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Like Apple, Google & Yahoo also avoid taxes by way of Ireland

post #1 of 133
Thread Starter 
Though they weren't grilled before a U.S. Senate subcommittee on Tuesday like Apple, Google and Yahoo rely on Irish subsidiaries to avoid taxes on billions of dollars in income, and they go one step further than Apple by utilizing offshore accounts.

Executives from Apple were called before the U.S. Senate Permanent Subcommittee on Investigations on Tuesday to respond to accusations of elaborate tax avoidance practices through a trio of subsidiaries based in Ireland. Apple Chief Executive Tim Cook told the committee that he was there of his own free will, compelled to appear because he wanted to personally give his side of the story.

Cork
Apple's headquarters in Cork, Ireland, via Flickr user Sigalakos.


Though some such as U.S. Sen. Carl Levin (D-Mich.) portrayed Apple's tax strategy as "unique," at least in scope, the tax shelter practice known by attorneys as the "Double Irish" is also utilized by tech companies Google and Yahoo.

Google has moved foreign profits through Ireland and the Netherlands, allowing to avoid about $2 billion in income taxes a year, according to Bloomberg. But unlike Apple, which manages its Irish subsidiary in the U.S., Google goes one step further and manages its Irish branch through Bermuda ? a British territory that has no corporate income tax.

Yahoo, too, is said to deposit its profits in an Irish subsidiary. Like Apple, Yahoo says its Irish arm is not a tax resident to avoid corporate income taxes. But Yahoo also employs a strategy similar to Google and claims its tax residency offshore, in the Cayman Islands.Unlike Google or Yahoo, Apple does not hold money on a Caribbean Island or have a bank account in the Cayman Islands.

Apple executives made it a point to differentiate themselves from those types of strategies in their official testimony this week. Specifically, the company noted it does not hold money on a Caribbean island, or have a bank account in the Cayman Islands.

With Tuesday's hearing, the U.S. Senate subcommittee took issue with current incompatibilities between U.S. and Irish tax laws. In Ireland, only companies that are managed and controlled in Ireland are considered tax residents. And in the U.S., tax laws are based on where a company is incorporated, rather than where it is managed and controlled.

Companies like Apple, Google and Yahoo have incorporated their subsidiaries in Ireland and managed those operations elsewhere to avoid corporate income taxes. But while Google and Yahoo manage their Irish subsidiaries overseas, Apple has instead controlled its operations from the company's corporate headquarters in Cupertino, Calif.

Wednesday's report from Bloomberg also noted that Yahoo has funneled hundreds of millions of dollars in profits through a Dutch bookkeeper's suburban home office. That money is then passed on to subsidiaries located in Mauritius and Switzerland.

Apple and Google, along with Amazon, were also faced with tax scrutiny in a report from the U.K. last year, which noted numerous companies take advantage of low tax rates in Ireland. A government investigation found that Amazon did not pay any British corporation tax in 2010 or 2011 by switching its European headquarters to Luxembourg.
post #2 of 133

Somewhere in the world, a gang of bank robbers are thinking, "Ireland? Billions?"

post #3 of 133
I'm willing to bet this will soon go away since Apple can't be singled out. Interesting.
post #4 of 133

This is nothing more than the greedy US government needing money that non-government agencies, or even private citizens, have. The government has no right to Apple or Google's funds that they have EARNED. The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products. It is an insult that the government with the biggest debt in the history of mankind on this planet, and still spending like there's no tomorrow, has the audacity to question the financial practices of the most valuable company in the world and tell them what they are doing wrong. They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.

post #5 of 133
Hang on, only a few days ago there was a story on here with some old c*** stating that Apple was ripping the arse out of the tax system using a method that was "unique to Apple". Now it turns out it is common place (and will probably therefore never be mentioned again).

I can't even see the old post about it on here any more.
post #6 of 133
Quote:
Originally Posted by thebudda View Post

They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.

They're already are. The Corporate States of America is run by the Corporates through Lobbyists. People don't run for office because they want to help the community, they ran for office because of the money that pours in from lobbyists.

post #7 of 133
Leave it to the US government to permit the destruction of our manufacturing industry in the name of globalization and now they will attack those company's who availed themselves of this. As Pogo said many years ago "we have met the enemy and he is us."
post #8 of 133
Quote:
Originally Posted by thebudda View Post

The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products.

