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MagnusVonMagnum

macrumors 603
Jun 18, 2007
5,193
1,442
Nope. There is little difference in the context of this discussion between Apple owning all the stock in a foreign subsidiary and a person owning all the stock in a foreign subsidiary. In both cases, the owner of the stock is in control of the company and it's foreign profits.

You're STILL talking about a corporation and owning a majority in a corporation, though in both examples above. My original comparison was between a corporation like Apple and a private citizen, not between a corporation and citizen owning the majority share in a corporation. Your comment has nothing to do with the discussion. I already mentioned the only way I could personally get away with what Apple does is to incorporate myself and then create a subsidiary corporation of myself in a foreign country in which all my foreign earnings occur. Of course, I could only spend that money overseas and I'd still have to pay tax in the country my corporation is in, but short of that, ALL individual income (not holdings like stock without dividends), foreign or domestic must be declared to the IRS and taxed accordingly. NOTHING anyone has said thus far has changed that basic fact.

As long as money made in Europe stays in Europe, I don't really care. They made the money over there; they can pay the taxes over there. But the minute they try to bring that money back into the U.S., there is simply no way they should get the 7% tax rate they are lobbying for when the best I can possibly do is 14% for capital gains.

And let's face it, the ONLY reason Apple has created a subsidiary corporation in the first place is to avoid taxes. The only other reason to create such a division is legal protection, since legally they are separate entities and that limits liability. The downside to a subsidiary is possible double taxation if you want to bring the foreign earnings back into the U.S. and that is what Apple has said it wants to do, but only if the U.S. makes an exception for it or a new law that allows them to do it closer to 7%, not 35%. And THAT I have a problem with since that is not just tax dodging, it's tax shredding.

Frankly, I think even the capital gains tax rate of 14% needs to go WAY up, at least for those that make the majority of their income through capital gains since people like Mitt Romney make virtually ALL their money that way. No millionaire should get to pay 14% taxes on multi-million dollar income when ordinary people making money the hard way have to pay as much as 39.6%. In short, if you're born into "old" money, you get treated as royalty and pay the same tax rate as someone making $12k a year? That's a crock, pure and simple. But like finance reform, you never seem to get any real change because the rich lobby lobby lobby (i.e. bribe bribe bribe) government to NOT change the laws. That in turn means our government is CORRUPT (they take BRIBES and that's EXACTLY what lobbying money is, a BRIBE) and frankly, we as citizens should be outraged by it all. The way the system works, though, it's very difficult to clean up the mess they've created since the people doing the underhanded unethical things are the same ones that are making the laws that allow themselves to get away with it (e.g. allowing insider trading all those years for Congress). Only massive bad press and public outrage can possibly scare them into doing the right thing, ethically speaking.
 

vvswarup

macrumors 6502a
Jul 21, 2010
544
225
And yet I'm required to disclose all foreign bank accounts I might have to the IRS so they can tax any income I make overseas. Why the hell should it be any different for a corporation? Income is income and they are based in the USA. They want to be treated like a "person" then they should PAY like a person, IMO.

http://www.irs.gov/Businesses/Income-from-Abroad-is-Taxable

On the note of interest earned overseas, I remember Tim Cook saying that Apple pays tax on interest earned in foreign bank accounts.

But on the note of taxing foreign income in general, you're looking at it the wrong way. Two wrongs don't make a right. Taxing income earned by individuals who work overseas and earn their income overseas is absolutely ludicrous. So it's not right that you are taxed on foreign income.

You have said in previous posts about how if people/corporations use the resources of a country, they have should pay tax on it. That's all fine. But when you work overseas and earn income overseas, what US resources did you use? Why should you have to pay US tax on that income?
 

MagnusVonMagnum

macrumors 603
Jun 18, 2007
5,193
1,442
On the note of interest earned overseas, I remember Tim Cook saying that Apple pays tax on interest earned in foreign bank accounts.

But on the note of taxing foreign income in general, you're looking at it the wrong way. Two wrongs don't make a right. Taxing income earned by individuals who work overseas and earn their income overseas is absolutely ludicrous. So it's not right that you are taxed on foreign income.

You have said in previous posts about how if people/corporations use the resources of a country, they have should pay tax on it. That's all fine. But when you work overseas and earn income overseas, what US resources did you use? Why should you have to pay US tax on that income?

There's a difference between having money invested overseas that's earning money overseas while you live here and actually living and working abroad. (see: http://www.overseastaxservices.com/index.php?option=com_content&view=article&id=53&Itemid=57 ). You can typically deduct almost $100k if you spend a full work year overseas. Beyond that, if you pay tax over there, there's more complications (in your benefit). If you earn a lot more than $100k, yes, you will typically have to pay some taxes, but one might say it's the price of being an American citizen (i.e. you still enjoy the protections that come with being a U.S. citizen. In other words, it's not just resources you're using, but those you might use).

