This article shed credibility in the 1st paragraph, calling the Motorola purchase a patent and panic-driven deal. Au contraire, it was a heck of good deal for Google. It's not clear that Google panics about anything.
Much like the "panic" supposedly over Facebook at Google. Unless it isn't clear by now after Facebook's IPO, the apocalypse of social search/ads eating Google's lunch didn't materialize, and if Google has anything to worry about, it's not Facebook, but mobile's screen size and drive towards native apps hurting the web driver ad business.
This tax "analysis" doesn't even pass the smell test and appears to be based on the assumption that Motorola losses will continue at the Q3 '12 record level and makes hay of the $700 of reduced taxes Google would have to pay in that case while ignoring the actual $2 bln losses a year that would pile up on the side.
Forbes put it like this: http://www.forbes.com/sites/timworstall/2013/10/22/motorola-...