 

What have the Romans ever done for us? Well, yes, apart from the roads. And the education system. Oh, and the sewage system. 

post #9 of 133
Quote:
Originally Posted by RichL View Post

What have the Romans ever done for us? Well, yes, apart from the roads. And the education system. Oh, and the sewage system. 

 

I see what you're doing there. I'll assume most others aren't dumb enough to fall for it (but I could be wrong on that.)

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post #10 of 133
Quote:
Originally Posted by dbtinc View Post

Leave it to the US government to permit the destruction of our manufacturing industry...

 

1confused.gif

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post #11 of 133
Incorporating a company gives certain government-granted privileges, not least of which is limited liability, a massive, massive boon for shareholders. Financial reporting and corporation tax are the price for that privilege.

If corporation tax is being aggressively avoided then government has a right to investigate and take measures to close the avenues for avoidance, as the incorporation agreement has been compromised.

My two cents.

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post #12 of 133
Quote:
Originally Posted by thebudda View Post

This is nothing more than the greedy US government needing money that non-government agencies, or even private citizens, have. The government has no right to Apple or Google's funds that they have EARNED. The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products. It is an insult that the government with the biggest debt in the history of mankind on this planet, and still spending like there's no tomorrow, has the audacity to question the financial practices of the most valuable company in the world and tell them what they are doing wrong. They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.

 

 
Except the government is responsible for building the roads that deliver Apple's products, the government also set up the system that educated many of the people who work at Apple. The government also make the laws that mean Apple can sue when Samsung infringes their IP. Apple move that IP to other countries & rent it back to decrease their tax bill, is that a reasonable way to do buisness, move assets to places tax is lower despite creating the IP in the US?
 
The same government pays for the courts & prison that stop people walking into Apple stores, factories & taking the products without paying. 
 
Go to countries where governments have less power & see what companies do, like Coca Cola in El Salvador, buying sugar cane from farmers who employ children, bullying Colombian street vendors out of unions (that help them get fair pay & healthcare) or depleting water tables in India. How about the biggest industrial disaster caused by Union Carbide in Bohpal. Or Shell's leaky pipelines ruining farmland in Nigeria, not to mention the lovely mess in the Gulf of Mexico that BP made. 
Johnson & Johnson also refused to pay disability benefits for long term employees, attempted to sue the Red Cross for trademark infringement, sound like they are the good guy, not in the least bit greedy?
 
You seem to think the government is the bad guy here, but big business is full of unscrupulous people who are willing to exploit the planet & other people for their own gain. I suspect you wouldn't be in the same position if the companies were the ones running the world, go find the real budda, you are not him.
post #13 of 133
Quote:
Originally Posted by thebudda View Post

They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.
They already are at the feet of big business, every election cycle the United Oligarchies of America elect your new leaders. You didn't think you did, did you?
A.k.a. AppleHead on other forums.
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post #14 of 133
Quote:
Originally Posted by RichL View Post

 

What have the Romans ever done for us? Well, yes, apart from the roads. And the education system. Oh, and the sewage system. 

 

 

Yeah, and look what Roman taxation did -- the over taxation of the people lead to the eventual downfall of the Empire. On the upside you didn't have to understand some ridiculously complicated tax code that applied differently to damn near everyone, they just took a percentage (a really BIG percentage) from everyone. 1wink.gif

post #15 of 133

I was going to reply like "Droid" did, but then I wasn't too sure if "thebudda" was being sarcastic or not.  After all governments do provide a ton of services that people and businesses take for granted - roads, sewers, clean water, law & order, etc., etc. etc..

 

Really, there is no one at fault here.  Apple pays over 7 Billion in taxes to the US, so they do pay taxes.  And we all try to avoid paying more taxes than we have to using legal means.  Apple is paying it's taxes.  On the other hand governments entice businesses to their own countries so that jobs are provided.  That's what Ireland has done.

post #16 of 133
Quote:
Originally Posted by Droid View Post

Except the government is responsible for building the roads that deliver Apple's products, the government also set up the system that educated many of the people who work at Apple. The government also make the laws that mean Apple can sue when Samsung infringes their IP. Apple move that IP to other countries & rent it back to decrease their tax bill, is that a reasonable way to do buisness, move assets to places tax is lower despite creating the IP in the US?