Apple is in Ireland because the tax rate is 2% (compared to 35%) here. The Republicans want a 0% tax rate here for corporations. An article I just read said they could implement a 10% tariff on imports instead to make up for it. I might be agreeable to that idea, but I just can't imagine Republicans voting for tariffs since it might affect their offshore factories, etc.
 

Cartaphilus

macrumors 6502a
Dec 24, 2007
581
65
Apple is in Ireland because the tax rate is 2% (compared to 35%) here. The Republicans want a 0% tax rate here for corporations. An article I just read said they could implement a 10% tariff on imports instead to make up for it. I might be agreeable to that idea, but I just can't imagine Republicans voting for tariffs since it might affect their offshore factories, etc.

You are obviously one of those who cling to your misunderstandings and mistaken facts in the grip of the certainty of your convictions. Republican Tea Party types are often like this, but it's unusual among moderate liberals.

You have no idea why Apple is in Ireland. They established their subsidiary there in 1980, shortly after their founding, and had no way of knowing they would ever have significant earnings in Europe. The tax rate in Ireland is not 2%. Apple pays U.S. tax on interest earnings on investments by their Irish sub, and some PCI staffer divided that tax by what Apple's GAAP earnings in Ireland were and a member threw out the number. The 35% nominal rate starts at $10 million and is after many deductions and exclusions.

Tariffs? Do you know about GATT and the WTO? Do you understand the economic impact of imposing import tariffs?

The gods themselves contend in vain.
 
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vvswarup

macrumors 6502a
Jul 21, 2010
544
225
There's a difference between having money invested overseas that's earning money overseas while you live here and actually living and working abroad. (see: http://www.overseastaxservices.com/index.php?option=com_content&view=article&id=53&Itemid=57 ). You can typically deduct almost $100k if you spend a full work year overseas. Beyond that, if you pay tax over there, there's more complications (in your benefit). If you earn a lot more than $100k, yes, you will typically have to pay some taxes, but one might say it's the price of being an American citizen (i.e. you still enjoy the protections that come with being a U.S. citizen. In other words, it's not just resources you're using, but those you might use).

If you're a US citizen living abroad, you are subject to local laws. If you break the law, the US government is not going to help you get out of trouble.

And in my opinion, those protections that you might use don't justify a 35% tax rate.
Apple is in Ireland because the tax rate is 2% (compared to 35%) here. The Republicans want a 0% tax rate here for corporations. An article I just read said they could implement a 10% tariff on imports instead to make up for it. I might be agreeable to that idea, but I just can't imagine Republicans voting for tariffs since it might affect their offshore factories, etc.

Apple is in Ireland because they pay a lower tax rate. That's a fact. But the problem isn't Apple. The problem is the US tax rate of 35% which is too high. While it's true that no one really pays that rate, that's not the issue. The issue is the hoops that companies jump through to get their tax rate down.

Companies are able to reduce their tax rate from the marginal tax rate only after hiring an army of accountants and lawyers. In other countries, the marginal tax rate is lower, meaning that companies in those countries would pay a lower tax rate right off the bat without paying accountants and lawyers to come up with a convoluted migraine-inducing tax avoidance scheme.

And corporations aren't the ones who actually pay the tax. The incidence of the tax falls on employees, shareholders, and customers.
 

MagnusVonMagnum

macrumors 603
Jun 18, 2007
5,193
1,442
You are obviously one of those who cling to your misunderstandings and mistaken facts in the grip of the certainty of your convictions. Republican Tea Party types are often like this, but it's unusual among moderate liberals.

The under the table insults are really unbecoming. If you can't win an argument, just throw around insults? Is that your motto? :rolleyes:

You have no idea why Apple is in Ireland.

You mean YOU don't know why they're there. I know perfectly why they're there and it's to take advantage of their lower tax rate. Ireland just happens to have one of the the lowest corporate tax rates in Europe at 12.5%. But contrary to your false statement that Apple doesn't pay 2% tax over there as I said earlier, they actually paid 1.9%. Unlike you and your claims, I'll provide PROOF:

http://www.rte.ie/news/business/2013/0521/451564-apple-tax-arrangements/
http://www.bbc.co.uk/news/business-20197710
http://online.wsj.com/article/SB10001424127887324787004578496803472834948.html

Relevant quotes: "The Senate report said Apple executives claimed they had negotiated a special rate of corporation tax with the Irish Government, which has been less than 2% over the past decade."

