAI could be worth $2-3B in tax shields (depending on their bracket and how the structure works). That completely changes the return calculation
I know nothing about finances at this level, so asking like a complete newbie: doesn't that just mean that instead of risking $10B they're risking $7-8B? It is a cheaper bet for sure, but doesn't look to me like a game changer when the range of the bet's outcome goes from 0 to 1000% or more.
It all depends on the actual numbers. Consider this simplified example: If you are offered a deal that requires you to lay down 10 billion today and it has a 5% chance to pay out 150 billion tomorrow, your accountants will tell you not to take this deal because your expected return is -2.5 billion. But if you can offset 3 billion in cost to the tax payer, your expected return suddenly becomes $500 million, making it a good deal that you should take every time.
I get that this example is simplified, but doesn’t the maths here change drastically when the 5% changes by even a few percentage points? The error bars on Openais chance of succes are obviously huge, so why would this be attractive to accountants?
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This applies to any spending Microsoft does. What does it have to do with OpenAI?
Also, classifying business expenses as "cost to the tax payer" seems less than useful, unless you are a proponent of simply taxing gross receipts. Which has its merits, but then the discussion is about taxing gross receipts versus income with at least some deductible expenses, not anything to do with OpenAI.
Those 150 billion will be taxable at the same (hypothetically 30%) tax rate, reducing the expected return by 45bn * 5% chance. The expected return is still negative; all this bet does is shift tax liabilities in time, which admittedly would matter to some people who subscribe to short-termism.
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Thank you, that made perfect sense and in a very simple (simplified but relevant) way. Besides the idea that such risks get aggregated over a portfolio, I can also imagine how the raw numbers flipping from - to + may be useful to paint as acceptable to accounting a bet you want to take anyway for strategic reasons.
If your accountants suggest that you take a single 5% chance deal, they probably skipped maths and statistics and you should fire them.
It's the dumb as rocks MBAs that will go head first into the 5% chance deal.
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The taxes on returning profits to investors via dividends are quite high. You’d be looking at the corporate tax rate (35%) + the dividend tax rates (between 15 and 35%). For any company which may need to raise equity finance later, this is an awful deal - but growing a cash balance doesn’t do the job either.
So MSFT is effectively getting 2x the equity by putting money into OpenAI, it also conveys some financial engineering capability as they can choose to invest more when profits are high to smooth out cash flow growth.
>The taxes on returning profits to investors via dividends are quite high.
isn't that what buybacks are for?
That just doesn't sound right. This kind of thought process only works if you think you are guaranteed more than that the next year. It only works in crony capitalism where your friends in government put money in your pockets. It's where we are right now, but definitely not something that is sustainable or something to aspire to.
Your intuition is exactly correct. An investor with tax to offset can essentially access the same future upside at a discount
However, this discussion will be a perfect introduction to "finances at this level", where about 60% of the action is injecting more variables until you can fit a veneer of quantification onto any narrative.
If that $7-8 billion is spent on Azure, then it's basically a way to invest in data center capacity while also getting a big piece of Open AI ownership at the same time.
Är the same time, MS revenues are looking real good, causing the stock price to go up. It's a win win win maybe win huge situation.
>> For the right investor base, $10B in annual losses at OpenAI could be worth $2-3B in tax shields
So just a loss for governments, or in other words, socializing the losses.
OpenAIs losses are someone else's (taxed) earnings.
Hi, I'm here to hold the bag?
We really should have thought of this before becoming peasants.
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You guys are getting bags?
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Your pension fund, yes.
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>So just a loss for governments, or in other words, socializing the losses.
How's that different than any other sort of R&D incentive? Would you rather that companies return as much money as possible to shareholders, future growth be damned? What about other sorts of tax incentives, which by definition also "just a loss for governments"? Are tax breaks for people with kids also "socializing the losses", given that most households don't have kids?
I call it theft when the government steals money from people without kids to enrich parents.