 

In addition, and to relate this more to Apple's products, government is responsible for the internet through DARPA, and the web, through CERN.  Government regulates the cellular spectrum so that Apple can sell just a small number of variants that will work almost worldwide.  Government funding of  Bletchley Park led to the computing breakthroughs that made the modern computing industry possible.

 

Government did not contribute a damn thing?  Fantasy.

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post #17 of 133
Quote:
Originally Posted by thebudda View Post

This is nothing more than the greedy US government needing money that non-government agencies, or even private citizens, have. The government has no right to Apple or Google's funds that they have EARNED. The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products. It is an insult that the government with the biggest debt in the history of mankind on this planet, and still spending like there's no tomorrow, has the audacity to question the financial practices of the most valuable company in the world and tell them what they are doing wrong. They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.


You're parroting the same thing, yet you ignore the fact that these companies depend on the court system, banking system, military, and diplomatic work. Perhaps you should consider some of this before mindlessly jumping to extremes.

post #18 of 133
Quote:
Originally Posted by thebudda View Post

The government has no right to Apple or Google's funds that they have EARNED. The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products

I'm all for smaller less wasteful government - and a smaller federal government with truly limited powers. But the statement above goes too far. The government (federal, state, and local) provides services these companies - and all citizens - rely on. Roads, bridges, fire departments, port inspections, treaty negotiation, standards development & enforcement, defense, and on and on. All those things get paid for with taxes.

 

"Taxes are the price we pay for a civilized society." - Oliver Wendell Holmes, Jr.

 

To say that the government "did not contribute a damn thing" is naive at best.

 

I do not blame Apple and any other company for reducing their tax burden as much as legally possible. If the laws are exploitable in unintended ways, then the government has the duty to fix those "loopholes". The companies have no obligation to say, "Oh, sorry, you didn't mean for us to do what these laws allow? Our bad. Here's more money."

 

- Jasen.

 

P.S. If we've all been trolled, he was very effective. Good catch.


Edited by jasenj1 - 5/22/13 at 6:59am
post #19 of 133
Quote:
Originally Posted by Damn_Its_Hot View Post

Yeah, and look what Roman taxation did -- the over taxation of the people lead to the eventual downfall of the Empire. 

 

Yeah, the downfall of one of the greatest empires the world has ever seen is attributable to a single thing as simple as taxation lol.gif

 

History runs to a different beat for anti-tax libertarians, doesn't it?

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post #20 of 133

Except that Apple is not evading anything, Apple is simply leveraging Ireland as the EU's most attractive location for this particular purpose and has been there for over 30 years.

 

If the US government wants to give incentives to companies to actually bring more foreign money into the US, don't double tax it at 35%, this way no sane person rightfully wants to bring any of it into the country.

 

At the same time, it is absolutely not the US government's business to judge about foreign tax rates, this is a problem to be dealt with within the EU. This is not US money, this is foreign money rightfully taxed where it was earned and the US government is not entitled to any of it. This is huge bullshit.

 

It is also stupid to hit at those EU headquarters, every multinational company has them and it really doesn't matter in which country they are located. If it wasn't Ireland it might have been any other EU country and the US government wouldn't get a penny of sales in the EU either.

 

Not sure what they are imagining...

post #21 of 133
Quote:
Originally Posted by Droid View Post

 

 
Except the government is responsible for building the roads that deliver Apple's products, the government also set up the system that educated many of the people who work at Apple. The government also make the laws that mean Apple can sue when Samsung infringes their IP. Apple move that IP to other countries & rent it back to decrease their tax bill, is that a reasonable way to do buisness, move assets to places tax is lower despite creating the IP in the US?
 
The same government pays for the courts & prison that stop people walking into Apple stores, factories & taking the products without paying. ...

 

 

The same government set up this quagmire of a tax code that now needs to be reformed. I dare say that the lobbyist for the tax lawyers and corporate accountants are probably the biggest impediment to the reform of the US tax laws.

post #22 of 133
Quote:
Originally Posted by bleh1234 View Post

They're already are. The Corporate States of America is run by the Corporates through Lobbyists. People don't run for office because they want to help the community, they ran for office because of the money that pours in from lobbyists.