The committee said one of Apple's Irish subsidiaries - AOI - "declined to declare its tax residence" and filed no return of corporation tax liability in any country as a result. The report described AOI as Apple's "primary offshore holding company".

As AOI meets neither the Irish nor the US test of residence, it is not tax resident in any country, and appears not to file tax returns or pay corporation tax. According to the Senate report, AOI accounted for 30% of Apple's total profits between 2009 and 2011.




Yeah, I really misunderstood. :rolleyes:

So much for you contention that Apple doesn't do any particularly creative accounting either. AOI pays 0% tax. :rolleyes:

They established their subsidiary there in 1980, shortly after their founding, and had no way of knowing they would ever have significant earnings in Europe.

You don't set up tax havens knowing how well you'll do in business (although no company thinks it's going to fail when it starts up). You set them up because they have lower tax rates. :rolleyes:

The tax rate in Ireland is not 2%.

See above articles. Apple has been averaging between 1.9% and 2.5% the past few years. Their official rate is 12.5%, but Apple doesn't pay anywhere near that much in reality.

Tariffs? Do you know about GATT and the WTO? Do you understand the economic impact of imposing import tariffs?

You seem to have missed the part (as usual since you don't really read what I write) the bit where I said the tariff idea was from a Republican writer in the newspaper who suggested he would rather see a 0% corporate tax with a 10% flat tariff on foreign goods to make up for it. You and anyone else can debate whether that's a good trade-off or not.

You certainly can't just wipe out the corporate tax with no ill effects. The article estimated a loss of $250 BILLION in taxes with no corporate tax and so they had to make up for it somehow and a 10% tariff was their answer. Certainly, it would probably drive the cost of certain items up a good deal in the short run, but in the long run we might end up making many of those goods over here once again. I couldn't care less about trade wars with China. We are already losing the war as it is, bit by bit.

I've always liked the idea of a tariff on US companies that move manufacturing overseas and then export those goods back to the U.S. for sale just to avoid paying living wages over here. That would nullify their advantage of moving overseas in the first place and thus act as a serious deterrent as well. Short terms effects may pale in comparison to what will happen to this country if our debt continues to pile up. You can't pay down the principal if you're just paying on interest.

The gods themselves contend in vain.

Now just what god would that be? Lyssa? :p
 

Cartaphilus

macrumors 6502a
Dec 24, 2007
581
65
You mean YOU don't know why they're there. I know perfectly why they're there and it's to take advantage of their lower tax rate. Ireland just happens to have one of the the lowest corporate tax rates in Europe at 12.5%. But contrary to your false statement that Apple doesn't pay 2% tax over there as I said earlier, they actually paid 1.9%. Unlike you and your claims, I'll provide PROOF:

http://www.rte.ie/news/business/2013/0521/451564-apple-tax-arrangements/
http://www.bbc.co.uk/news/business-20197710
http://online.wsj.com/article/SB10001424127887324787004578496803472834948.html

Relevant quotes: "The Senate report said Apple executives claimed they had negotiated a special rate of corporation tax with the Irish Government, which has been less than 2% over the past decade."

Let me remind you of what you had said: "Apple is in Ireland because the tax rate is 2% (compared to 35%) here." (sic). The tax rate in Ireland is not 2%. You were wrong. Apple may pay what amounts to about 2% at least sometime, but there are conflicting claims as to why. Your thesis was that Apple established its Irish subs to take advantage of the 2% tax rate, a rate which appears nowhere in Irish law, as you yourself finally acknowledge is the case.

So much for you contention that Apple doesn't do any particularly creative accounting either. AOI pays 0% tax. :rolleyes:



You don't set up tax havens knowing how well you'll do in business (although no company thinks it's going to fail when it starts up). You set them up because they have lower tax rates. :rolleyes:



See above articles. Apple has been averaging between 1.9% and 2.5% the past few years. Their official rate is 12.5%, but Apple doesn't pay anywhere near that much in reality.

There is no creative accounting. The Irish sub that earns royalties is in Ireland, not in the U.S. Apple's accounting is pure vanilla, audited by the IRS and by its CPAs. No one has even suggested that U.S. income is being reported as belonging to an Irish entity. No creativity is needed; income earned by a subsidiary needn't be reported on the parent's Federal tax return. That's the law. If you want a new law, the creativity is yours, not Apple's.

