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PanickyFool

Banned
Oct 25, 2017
5,947
Just think of the good that money could do. There's your free college, Healthcare and infrastructure with plenty leftover for jobs training and veterans services. But nope, greed is more important.
Well in the 80s as part of the last tax reform we shifted a huge amount of tax burden from the middle and upper class to corporations. Our corporations do have a huge tax burden compared to other industrial countries as a result. While large companies are able to legally avoid the the high tax rate by investing and saving overseas, the vast majority of mid and small size companies effectively get hot with a regressive tax as a result. -Because they do not have a reason to invest overseas.

Steve Jobs is rolling in his grave.

Sarcasm?
 

Panic Freak

Member
Oct 26, 2017
4,583
Governments around the world are cracking down on tax structures like these and moving to a system where entities which control, protect and develop IP will be entitled to the non-routine profits generated by companies. This is different from what the NYT is talking about because back then, simply owning rights to the IP entitled an entity to those non-routine profits. Now most governments are collecting what is known as a Country by Country report where large taxpayers report functional information along with financial information for each separate tax jurisdiction they operate in. That Country by Country report is shared automatically with other countries so if you identify a jurisdiction that generates 20 percent of the company's profits with zero headcount, it will raise red flags for challenges.
 

adamsappel

Member
Oct 27, 2017
2,503
Just think of the good that money could do. There's your free college, Healthcare and infrastructure with plenty leftover for jobs training and veterans services. But nope, greed is more important.
Not only that, but everyone working for Apple (and all of these companies) could get a nice salary bump, too.
 
Oct 25, 2017
1,293
Pretty safe to assume most people/companies/anything with a lot of money probably aren't being honest about said money (among many other things). But hey they create jobs right?
 

PanickyFool

Banned
Oct 25, 2017
5,947
I'm more shocked to not see Amazon on there.
Amazon deals in low margin physical goods, not so much creating intellectual property. The vast majority of their revenue comes from recognizing sales and the distribution centers getting those goods to the purchaser. They do not have as many methods to move profit available to them.

There is nothing morally defensible about sitting on hundreds of billions of dollars.

To be fair it is not just sitting there, they are gaining interest on it. And through the wonders if fractional reserve banking a large chunk of it is probably in the USA and mortgages or holding government debt.
 

eyeball_kid

Member
Oct 25, 2017
10,224
Yeah....that just isn't correct. At all.

It's tough to find more recent figures, but here's an article from 2014 on it.

https://www.irishtimes.com/business...11bn-profits-at-irish-unit-1.1715727?mode=amp

They're currently preparing for a legal battle to avoid paying €13 billion in back taxes to Ireland, but that is slightly different (and still nowhere close to being 6% of Irish tax revenue, which was around €45 billion last year.

It might've been 6% of all Irish corporate tax revenue. That's just the number I remember hearing on the BBC today.
 

oledome

Member
Oct 25, 2017
2,907
Defensiveness from me? Or from other people?

Because as far as I'm concerned, fuck all of these companies, including Apple.

I wasn't singling you out, I think for anyone to lead with "they all do it" is neither here nor there, Apple is going to have the headline since they're top of the list and it's more exciting than Pfizer.

My opinion is that if a government wants more tax they should change the tax laws with international cooperation, the idea that we can expect a company that seeks profits for shareholders to have a moral ambition to pay a penny more than it possibly has to is ludicrous.
 

Flo_Evans

Member
Oct 25, 2017
1,250
So are they moving profits from here over there or are these profits they made overseas?
 

Deleted member 3345

User requested account closure
Banned
Oct 25, 2017
4,967
So are they moving profits from here over there or are these profits they made overseas?

The latter.

Apple, for example, pays taxes at a small fraction of that rate on its offshore profits, according to calculations by The Times based on the company's securities filings. Apple reports that nearly 70 percent of its worldwide profits are earned offshore.

An Apple spokesman, Josh Rosenstock, declined to answer most questions about the company's tax strategy. He did say that Apple had told regulators — in the United States and Ireland and at the European Commission — about the reorganization of its Irish subsidiaries. "The changes we made did not reduce our tax payments in any country," he said.

He added: "At Apple we follow the laws, and if the system changes we will comply. We strongly support efforts from the global community toward comprehensive international tax reform and a far simpler system."

Every major US company has said the same thing as bolded.

Repatriation of profits is literally in the hands of legislature. But those fuck faces are too busy being assholes.
 

Dennis8K

Banned
Oct 25, 2017
20,161
The NY Times obtained leaked documents showing that tech giant Apple is hiding "billions of dollars" from the IRS: https://www.nytimes.com/2017/11/06/world/apple-taxes-jersey.html



Apple has the most money hidden from the U.S.

Capture5.PNG
What an excellent list to identify the CEOs that should be first in the guillotine for treason.

Pay your fucking taxes like the rest of us.
 

PanickyFool

Banned
Oct 25, 2017
5,947
So are they moving profits from here over there or are these profits they made overseas?
High margin companies like Apple are able to generate invoices from foreign subsidiaries against the parent company and other subsidiary companies to add costs and reduce the profit from high tax jurisdictions.