Being a politician is a good gig. But do some research and you'll find out how many congressmen actually took a pay cut by entering politics. Quite a few are millionaires or otherwise quite well off. If money alone is the appeal, politics is not the most lucrative place to make it. That's not saying corruption doesn't exist. But it's saying only idiotic conspiracy theorists would believe that's the primary foundation of government.

post #23 of 133
Quote:
Originally Posted by Crowley View Post

 

In addition, and to relate this more to Apple's products, government is responsible for the internet through DARPA, and the web, through CERN.  Government regulates the cellular spectrum so that Apple can sell just a small number of variants that will work almost worldwide.  Government funding of  Bletchley Park led to the computing breakthroughs that made the modern computing industry possible.

 

Government did not contribute a damn thing?  Fantasy.

 

Correct however at the same time they should come down from their high horses and realise that there is a world beyond the US. As the US is not Apple's biggest market anymore, more money is earned internationally and this is nothing but logical.

Apple pays taxes where the money was earned and this is also true for using local infrastructures.

post #24 of 133
Quote:
Originally Posted by Crowley View Post

 

Yeah, the downfall of one of the greatest empires the world has ever seen is attributable to a single thing as simple as taxation lol.gif

 

History runs to a different beat for anti-tax libertarians, doesn't it?

 

Well, to be fair, I haven't studied the history of the Roman Republic and Empire in enough detail myself to make a particular claim here. But...that said...it's not an unreasonable claim in general. The point here is that taxation (forcibly taking people's property) becomes the fuel, the oxygen to the fire if you will, to a great many other evils. This is happening in the US as we speak. The "empire-ization" of the US has grown and been fueled by taxation (and borrowing). So while, surely there are other factors at play...it, when tracing back to root causes, certainly a claim worthy of consideration,

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post #25 of 133
Quote:
Originally Posted by cynic View Post

If the US government wants to give incentives to companies to actually bring more foreign money into the US, don't double tax it at 35%, this way no sane person rightfully wants to bring any of it into the country.

 

Double tax implies Apple have paid significant tax already.  They haven't.  Their tax rate through their Irish subsidiaries is less than 1%.

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post #26 of 133
Quote:
Originally Posted by Crowley View Post

Incorporating a company gives certain government-granted privileges, not least of which is limited liability, a massive, massive boon for shareholders.

 

Now this is a legitimate argument. In fact, I'd argue that in a true free-market, the only entity like this that could exist would be the corporation's ancestor: the joint-stock company (early versions of which did not have limited liability...which, as you note, is a government granted benefit.)

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post #27 of 133
Quote:
Originally Posted by Droid View Post

 

 
Except the government is responsible for building the roads that deliver Apple's products, the government also set up the system that educated many of the people who work at Apple. The government also make the laws that mean Apple can sue when Samsung infringes their IP. Apple move that IP to other countries & rent it back to decrease their tax bill, is that a reasonable way to do buisness, move assets to places tax is lower despite creating the IP in the US?
 
The same government pays for the courts & prison that stop people walking into Apple stores, factories & taking the products without paying.

 

Can we stop pretending that a) Apple has not paid taxes that pay for these things also, and, more importantly, b) that these thing can only be provided via taxation?

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post #28 of 133
Quote:
Originally Posted by Crowley View Post

Quote:
Originally Posted by Droid View Post

Except the government is responsible for building the roads that deliver Apple's products, the government also set up the system that educated many of the people who work at Apple. The government also make the laws that mean Apple can sue when Samsung infringes their IP. Apple move that IP to other countries & rent it back to decrease their tax bill, is that a reasonable way to do buisness, move assets to places tax is lower despite creating the IP in the US?

 

In addition, and to relate this more to Apple's products, government is responsible for the internet through DARPA, and the web, through CERN.  Government regulates the cellular spectrum so that Apple can sell just a small number of variants that will work almost worldwide.  Government funding of  Bletchley Park led to the computing breakthroughs that made the modern computing industry possible.

 

Government did not contribute a damn thing?  Fantasy.

Geeze, seriously Crowly?

"The Budda" Won't have any idea what you are even talking about. You are just as well to be making your points to a road apple.

post #29 of 133
Quote:
Originally Posted by MJ1970 View Post

 

Well, to be fair, I haven't studied the history of the Roman Republic and Empire in enough detail myself to make a particular claim here. But...that said...it's not an unreasonable claim in general. The point here is that taxation (forcibly taking people's property) becomes the fuel, the oxygen to the fire if you will, to a great many other evils. This is happening in the US as we speak. The "empire-ization" of the US has grown and been fueled by taxation (and borrowing). So while, surely there are other factors at play...it, when tracing back to root causes, certainly a claim worthy of consideration,

 

I don't think it's reasonable to say things like "it's not an unreasonable claim" when you self-confess to not having studied the history.  It's unreasonable to claim anything when you don't have any significant facts to draw upon.