AOI pays zero tax in Ireland because that is what Irish law provides. Perhaps you'd like to advise the Irish government on how they can get more tax revenue by changing their laws to make subs like AOI subject to a 35% tax in Ireland. I would have thought that establishing a higher tax rate on foreign-managed corporations in Ireland might actually have occurred to the Irish and that they felt in was in the overall long-term interests of Ireland to keep a low to non-existent tax rate in order to attract more companies, more jobs, and more economic activity. But I could be all wet and the Irish would just be on tenterhooks awaiting the pearls of wisdom to fall from the lips of noted international tax expert Dr. VanMagnum.

In any case, whatever Apple pays or doesn't in Ireland has no effect on its U.S. tax obligations. The IRS gets nothing unless or until a dividend is paid to a U.S. entity. I heard your rejection of the very concept of a dividend, citing the maxim, "profits are profits", but it turns out the grown-ups of the world don't agree and think whether or not a dividend has been paid matters.

Let's say you're right and somehow the devilishly clever tax lawyers this startup was hiring by the carload in 1980, just a few years before flirting with bankruptcy, figured out that Apple would be inventing iPods, iPhones, and iPads that unlike the Macintosh and Newton, would one day be sold like hotcakes all over the world at a great profit. Hmm...what to do with all those pesky taxes those far-flung government would be trying to collect...hey, how about setting up Irish subsidiaries! Sure it will cost a bunch to set up, get office space, hire Irish employees, but one day it'll pay off big time. Let's say you're right about all that? If profits are made outside the U.S. by selling iPhones in France, what difference does it make if the taxes are collected by France or Ireland? The U.S. has nothing to do with any of it because, and only because, the U.S. has decided it is in the best long-term interests of the U.S. not to. The fundamental flaw of your position, which you refuse to recognize for some reason, is that you can't make a rule that says if you give money to charity you won't have to pay taxes on it, and then call somebody who gives money to charity a tax avoider, and suggest that they go ahead and pay the taxes they would have paid in the absence of their philanthropy. This is no unintended loophole that some gnome discovered an unanticipated way to exploit--this is the well-know law of the U.S., the well-known law of Ireland, and the well-known deductibility of royalty payments under the laws of all the other countries Apple products are sold in.



You seem to have missed the part (as usual since you don't really read what I write) the bit where I said the tariff idea was from a Republican writer in the newspaper who suggested he would rather see a 0% corporate tax with a 10% flat tariff on foreign goods to make up for it. You and anyone else can debate whether that's a good trade-off or not.

You certainly can't just wipe out the corporate tax with no ill effects. The article estimated a loss of $250 BILLION in taxes with no corporate tax and so they had to make up for it somehow and a 10% tariff was their answer. Certainly, it would probably drive the cost of certain items up a good deal in the short run, but in the long run we might end up making many of those goods over here once again. I couldn't care less about trade wars with China. We are already losing the war as it is, bit by bit.

I've always liked the idea of a tariff on US companies that move manufacturing overseas and then export those goods back to the U.S. for sale just to avoid paying living wages over here. That would nullify their advantage of moving overseas in the first place and thus act as a serious deterrent as well. Short terms effects may pale in comparison to what will happen to this country if our debt continues to pile up. You can't pay down the principal if you're just paying on interest.

I understand you don't like the fact that other countries can produce higher quality goods at lower cost than workers in the United States can. The United States can produce corn and wheat at better quality and lower cost than just about anybody in the world can. Some time ago it was discovered that when countries do what they do best and buy what others do best from those countries, all countries are better off. Protective tariffs that allow the companies of a country to produce products that can't compete in the world market, and which pay their workers a premium over the world wage for producing inferior product have long be recognized as counter-productive. It puts on the back of every domestic consumer a hidden tax used to subsidize poorly-run companies. The U.S. automobile industry in the 1970's is a good example, but there are many. You don't want your iPhone to have the quality of the 1973 Pacer.

The point I was making is that the U.S. is a member of the World Trade Organization which replaced GATT and mediates multilateral trade agreements around the world. The U.S. can't just unilaterally decide to abrogate its treaties and impose a 10% tariff because it can't figure out how to tax corporate efficiently, something that the rest of world does very nicely, as another poster to this thread rightly pointed out.

If you want to collect more money from Apple, just say so. Pass a law that says that your worldwide GAAP profit as reported on a consolidated basis is taxed for corporations at some rate you like. GIve a tax credit for cash taxes paid to other governments. There you go. You have the tax you like, perfectly fair, and it will generate tax revenue for the government. At least it will until corporations figure out they can be more profitable relocating abroad, taking many jobs, real estate leases, and Federal, state, and local tax revenue with them.



Now just what god would that be? Lyssa? :p[/QUOTE]

Ask Friedrich Schiller.
 

samiwas

macrumors 68000
Aug 26, 2006
1,598
3,579
Atlanta, GA
But on the note of taxing foreign income in general, you're looking at it the wrong way. Two wrongs don't make a right. Taxing income earned by individuals who work overseas and earn their income overseas is absolutely ludicrous. So it's not right that you are taxed on foreign income.