No, because income equals expenditure. They are one and the same.
Private industry loses 10B. Governments mostly affected as they have less free money to extract.
Amazon already has not been paying any sort of income tax to the EU. There was a lawsuit in Belgium but Amazon has won that in late-2024 since they had a separate agreement in/with Luxembourg.
Speaking for EU, all big tech already not paying taxes one way or another, either using Dublin/Ireland (Google, Amazon, Microsoft, Meta, ...) and Luxembourg (Amazon & Microsoft as far as I can tell) to avoid such corporate/income taxes. Simply possible because all the earnings go back to the U.S. entity in terms of "IP rights".
> Amazon already has not been paying any sort of income tax to the EU.
That should be expected, because
https://european-union.europa.eu/priorities-and-actions/acti...
> The EU does not have a direct role in collecting taxes or setting tax rates.
> There was a lawsuit in Belgium but Amazon has won that in late-2024 since they had a separate agreement in/with Luxembourg.
Dec 2023.
> Speaking for EU, all big tech already not paying taxes one way or another, either using Dublin/Ireland (Google, Amazon, Microsoft, Meta, ...) and Luxembourg (Amazon & Microsoft as far as I can tell) to avoid such corporate/income taxes. Simply possible because all the earnings go back to the U.S. entity in terms of "IP rights".
Ireland (due to pressure from EU) closed this in 2020. The amount of tax collected by Ireland quadrupled. See Figure 5 and 6 in link below.
https://budgetmodel.wharton.upenn.edu/issues/2024/10/14/the-...
> any sort of income tax to the EU.
Its clear that OP means "in the EU".
> Ireland (due to pressure from EU) closed this in 2020. The amount of tax collected by Ireland quadrupled. See Figure 5 and 6 in link below.
And Ireland fought against this tooth and nail. Yes, a country was fighting to have less income. All out of fear that the companies will leave the little tax heaven. Did they leave? No ...
> See Figure 5 and 6 in link below.
Figure 7 is also interesting if we look at the tax income increase and the outbound.
I find it funny because;
1. Amazon reports 250bn$+ revenue for entire EU in 2025. (of course, revenue != profit) while all 250bn$+ evaporates to somewhere. Their own page [1] reports 225k employees across EU, meaning that each employee returns whopping 1 million plus dollars! While being compensated less than 10% of their value!
2. In their own article [1], they boast how they invested (translated; smuggled money out) and enabled SMEs 20bn$+ revenue. (Like seriously, less than 10%?! actually goes back into the economy...)
3. Amazon says that they have invested 250bn$ in EU since 2010. It is completely unknown what or where that was invested. I do not see my street lightning being improved by the Amazon's investment or garbage being collected better.
4. Luxembourg's GDP is ~95bn$ in 2025. Amazon has contributed to that with the 0$ corporate tax. Obviously they employed about 4.5k people which they've decided to let go about 10% of them. Where the median/average yearly gross salary stands somewhere around 80k eur, it is hardly anywhere near 1mm+$ total income. I am guessing that they heat up the offices with burning the remaining cash...
[1]: https://www.aboutamazon.eu/news/job-creation-and-investment/...
For the date of the verdict for Amazon vs EU, apologies. The article date was November 2024 in the source [2].
[2]: https://www.techtimes.com/articles/308509/20241129/amazons-2...
For the Ireland, I only knew similarities between Luxembourg and specific laws allowing such loopholes pre-brexit period. The source is certainly interesting and I need to dive deeper to understand better.
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The EU doesnt collect income/corporate tax, the individual countries do.
These big corps use holdings in low tax jurisdisctions like Ireland and Luxemburg, funnel all their EU subsidiaries’ revenues there and end up paying 0 tax in the individual EU countries.
This system is actually legal, EU lawmakers should pass laws to prevent this.
