巴菲特致股东的信（1989年）②税务

Taxes

Our 1989 gain of $1.5 billion was achieved after we took a charge of about $712 million for income taxes. In addition, Berkshire's share of the income taxes paid by its five major investees totaled about $175 million.

税务

事实上，1989 年伯克希尔 15 亿美元的净利润是支付了 7.12 亿美元所得税后实现的，此外，伯克希尔在五大主要被投资公司缴纳的所得税中所占份额为 1.75 亿美元。

Of this year's tax charge, about $172 million will be paid currently; the remainder, $540 million, is deferred. Almost all of the deferred portion relates to the 1989 increase in unrealized profits in our common stock holdings. Against this increase, we have reserved a 34% tax.

在今年的所得税费用中，大约有 1.72 亿美元是马上要支付的，剩下的 5.4 亿则可以记帐递延处理，大部分是由于 1989 年我们持有的股票未实现的增值收益，按 34%的预估税率计算出来的。

We also carry reserves at that rate against all unrealized profits generated in 1987 and 1988. But, as we explained last year, the unrealized gains we amassed before 1987 - about $1.2 billion - carry reserves booked at the 28% tax rate that then prevailed.

另外我们也为 1987 年及 1988 年的未实现资本利得依照前项税率补提准备，但如同去年解释过的，我们在1987 年以前所累积的未实现收益约 12 亿美元，仍依照当时 28%的税率提列准备。

A new accounting rule is likely to be adopted that will require companies to reserve against all gains at the current tax rate, whatever it may be. With the rate at 34%, such a rule would increase our deferred tax liability, and decrease our net worth, by about $71 million - the result of raising the reserve on our pre-1987 gain by six percentage points. Because the proposed rule has sparked widespread controversy and its final form is unclear, we have not yet made this change.

新的会计原则有可能会要求，公司将所有的未实现利得以现行的税率估算(不管税率高低)，若以 34%来计，这样的规则可能会大幅增加我们帐列递延所得税的数字，并使我们的账面价值减少约 7,100 万美元(约将税率提高6%，34%-28%)，由于新提出的规定引发相当大的争议，最后的结果尚难定论，所以我们尚未做此反应。

As you can see from our balance sheet on page 27, we would owe taxes of more than $1.1 billion were we to sell all of our securities at year-end market values. Is this $1.1 billion liability equal, or even similar, to a $1.1 billion liability payable to a trade creditor 15 days after the end of the year? Obviously not - despite the fact that both items have exactly the same effect on audited net worth, reducing it by $1.1 billion.

大家可以从资产负债表上看到，若是年底我们一口气将所有的有价证券按市价全部出清，则我们要支付的所得税将高达 11 亿美元，但这 11 亿的负债，是否就跟 15 天后要付给厂商的货款一样或是相近吗？很显然的并非如此，虽然在财务报表上计算的账面价值的方式都一样，只是很简单地减掉 11 亿美元。

On the other hand, is this liability for deferred taxes a meaningless accounting fiction because its payment can be triggered only by the sale of stocks that, in very large part, we have no intention of selling? Again, the answer is no.

另一方面，这项递延所得税负债是不是一项会计虚构呢？因为它的支付只能通过出售股票来触发，而在很大程度上，我们并不打算出售这些股票。答案很显然也不是。

In economic terms, the liability resembles an interest-free loan from the U.S. Treasury that comes due only at our election (unless, of course, Congress moves to tax gains before they are realized). This "loan" is peculiar in other respects as well: It can be used only to finance the ownership of the particular, appreciated stocks and it fluctuates in size - daily as market prices change and periodically if tax rates change. In effect, this deferred tax liability is equivalent to a very large transfer tax that is payable only if we elect to move from one asset to another. Indeed, we sold some relatively small holdings in 1989, incurring about $76 million of "transfer" tax on $224 million of gains.

就经济实质而言，这种递延所得税负债就好象是美国财政部借给我们的无息贷款，且到期日由我们自己来决定，(当然除非国会在收益实现之前就开始征税)，这种贷款还有一项很奇怪的特点，它只能被用来购买某些特定增值的股票，而且额度会随时市场价格而变动，有时也会因为税率变动而改变，事实上这种递延所得税有点类似于资产移转时所要缴交的转让税，事实上我们在 1989 年只做了一小部分的变动，总共产生了 2.24 亿的资本利得，因此发生了 7,600 万的转让税。

Because of the way the tax law works, the Rip Van Winkle style of investing that we favor - if successful - has an important mathematical edge over a more frenzied approach. Let's look at an extreme comparison.

由于税法运作的方式，如果情况许可的话，我们偏爱李伯大梦式的投资(短篇小说《Rip Van Winkle》)。因为较之疯狂短线进出的方法，它有一个很重要数学优势，让我们举一个很极端的例子来做说明。

Imagine that Berkshire had only $1, which we put in a security that doubled by yearend and was then sold. Imagine further that we used the after-tax proceeds to repeat this process in each of the next 19 years, scoring a double each time. At the end of the 20 years, the 34% capital gains tax that we would have paid on the profits from each sale would have delivered about $13,000 to the government and we would be left with about $25,250. Not bad. If, however, we made a single fantastic investment that itself doubled 20 times during the 20 years, our dollar would grow to $1,048,576. Were we then to cash out, we would pay a 34% tax of roughly $356,500 and be left with about $692,000.

假设伯克希尔只有 1 块美金的投资，但它每年却可以有一倍的回报，假设我们将卖掉后所得的资金，用同样的方式再重复 19 年，结果 20 年下来，依照 34%的税率总共贡献给政府 13,000 美元，而我们自己则可以拿到25,250 美元，看起来还不错。然而，要是我们简单一点，只做一次超棒的投资，同样每年翻一倍，则最后的金额却高达 1,048,576 美元，在扣除 34%即 356,500 的所得税之后，实得约 692,000 美元。

The sole reason for this staggering difference in results would be the timing of tax payments. Interestingly, the government would gain from Scenario 2 in exactly the same 27:1 ratio as we - taking in taxes of $356,500 vs. $13,000 - though, admittedly, it would have to wait for its money.

之所以会有如此大的差异唯一的原因就是所得税支付的时点，有趣的是政府将以与我们完全相同的 27：1 比例从方案 2 中获益：税收为 356500 美元，而不是 13000 美元，当然政府必须等到最后才能拿到这笔税金。

We have not, we should stress, adopted our strategy favoring long-term investment commitments because of these mathematics. Indeed, it is possible we could earn greater after-tax returns by moving rather frequently from one investment to another. Many years ago, that's exactly what Charlie and I did.

必须强调的是，我们并不是因为这种简单的算术就倾向采用长期投资的态度。事实上，通过频繁地投资变动，我们有可能获得更高的税后回报。很多年前，查理跟我就是这样在做的。

Now we would rather stay put, even if that means slightly lower returns. Our reason is simple: We have found splendid business relationships to be so rare and so enjoyable that we want to retain all we develop. This decision is particularly easy for us because we feel that these relationships will producegood - though perhaps not optimal - financial results. Considering that, we think it makes little sense for us to give up time with people we know to be interesting and admirable for time with others we do not know and who are likely to have human qualities far closer to average. That would be akin to marrying for money - a mistake under most circumstances, insanity if one is already rich.