This is only true in my mind if your only connection to the US is a passport. If the money you earn goes into a US bank account, or can be used within the US in any way, then it should be taxed. If you have any property in the US, you should be paying something (besides just property taxes). If you have no connection to the US outside of a passport, then maybe you can skate free. But then, I'd expect you to have to pay for any services (consulate, etc) you do use.

I live in the US. I went over to London for six weeks a few years ago for an install. I earned quite a bit while I was there. I worked and earned income overseas. Do you think I don't owe anything to the US? Does the fact that I was working for a US company change that?
 

Cartaphilus

macrumors 6502a
Dec 24, 2007
581
65
This is only true in my mind if your only connection to the US is a passport. If the money you earn goes into a US bank account, or can be used within the US in any way, then it should be taxed. If you have any property in the US, you should be paying something (besides just property taxes). If you have no connection to the US outside of a passport, then maybe you can skate free. But then, I'd expect you to have to pay for any services (consulate, etc) you do use.

I live in the US. I went over to London for six weeks a few years ago for an install. I earned quite a bit while I was there. I worked and earned income overseas. Do you think I don't owe anything to the US? Does the fact that I was working for a US company change that?

Broadly, an employee of a US company visiting the UK who spends less than 30 days here in any UK tax year should not run into any tax problems whilst they are here, as the UK tax authorities, the Inland Revenue (IR), will not normally seek to tax these individuals.

A short term visitor (i.e. an employee of a US company) coming to the UK for between 30 & 91 days in a UK tax year is, strictly speaking, liable to UK withholding taxes (Pay As You Earn, or PAYE) on their employment income for the period of time they are here. However, it is normally possible to reach an agreement with the IR that, under the terms of the Double Taxation Agreement that the UK has with the US, PAYE withholdings are not required on the basis that no tax will eventually be payable.

The tax treatment of those individuals in the UK for between 91 days and 183 days in a UK tax year is complicated and depends not only on the number of days they spend in the UK in the relevant tax year, but also in the previous 4 years. In overview, providing the following conditions are met, an employee of a US company visiting the UK for a temporary purpose will not suffer UK tax on their employment income:

1) They are in the UK for less than 183 days in the tax year; &

2) Their visits to the UK over the previous 4 years have averaged less than 91 days per year, &

3) They are not paid by a UK company, &

4) Their compensation is not borne by a UK company (i.e. their costs are not re-charged back to the UK company).

Seems reasonable to me; we'll see what insight MVM brings.
 

jnpy!$4g3cwk

macrumors 65816
Feb 11, 2010
1,119
1,302
I understand you don't like the fact that other countries can produce higher quality goods at lower cost than workers in the United States can.

Other countries can produce ... [etc]. The tax code should not encourage multinational companies to move production when, otherwise, it would not make sense.

The United States can produce corn and wheat at better quality and lower cost than just about anybody in the world can.

Lower cost for sure. But, at what cost?

Some time ago it was discovered that when countries do what they do best and buy what others do best from those countries, all countries are better off.

That's what they taught me in Econ 1A. But, they left out a lot. Such as the effect on unemployment and income distribution. The bottom quintile in a population may benefit little from the average income or the overall improved efficiency that comes with international trade.

Protective tariffs that allow the companies of a country to produce products that can't compete in the world market, and which pay their workers a premium over the world wage for producing inferior product have long be recognized as counter-productive. It puts on the back of every domestic consumer a hidden tax used to subsidize poorly-run companies. The U.S. automobile industry in the 1970's is a good example, but there are many. You don't want your iPhone to have the quality of the 1973 Pacer.

The point I was making is that the U.S. is a member of the World Trade Organization which replaced GATT and mediates multilateral trade agreements around the world. The U.S. can't just unilaterally decide to abrogate its treaties and impose a 10% tariff because it can't figure out how to tax corporate efficiently, something that the rest of world does very nicely, as another poster to this thread rightly pointed out.

I'm still looking for suggestions on how to restructure the tax code, WTO, etc, so that, worldwide, the bottom 20% in every country have a chance.
 

Cartaphilus

macrumors 6502a
Dec 24, 2007
581
65
I'm looking too, because the only idea I've heard that I believe is realistic seems to me to be awfully difficult to persuade people to accept, especially since ideas that won't work are a lot easier to sell.