So for example, Apple Jersey will own the intellectual property and charge Apple USA a high per unit licensing fee for every unit sold in the USA.
 

KHarvey16

Banned
Oct 27, 2017
9,193
High margin companies like Apple are able to generate invoices from foreign subsidiaries against the parent company and other subsidiary companies to add costs and reduce the profit from high tax jurisdictions.

So for example, Apple Jersey will own the intellectual property and charge Apple USA a high per unit licensing fee for every unit sold in the USA.

What is "Apple Jersey"? What do they actually own?
 

PanickyFool

Banned
Oct 25, 2017
5,947
What is "Apple Jersey"? What do they actually own?
Probably a mailbox and the intellectual property, patents, trade secrets, R&D assets of the iPhone, iPad, etc. Basically Apple Jersey owns the design and engineering of the hardware and software. My assumption but that is one very easy way to do it.

It is very easy to move non-plant assets.
 

numble

Member
Oct 25, 2017
814
Do you have a specific question?

I don't think you can even get people in this thread to agree on what a fair outcome in terms of global taxation of multinationals should be. Some think it should all go to the IRS. Is it fair if that profit is a product of a Chinese assembler, a German Apple Store employee and a French consumer? Should it all go to Ireland because the Irish Apple entity owns the IP? I think a fair outcome would be some sort of global formulary apportionment, but you will never get countries to agree on the proper allocation. China could say that they deserve to tax 40% of the profit if 90% of the labor and 30% of the end consumer market is located in China, US could say they deserve to tax 90% of profits because the headquarters are domiciled in the US and the IP is generated there.

What you have now is a disjointed system encouraging legal arbitrage.
What you get with BEPS is some minor changes on the side that may allow countries to tax a little bit more.
At cross-purposes what you get with US tax reform and the international move towards territorial tax systems is that you still end up encouraging most multinational profit to not be subject to tax as countries around the world are all starting agree to not tax foreign profit.
 

KHarvey16

Banned
Oct 27, 2017
9,193
Probably a mailbox and the intellectual property, patents, trade secrets, R&D assets of the iPhone, iPad, etc. Basically Apple Jersey owns the design and engineering of the hardware and software. My assumption but that is one very easy way to do it.

It is very easy to move non-plant assets.

Your assumption based on what they could do or what someone with knowledge is suggesting they're doing specifically?
 

numble

Member
Oct 25, 2017
814
High margin companies like Apple are able to generate invoices from foreign subsidiaries against the parent company and other subsidiary companies to add costs and reduce the profit from high tax jurisdictions.

So for example, Apple Jersey will own the intellectual property and charge Apple USA a high per unit licensing fee for every unit sold in the USA.

Probably a mailbox and the intellectual property, patents, trade secrets, R&D assets of the iPhone, iPad, etc. Basically Apple Jersey owns the design and engineering of the hardware and software. My assumption but that is one very easy way to do it.

It is very easy to move non-plant assets.
No need to make stuff up. The information is available in the article as well as the EU Commission's documents. There is very little tax planning to reduce US HQ profit due to the way the US tax rules are setup. The planning is all around foreign income.

Apple Sales International and Apple Operations Europe are two Irish incorporated companies that are fully-owned by the Apple group, ultimately controlled by the US parent, Apple Inc. They hold the rights to use Apple's intellectual property to sell and manufacture Apple products outside North and South America under a so-called 'cost-sharing agreement' with Apple Inc. Under this agreement, Apple Sales International and Apple Operations Europe make yearly payments to Apple in the US to fund research and development efforts conducted on behalf of the Irish companies in the US. These payments amounted to about US$ 2 billion in 2011 and significantly increased in 2014. These expenses, mainly borne by Apple Sales International, contributed to fund more than half of all research efforts by the Apple group in the US to develop its intellectual property worldwide. These expenses are deducted from the profits recorded by Apple Sales International and Apple Operations Europe in Ireland each year, in line with applicable rules.

...

Apple Sales International is responsible for buying Apple products from equipment manufacturers around the world and selling these products in Europe (as well as in the Middle East, Africa and India). Apple set up their sales operations in Europe in such a way that customers were contractually buying products from Apple Sales International in Ireland rather than from the shops that physically sold the products to customers. In this way Apple recorded all sales, and the profits stemming from these sales, directly in Ireland.

The two tax rulings issued by Ireland concerned the internal allocation of these profits within Apple Sales International (rather than the wider set-up of Apple's sales operations in Europe). Specifically, they endorsed a split of the profits for tax purposes in Ireland: Under the agreed method, most profits were internally allocated away from Ireland to a "head office" within Apple Sales International. This "head office" was not based in any country and did not have any employees or own premises. Its activities consisted solely of occasional board meetings. Only a fraction of the profits of Apple Sales International were allocated to its Irish branch and subject to tax in Ireland. The remaining vast majority of profits were allocated to the "head office", where they remained untaxed.

Jersey is just the new tax residence of the Irish-incorporated companies, Apple Sales International and Apple Operations International.
 

