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I do wonder how much of Amazon's $50B share (per last press release) is in AWS credits rather than money in the bank.


Probably a lot? It would be much more tax-advantageous to do it this way, $50B worth of credits != $50B worth of spend on Amazon's part, and they might meet in the middle about how much equity that translates to.


I can see a lot of advantages for Amazon, but I don't see why it would be tax-advantageous.


Situation A:

You're Amazon. You give OpenAI $50B cash investment, they then hand you back the $50B over time because they buy $50B worth of Amazon AWS services (they would use AWS or other equivalent compute anyway). OpenAI pays an additional $1-5B in sales taxes on top of their $50B compute purchase. Now let's say you have $25B opex for said compute. You then have $25B profits, you pay 21% corporate taxes on the profits, so you too owe the government about $5B. Government collects around $6-10B on this whole transaction.

Situation B:

You're Amazon. You let OpenAI use your services by handing them API credentials that unlock what would normally cost $50B worth of services, but no money changes hands. You have zero revenue from the transaction, write off the $25B opex as a tax loss on your other profits elsewhere in the company. You thus pay ~$5B less tax on your other income as a company, and OpenAI also doesn't have to pay sales tax because they didn't actually purchase anything.


You have to report barter transactions as income. And Amazon already pays 0% corporate income tax.


Isn’t sales tax only for consumers? Ie companies reverse charge sales tax or omit it entirely. Or what is this 2% - 10% sales tax you’re referring to?


> Isn’t sales tax only for consumers?

It depends how you defined “consumers”. If you mean “those who consume the good subject to the tax, rather than people who resell the good”, yes, ideally.

If you mean “not businesses” or “individuals but not corporations”, then, no.

> Ie companies reverse charge sales tax or omit it entirely.

Generally, the theory of sales taxes is that people (including corporations) pay sales tax on things they consume as a final good rather than use as an intermediate good in production or simply resell. The exact way in which that is determined varies somewhat between jurisdictions with sales taxes, but generally (assuming paper is subject to sales tax in a jurisdiction), if you are buying paper to print books that you sell, you don't pay sales tax, if you are buying paper to print internal documents that you use in running the business, you do pay sales tax.


That’s interesting, that’s not the case in the EU. Here, as long as you can argue that it’s a business expense, you don’t have to pay sales tax. Eg the internal documents are a necessary expense / cost of doing business.


My understanding is that EU nations all have VAT, not sales tax; both are broadly consumption taxes, but they function rather differently (VAT charged at each stage of production vs sales tax only at final sale to consumer, among other differences.). VAT is sort of opposite of sales tax for businesses as payers; they pay VAT on goods bought as production inputs (and collect it on behalf of government on items they sell downstream on the chain of production), but do not pay it on what they consume for internal operations (in effect, to the extent thise internal operations contribute to the value added to the product, that is what the people downstream in the chain of production are paying VAT for.)


To then claim that Trainium is “selling” and not a dud? I’d bet a lot.




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