And let us not forget the millions and billions the global IT corporations pay in the EU in form of social security taxes, income taxes, the jobs they create, and the further millions and billions in the form of purchases from local delivery companies, consultants, DC vendors, office suppliers, taxi companies, delivery companies, food and catering and all the other local EU-based companies who benefit from having these giants walking among us.
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> EU lawmakers should pass laws to prevent this.
So EU lawmakers should determine the amount member countries collect in tax?
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I don't really understand this perspective.
What should be taxed?
Amazon, as an example, has servers in country X. Country X taxes the transaction or the income from the server company.
Amazon pays delivery drivers in country X to deliver goods, and the driver is taxed through various means (vehicle, fuel, payroll, etc).
What is Amazon doing in country X that should be taxed?
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> OpenAI's losses might actually be attractive to certain investors from a tax perspective.
OpenAI is anyways seeking Govt Bailout for "National Security" reasons. Wow, I earlier scoffed at "Privatize Profits, Socialize Losses", but this appears to now be Standard Operating Procedure in the U.S.
https://www.citizen.org/news/openais-request-for-massive-gov...
So the U.S. Taxpayer will effectively pay for it. And not just the U.S. Taxpayer - due to USD reserve currency status, increasing U.S. debt is effectively shared by the world. Make billionaires richer, make the middle class poor. Make the poor destitute. Make the destitute dead. (All USAID cuts)
> Make billionaires richer, make the middle class poor. Make the poor destitute. Make the destitute dead. (All USAID cuts)
How do you square this thought with the actual rate of poverty being on a steady downward trend while billionaires do their things?
Kindly use the Supplemental Poverty Measure (SPM) - which accounts for government benefits (e.g., tax credits, SNAP), taxes, and expenses like medical costs.
This does not show your "steady downward trend", but has considerably fluctuated over the last few years. It is an increase to 12.9% in 2024, compared to 7.1% in 2020-21. Will need to wait till end of 2026 for the 2025 computation.
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There's already a lot that the US taxpayer is on the hook for that's a lot less valuable than a best on the next big thing in software, productivity, and warfare.
It shouldn't be the job of the US taxpayer to feed someone that doesn't want to work, study, or pass a drug test, and it absolutely shouldn't be the job of the US taxpayer to feed another country's citizens half a world away.
As intrinsically social animals, we have general obligations toward other people that precede our consent. How these play out in practice will be determined by the limitations and conditions of the situation. But in general, such obligations radiate outward based on proximity of relation.
Our first obligations are toward our immediate families. As the human race is essentially a large extended family, the obligations dissipate the further out we go. We do have a general obligation to help those in need, but this obligation is prioritized. In classical texts, this is called the ordo amoris or "order of love" (in the older, more technically accurate terminology, order of charity, where "charity" - from caritas - means willing the good of the other).
Now, to address your comment specifically...
> There's already a lot that the US taxpayer is on the hook for that's a lot less valuable than a best on the next big thing in software, productivity, and warfare.
For example? Whatever the benefits of LLMs, I find this relative exuberance unreasonable.
> It shouldn't be the job of the US taxpayer to feed someone that doesn't want to work,
In someone able-bodied and of sound mind refuses to work, then we don't have an obligation to support someone like that. This is true. In fact, it would be uncharitable to enable their laziness, because it harms the character and virtue of that person. Of course, in practice, if someone you have determined is able to work is found starving and in danger of death, for example, then it is unlikely they are merely lazy. Would a man of sound mind allow himself to starve?
The manner in which we deal with such cases is a prudential matter, not a matter or principle. We need to determine how best to satisfy the principle in the given circumstances, and there is room for debate here.
> it absolutely shouldn't be the job of the US taxpayer to feed another country's citizens half a world away.
If there is a humanitarian crisis somewhere in the world, for example, then there is a general obligation of the entire world to help those affected. How that happens, how that is coordinate, is a matter of prudence and implementation detail, as it were. Naturally, several factors enter the equation (proximity, wealth, etc).
Hello, I'm British by birth.