I'm persuaded by those who say that we have to put people to work doing things that are useful, getting a living wage for doing it, and doing something a robot or a worker in a developing country can't do as well. Jobs in the broad health care industry, the trades (plumbers, electricians, auto repair, butchers, bakers, construction) and personal service industries (hotel, food service, salons, etc.) fall into this category, as do many office workers. We could stop subsidizing banks to loan money to high school graduates with mediocre grades and 500's on their SAT's to attend (at least for awhile) colleges where they take academic courses that don't interest them and which will do them little good. We could take those funds and establish real trade schools where real-world skills are taught and practiced. I fully understand the sentiments of low income, poorly-educated parents who believe that in America anyone can rise to be whatever he or she wants to be, and I hope that will always be true; but if a child hasn't demonstrated academic promise by the time high school ends, taxpayers shouldn't support higher education in state-supported colleges, or by making grants or loans.

There should be nothing shameful about doing a great job in a trade that doesn't require a degree. Our best and brightest ought to be able to compete with the world, but I can't imagine how unskilled Americans expecting a middle-class American lifestyle can compete with people in Africa, Asia, and Oceania whose expectations are far more modest. Each year the return to capital increases while the real return to labor diminishes. Some of the erosion is attributable to the decline of effective labor unions, but much more is because other nations in a world of low transportation and information processing costs with access to capital can produce many products of good quality much less expensively than the U.S. can. No union, no tariff, no tax, no trade barriers can erase this intrinsic disadvantage, nor, in the long run, should it.

I'd be in favor of incurring substantial fiscal deficits to fund a comprehensive program to put our lowest 20% to work in good jobs they can learn to do well, and the increased productivity and decrease in social welfare payments would rapidly retire the incurred debt. At the same time, though, not trying to learn a skill, and not wanting to work needs to result in unpleasant living conditions, but not in starvation, or there is less motivation than is necessary.

That's all I've got.
 
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MagnusVonMagnum

macrumors 603
Jun 18, 2007
5,193
1,442
Let me remind you of what you had said: "Apple is in Ireland because the tax rate is 2% (compared to 35%) here." (sic). The tax rate in Ireland is not 2%. You were wrong.

You're right, I should have said, THEIR (tax rate) instead of THE. Regardless of wording, it doesn't change a single thing. Apple still only pays 2% in Ireland. Whether Ireland likes it or not, they're not getting what they should either, but I'm sure it's a matter of, we'll take our business elsewhere if you won't give us what we want and someone decided they'd rather have Apple there at 2% than not at all. The problem is Apple's ability to move around like that and that is our fault for letting them do it. If they could not form a subsidiary under U.S. law, they would not be in Ireland in the first place. But our government is run by the corporations FOR the corporations so they can pretty much do anything they want. Very few large corporations actually pay 35% here so the notion of getting rid of that rate is largely just for show anyway. Pointing out our tax rate is the problem is similarly misdirection at best since large corporations don't generally pay it anyway.

That is the American way these days. It's why the right is working so hard to dismantle the last vestiges of unions wherever it can, to undo all the progressive positive changes made in the past century. They will not be happy until there's the 1% and the peasants and nothing in-between. It's easier to control a population that can't even afford to eat properly, after all.

In your post to someone else above, you talk about how it'd be nice if stupid people could earn a middle class wage, but of course they're all replaceable and how dare someone working in a restaurant ask for more than $7.25 (with waiters/waitresses earning substantially less since they are expected to make their money from tips and if a customer doesn't leave a proper tip, too bad). Of course the same people at a high-end restaurant probably make more money in a night than I make in a week. It's disproportionate to the actual work and skill involved all around. In the end, it simply comes down to what the 1% want to spend. Their profits go through the roof and unless they're forced to, they will not spread it around at all. They'll pay through the nose for the top-end management, but everyone else can expect nothing for increased productivity and hard work. It was the American way in the 19th Century and despite the progress made during the 20th Century, we are quickly regressing back to the Middle Ages thanks to unlimited spending from the top to bribe...ahem...lobby their way back in time.

Apple may pay what amounts to about 2% at least sometime, but there are conflicting claims as to why. Your thesis was that Apple established its Irish subs to take advantage of the 2% tax rate, a rate which appears nowhere in Irish law, as you yourself finally acknowledge is the case.

Oh come on. You're playing word games now. I'm not out to win a debate or a prize here. I'm just trying to keep people like you honest. Let's go with the 12% figure instead. It' still 23% less than the USA and one of the lowest in all of Europe and now that the religious violence crap has largely abated over there, Ireland looks like a pretty good base to work out of for Europe. Apple didn't have to know about iPods back in 1980. They wanted to sell Apple computers back then. Besides, I'm talking about Apple today, not in 1980, which you brought up. It doesn't even matter if taxes were the reason they created Apple Ireland. What are they using it for now? A tax shelter. Period.