Suiko

Member
Oct 25, 2017
2,931
Yeah, taxation has not caught up to globalism in the slightest.

IP is the most complicated aspect of it. Otherwise a system where taxation occurs primarily on the people and investment would cover it.
There has been a race to the bottom on corporate taxes, so i've argued that you just hit the bottom and make up taxes elsewhere. Corporations can use tax havens for profits, so make it pointless to do so. But on the other hand it's really complicated and inefficient to do the same with people and investments. Government leverage exists with people, and not paper entities.

The arguments will ultimately become about IP and factoring in Negative Externality costs incurred by the presence of corporations. We don't want a race to the bottom on environmental and human regulations.
It's going to require multi-country agreements, and that's a very tall endeavour.
 

PanickyFool

Banned
Oct 25, 2017
5,947
Do you have a specific question?

I don't think you can even get people in this thread to agree on what a fair outcome in terms of global taxation of multinationals should be. Some think it should all go to the IRS. Is it fair if that profit is a product of a Chinese assembler, a German Apple Store employee and a French consumer? Should it all go to Ireland because the Irish Apple entity owns the IP? I think a fair outcome would be some sort of global formulary apportionment, but you will never get countries to agree on the proper allocation. China could say that they deserve to tax 40% of the profit if 90% of the labor and 30% of the end consumer market is located in China, US could say they deserve to tax 90% of profits because the headquarters are domiciled in the US and the IP is generated there.

What you have now is a disjointed system encouraging legal arbitrage.
What you get with BEPS is some minor changes on the side that may allow countries to tax a little bit more.
At cross-purposes what you get with US tax reform and the international move towards territorial tax systems is that you still end up encouraging most multinational profit to not be subject to tax as countries around the world are all starting agree to not tax foreign profit.
I always thought the fair solution was a VAT combined with income and payroll taxes, and destruction of the concept that capital gains is not income.

A corporation gets liability protection, but can't vote, so taxing the entity is perfectly fair. The corporation also benefits from government services in the market it is selling in. Revenue can't easily be manipulated, so tax revenue.

In developing and producing the product the corporation is using local government services and either local labor or local capital. Local labor is a payroll tax, local capital (or sub contractor) would be covered in VAT.

Then profit, where ever it is distributed or equity sold is an income to the owner(s).

Corporate income tax dodging by manipulating costs always seemed like an easy fix to me. A revenue tax, a payroll tax, and a capital gains tax (at income rates) seems logical.
 

Flo_Evans

Member
Oct 25, 2017
1,250
High margin companies like Apple are able to generate invoices from foreign subsidiaries against the parent company and other subsidiary companies to add costs and reduce the profit from high tax jurisdictions.

So for example, Apple Jersey will own the intellectual property and charge Apple USA a high per unit licensing fee for every unit sold in the USA.

I see. Just finished the article. This is like the big boy version of my sister claiming to live at her boyfriends place in another state to avoid property tax on her car lol.

Pretty fucking disgusting. But at the same time I have some ideas. Taking a company retreat to Cancun in a week... maybe we should setup a banana stand? *winkwink*
 

Enduin

You look 40
Member
Oct 25, 2017
11,470
New York
A sane country would go after these companies tooth and nail for this bullshit. But instead Republicans will champion these companies and use this to just say they're the real victims of unfair and punitive corporate taxes and if we only lowered and removed these taxes on foreign profits, and in general, we'd see all this money flowing back into the US.
 

Tuck

Member
Oct 25, 2017
3,576
Well, its not illegal. But it should be. I'm just not sure how to realistically prevent companies from exploiting loopholes - seems like closing loopholes is an endless chase.
 

PanickyFool

Banned
Oct 25, 2017
5,947
No need to make stuff up. The information is available in the article as well as the EU Commission's documents. There is very little tax planning to reduce US HQ profit due to the way the US tax rules are setup. The planning is all around foreign income.



Jersey is just the new tax residence of the Irish-incorporated companies, Apple Sales International and Apple Operations International.
Ah I see, so they are not really being that sketchy.

Hypothetically speaking, they could divest Apple sales international, give every shareholder in AAPL an equivalent holding in ASI. Establish an R&D/IP contract as they have now. And aside from the tax implications to the largely American shareholder base, no big difference accounting wise but a huge difference in political optics?
 

KHarvey16

Banned
Oct 27, 2017
9,193
A sane country would go after these companies tooth and nail for this bullshit. But instead Republicans will champion these companies and use this to just say they're the real victims of unfair and punitive corporate taxes and if we only lowered and removed these taxes on foreign profits, and in general, we'd see all this money flowing back into the US.

How, and how much, should Apple be taxed by the US for things it sells outside the US?
 

Mona

Banned
Oct 30, 2017
26,151
So nobody but the poor and middle class have to pay their taxes, now I understand
 

Deleted member 19003

User requested account closure
Banned
Oct 27, 2017
3,809
Fuck Apple. Another reason not to buy their overpriced stuff. I hope all the companies on that list have the loop hole closed, shameful.