That's pretty close to the story other Brits give themselves for why losing the empire was actually a good thing for the UK.
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> It shouldn't be the job of the US taxpayer to feed someone that doesn't want to work, study, or pass a drug test
This would make sense if every person was given similar opportunities, like providing quality education to all of our youngest and making higher education a mission rather than a business as a starter.
As a society we move at the speed of the weakest among us, we only move forward when we start lifting and helping the weakest and most vulnerable.
You also need to realize that not doing that work is also cause for other taxpayer money to be spent elsewhere, such as spending an average of 37k $ per incarcerated person, and that ignores all the damage that criminal might've caused, all the additional police staffing and personal security that is needed to be spent outside prisons, etc.
Those are complex systems, are you sure it wouldn't be better to spend the same gargantuan amount of money that's spent on millions of inmates and fighting crime into fighting the causes that make many fall into that?
Again, those are complex, but closed systems and the argument of "we shouldn't spend on X" often ignores the cost of not spending on X.
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The modern welfare state is the compromise reached by capitalist democracies to stave off communist revolutions. If you’re going to kill of the welfare part, be ready for the uprising part.
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> It shouldn't be the job of the US taxpayer to feed someone that doesn't want to work, study, or pass a drug test
What about someone who works and still can’t afford enough housing/food?
> shouldn't be the job of the US taxpayer to feed another country's citizens half a world away.
I mean where’s the profit in that, am i right?
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this is not accurate. microsoft recognizes openai losses on their income statement, proportionate to their ownership stake. this has created a huge drag on eps, along with a lot more eps volatility than in the past. it's gotten so bad that microsoft now points people to adjusted net income, which is notable as they had always avoided those games. none of this has been welcomed
OpenAI is a corporation, so their losses do not flow up to their owners.
Their investors, if publicly traded like Microsoft do have to take write-downs on their financial statements but those aren't realized losses for tax purposes. The only tax "benefit" Microsoft might get from the OpenAI investment is writing off the amount it invested if/when OpenAI goes bankrupt.
Can you explain it in another way? What you are saying is that instead of loosing 100% they loose 70% and loosing 70% is somehow good? Or are you saying the risk adjusted returns are then 30% better on the downside than previously thought? Because if you are, I think people here are saying the risk is so high that it is a given they will fail.
Let's say they are paying for "research". The research is very expensive and has a high likelihood of being worthless, but a small likelihood of having value later. So by claiming the financial loss, they can offset the cost of the expensive research by 30%, making it an even more attractive gamble.
Whilst that is an option, it wont cover the share price hit from the fallout, which would wipe out more than the debt as when the big domino falls, others will follow as the market panic shifts.
So kinda looking at a bank level run on tech companies if they go broke.
> The real question isn't "can OpenAI justify its valuation" but rather "what's the blended tax rate of its investor base?"
Was that an organic "it's not A, it's B" or synthetic?
It’s hardly a free option, by your numbers it’d be a 20-30% discount.
Sure but if there's no moat would you rather pay 100% or 80% until the credits run out? You reap the 100% spend in the meantime. Not everyone even has the no moat discount.
> Something nobody's talking about
Nobody is talking about this because it's not a thing.
People here will shit on LLMs all day for being confidently incorrect, then upvote aggressively financially illiterate comments like this.
None of this is how taxes work.
Correct, for tax purposes corporate losses remain with the corporation. Microsoft and the other owners don't get the benefit of OpenAI's losses. At best, they get to write off their investment in OpenAI if the company dissolves, at which point their maximum tax write-off is their capital investment.
Note: other people seem to be confused because companies can write off investments in corporate subsidiaries before the subsidiary is dissolved or sold...for book purposes. This creates what is known in the accounting world as a book-tax difference. If you have a few weeks to spare, look up tax provisions...
Lmao this is ridiculous. If MSFT really wanted the tax benefits they should’ve just wholly acquired OAI long ago to acquire the financial synergy you speak of.