This week in big name rationalists on facebook: Wiblin's commenters allege a Trump conspiracy, and EY argues against Wiblin on the social value of voting

Obscure Australian Tax Office document explains how to dodge tax in Australia. Protip: The Netherlands is your friend, the Cayman Islands are for chumps

1. So, for example, investors who are resident of the United States, or indeed a group of investors who are residents of various jurisdictions, may want to join together in creating an investment entity in the Cayman Islands. If the funds of that entity were used to acquire Australian business assets, that Cayman Islands entity would be the relevant taxpayer for the purposes of the Australian taxation system. For entities resident of a non-treaty country deriving a business profit sourced in Australia, it has always been readily understood that Australia would seek to tax that profit.

2. This understanding may be responsible for arrangements involving the purchase of shares in Australian businesses where the arrangements go beyond what might be thought necessary to achieve the commercial goal of bringing various buyers together to make the purchase.

3. Whilst no particular adverse taxation conclusions ought to follow from the use of a Cayman Islands entity to invest into Australia, the use of more complicated structures to make the same investment may require a broader consideration.

4. For example, rather than make a direct purchase from the Cayman Islands of the Australian assets, we have see>n Cayman Islands entities make an equity investment of their funds in a shelf company resident in another low-tax jurisdiction, which may then make an equity investment into a shelf company resident in a country with which Australia has a tax treaty. (European resident interposed entities are often used.) The treaty country resident then capitalises an Australian company intended to be the holder of the target assets. (It is this new Australian holding entity that is ultimately the entity sold by its tax treaty country resident parent.)

5. Where no sound commercial reasons for creating this pattern of holding interests in a number of jurisdictions is apparent, it naturally requires consideration of why these interposed entities between the Cayman Islands entity and Australia are there. For example, if a Dutch company buys and sells Australian assets and makes a business profit, the Australia-Netherlands tax treaty provides that the profit would be assessed in the Netherlands. If a Cayman Islands entity or a Luxembourg entity made a business profit on a similar transaction, the profit is assessable in Australia.

6. Under Australia's tax treaty with the Netherlands a business profit derived from Australian sources is taxable in the Netherlands, not Australia. We understand, however, that the Netherlands domestic tax law provides a participation exemption for mere holding companies that make a gain upon the sale of shares in a subsidiary company. There is also a European Union tax directive regarding the non-imposition of withholding tax in respect of dividends paid from subsidiaries to their European Union resident parent. In these circumstances if the Dutch holding company is owned, for example, by a Luxembourg holding entity, then one can see that a business profit that otherwise is taxable in Australia might be argued to have become a non-taxable gain in the Netherlands, a tax free dividend in Luxembourg, and then a tax free dividend to the Cayman Islands owner of the Luxembourg shelf company.

7. The characterisation of certain profits derived that are, for Australian taxation purposes, considered to be business profits, which in the Netherlands may well be characterised as mere capital gains in terms of Dutch tax jurisprudence, explains the desire, in tax terms, to have the profits derived by a Dutch resident entity rather than its Luxembourg parent or its indirect Cayman Islands holding entity.

Notes from my evening with my friend from the US

• Turns out my effective altruism economics politics and science motivation are all extrinsic therefore incompatible with my egoism and wellbeing
• It not a 100% maxim it's about nudging in the right direction
• Stop time travelling into the future about what happens. Contingencies, just enjoy the here and now
• Relationships from PERMA are extrinsic motivation, shift that! Unconditional self worth don't need validation
• Alternative explanation: I’m just not opinionated therefore non fb posts
• Reduce decision fatigue don't casually revisits tough decisions
• Sunk cost blog
• Read aloud ms voice my blog
• Overthinking the utility of my journal
• my externalising of my breakup with my housemate could be fed by a lack of humility about what’s wrong with me and my room for improvement.

Notes on reflection of that time, afterwards

• damn she even suggested having sex in my car at one point. Damn, so close, dw, keep trying with others
• I’ll be sure to change my preferences from intelligence operator with the army to intelligence specialist with the airforce since the fitness requirements are getting too dangerous!
• Excessive self reflection?
• Enjoy that Idgaf mentality