There is no creative accounting.

I guess that depends on your idea of creative. Creating subsidiaries inside of subsidiaries like AOI to pay 0% taxes sounds creative to me. But you call it "vanilla" and that's a load of crap ( http://www.guardian.co.uk/technology/2013/may/29/apple-ireland-cork-cathy-kearney ). Someone also made a deal for a ~2% tax rate. I don't care if if you want to call that creative or not, they're getting a hell of a deal.

AOI pays zero tax in Ireland because that is what Irish law provides.

By provides, you mean they found a loophole in Irish law that lets them do what they do. That's not creative, though. It's pure vanilla (whatever the frack that means in regards to avoiding taxes that are supposed to be paid by law). Really, you're doing nothing but making excuses for why Apple (and I don't mean Apple Ireland since Apple controls both Apple Ireland and by extension, AOI) avoids paying taxes. The bottom line is that Apple is a U.S. company, not an Irish one and they should be paying U.S. taxes. They hide their money overseas to avoid paying U.S. taxes. No one (but you it seems) disputes this. You make excuses for it and because it's legal, it's somehow OK. And that tells me all I need to know about your own ethical outlook on life. If it's legal, do it. If it's legal to thieve, do it. If they don't like thievery, they should change the law. That's your answer for everything financial. There's no moral qualms. There's no ethical or patriotic integrity to consider. If you can get away with it, do it. :rolleyes:

Just admit that much and I'll leave the discussion right now. Because my whole point here is that morality and ethical integrity should trump legality in people's lives. Just because you can get away with something (e.g. create a designer drug that isn't illegal yet), that doesn't mean you should. And it's precisely this grey area of ethical behavior that has developed as the country has become more and more secular that bothers me. I don't need God to tell me right and wrong, but it's becoming apparent that most of the population apparently does or at least, rather they are inherently evil to begin with and without a threat of eternal damnation (and many with it even so) will do whatever they want to do...anarchy if we let it happen.

Perhaps you'd like to advise the Irish government on how they can get more tax revenue by changing their laws to make subs like AOI subject to a 35% tax in Ireland. I would have thought that establishing a higher tax rate on foreign-managed corporations in Ireland might actually have occurred to the Irish and that they felt in was in the overall long-term interests of Ireland to keep a low to non-existent tax rate in order to attract more companies, more jobs, and more economic activity. But I could be all wet and the Irish would just be on tenterhooks awaiting the pearls of wisdom to fall from the lips of noted international tax expert Dr. VanMagnum.

I heard your rejection of the very concept of a dividend, citing the maxim, "profits are profits", but it turns out the grown-ups of the world don't agree and think whether or not a dividend has been paid matters.

Your comments are always under the table insults and attempts to make what is legal sound like it's ethical when it so obviously is not ethical in the slightest to anyone with a conscience in them. You have zero integrity. You are part of the problem, not the solution.

I understand you don't like the fact that other countries can produce higher quality goods at lower cost than workers in the United States can. The

In my humble opinion, the quality of goods in general have gone down considerably since many brands and items have moved production overseas, particularly China. Japan seemed to make high quality goods, but many of their own companies have moved their production to lower cost countries and quality control has dropped as a result. For example, I will never again buy a pair of jeans from Wal-Mart (made in China) since their pockets were so thin the last time I got a pair a few years ago that they broke within a week with only a moderate load. The overall material is so thin (low thread count in general) that other people I read looking for comments claims they don't last any time at all in general.

In short, your claim of "better quality" is suspect at best. They're cheaper to make in those countries, yes, but that in no way implies quality in the slightest. I've read report after report about the problems with worker in Mexico, for example. Look at the conditions at clothing manufacturers in Bangladesh and the accidents occurring due to pure greed there. You can make all the excuses you want all day long and it won't change the fact that ethics have taken a back seat to GREED in virtually every large publicly traded company in history. People blame the stock holders demanding profit or whatever or whomever they want, but the fact is they don't give a crap who they hurt so long as they get paid, from the banks to the manufacturers. They do what they do and take the ridiculous risks (which taxpayers end up having to shore up with "too large to fail" banks) because they're greedy and no other reason.

The point I was making is that the U.S. is a member of the World Trade Organization which replaced GATT and mediates multilateral trade agreements around the world. The U.S. can't just unilaterally decide to abrogate its treaties and impose a 10% tariff because it can't figure out how to tax corporate efficiently, something that the rest of world does very nicely, as another poster to this thread rightly pointed out.

Yes, it's impossible for the U.S. to drop out of the world trade organization. :rolleyes:

It's impossible to for the U.S. repeal NAFTA ("Not A Fair Trade America")

It's just plain impossible for us to undo the crap we've created.

If you want to collect more money from Apple, just say so. Pass a law

You act like it's a simple matter to change laws with a corrupt government in a greedy society based on the excesses of the ultra-rich. Yeah, and I'll single-handedly eliminate all red tape, pork and wasted spending in general while I'm at it. Everyone says they want rid of those things and a solution to the debt, but no one wants to DO any of it because someone has to pay for it and any someones that get pointed to use their money to lobby their way out of it and the only people that don't have that available to them are ordinary citizens trying to make a living. We get stuck with the bill. We can't afford the bill either. But that's OK, run the rest up in debt and let our children and grandchildren and their grandchildren deal with it. As long as we got ours, that's all that matters. :cool:
 

samiwas

macrumors 68000
Aug 26, 2006
1,598
3,579
Atlanta, GA
But on the note of taxing foreign income in general, you're looking at it the wrong way. Two wrongs don't make a right. Taxing income earned by individuals who work overseas and earn their income overseas is absolutely ludicrous. So it's not right that you are taxed on foreign income.

You have said in previous posts about how if people/corporations use the resources of a country, they have should pay tax on it. That's all fine. But when you work overseas and earn income overseas, what US resources did you use? Why should you have to pay US tax on that income?

It's not "absolutely ludicrous" that a US citizen should have to pay tax on income, even if it's earned overseas while living overseas. It can be argued that the percentage should be very low, but not zero. If you need to use an embassy, it's there for you, and you should be paying taxes for that, just like people pay for schools even if they don't use them. You should also get a credit for taxes you pay in the country you are in. If you think you should pay no taxes, then you should also get zero benefit to being an American citizen.

This would also assume that none of the money you earn overseas ever makes its way to the US, via gifts, transfers to family, or into any accounts.
 

MagnusVonMagnum

macrumors 603
Jun 18, 2007
5,193
1,442
And the other shoe has dropped. Obama has proposed a massive mandatory tax today:

http://news-beta.slashdot.org/story...-tax-on-2-trillion-us-companies-hold-overseas

The other shoe has dropped? So you prefer letting companies like Apple skirt the US Tax system while every day middle class Americans have to pay through the nose in terms of percentages? Screw the top 1%. They've got more money than they know what to do with and want MORE MORE MORE while the rest of the country tries to figure out how the bleep to pay for their next meal. :rolleyes:

And for those of you that think it's ridiculous to pay US taxes as a US citizen when you work overseas, the solution is simple. Renounce your US Citizenship and you won't have to pay those taxes again. :)

Because the first time you need help at an embassy or protection from terrorist attacks that we deal with overseas, you then won't deserve any protection. US Citizens are STILL US citizens and have US rights when overseas and most of the world would LOVE to be in your position and are lining up at the border. One of them can have your place since you obviously don't want it. This country doesn't pay for itself to run or for its defenses to be built and groups like ISIS would LOVE for us to drop those defenses.

Everyone wants to live in the greatest country in the world and benefit from the protections thereof (including free speech) but they don't want to help keep it running and try to avoid paying taxes and the like at every turn. People like the Koch brothers will spend nearly a BILLION dollars over the next two years to promote the rich getting tax cuts over the long run so the system is even more imbalanced and corrupt. Go figure. :rolleyes:
 

Rocketman

macrumors 603
The other shoe has dropped?
The proposal is a retroactive tax on all accumulated foreign earnings for US headquartered firms of IIRC 14.5%, whether they repatriate it or not. That is a new revolutionary proposal, one might even say radical, hence the shoe drop metaphor. In this country we have long standing case law preventing ANY retroactive laws.

Apple itself suggested the following:

TESTIMONY OF APPLE INC. BEFORE THE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS said:
Apple has always believed in the simple, not the complex. This is evident in the
Company’s products and the way it conducts itself. In this spirit, Apple has recommended to the Obama Administration and several members of Congress – and suggests to the Subcommittee today – to pass legislation that dramatically simplifies the US corporate tax system. This comprehensive reform should:
• Be revenue neutral;
• Eliminate all corporate tax expenditures;
• Lower corporate income tax rates; and
• Implement a reasonable tax on foreign earnings that allows free movement of capital back to the US. Apple recognizes these and other improvements in the US corporate tax system may increase the Company’s taxes. Apple is not opposed to such a result if it occurs in the context of an overall improvement in efficiency, flexibility and competitiveness. Apple believes the changes it proposes will stimulate the creation of American jobs, increase domestic investment and promote economic growth.
Rocketman
 
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