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post #30 of 133
Quote:
Originally Posted by Crowley View Post

 

Yeah, the downfall of one of the greatest empires the world has ever seen is attributable to a single thing as simple as taxation lol.gif

 

History runs to a different beat for anti-tax libertarians, doesn't it?

 

I never said I was anti-tax. I think if you look at my other posts you will see that I believe in taxation, I just believe in a much simpler solution that is applied more even handedly by using a tax code that is not so full of exceptions for this and that. Those that claim that the govt. adds no value clearly don't understand and are living in a dream world. Those that think corporations should pay more than what is due under the law are also living in a dream world. To be competitive you have to try to play on a level playing field -- the corporation also has a fiduciary responsibility to make a reasonable profit for the stock holders which I would argue includes paying no more or less than what is required by law. Therein lies the problem -- the tax laws should not be written so obtusely that there is so much room for "interpretation".

 

BTW: @Crowley: I don't pretend to think that the Roman empire was toppled solely by excessive taxation but if you don't think it played a big role in it, and many other revolutions (including the US), then you to are dreaming.

post #31 of 133
Originally Posted by Crowley View Post
Double tax implies Apple have paid significant tax already.  They haven't.  Their tax rate through their Irish subsidiaries is less than 1%.

 

Again with your made up crap! Double tax implies being taxed twice. That's the definition of the word "double". That you can't wrap your head around the concept that you get to decide neither what is "significant" nor what is an acceptable amount of times to tax someone is YOUR problem.

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post #32 of 133
Quote:
Originally Posted by Crowley View Post

 

I don't think it's reasonable to say things like "it's not an unreasonable claim" when you self-confess to not having studied the history.  It's unreasonable to claim anything when you don't have any significant facts to draw upon.

 

Except I didn't claim I don't have significant facts to draw upon. Perhaps not about the Roman empire specifically, yes. But there are plenty of examples besides them. Plus, you know, logical deduction.

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post #33 of 133
Quote:
Originally Posted by Tallest Skil View Post

Again with your made up crap! Double tax implies being taxed twice. That's the definition of the word "double". That you can't wrap your head around the concept that you get to decide neither what is "significant" nor what is an acceptable amount of times to tax someone is YOUR problem.

 

+1

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post #34 of 133
Quote:
Originally Posted by thebudda View Post

This is nothing more than the greedy US government needing money that non-government agencies, or even private citizens, have. The government has no right to Apple or Google's funds that they have EARNED. The government did not contribute a damn thing to their research, development, investments, planning, production or marketing and sales of products. It is an insult that the government with the biggest debt in the history of mankind on this planet, and still spending like there's no tomorrow, has the audacity to question the financial practices of the most valuable company in the world and tell them what they are doing wrong. They should be at the feet of Apple, Exxon, Google, Johnson & Johnson, Coca Cola, Walmart and other successful businesses begging them for advice, and listening to it. Pathetic.

 

 

First, given the inclination, the government can do anything it wants. So deal with that. It tramples on the little people's so called rights everyday. Second, the US spends billions of dollars of US tax payer money funding oversea operations that primarily benefit companies like Apple. For instance, the US's trade representative is currently strong arming countries like Canada to pass draconian copy right related legislation. That costs money, doesn't benefit regular US citizens, and helps companies like Apple. Third, the government doesn't contribute directly to me doing my job in the US everyday, but yet I get taxed. 

 

Taxes are the price we pay to live in a civilized society. We want good roads, good schools, and public safety net programs. That has always been the backbone of the US economy. 

post #35 of 133
Quote:
Originally Posted by TBell View Post

Taxes are the price we pay to live in a civilized society.

 

1rolleyes.gif

 

I want to slap anyone that repeats this tired old non sequitur.

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post #36 of 133
Quote:
Originally Posted by cynic View Post

 

Correct however at the same time they should come down from their high horses and realise that there is a world beyond the US. As the US is not Apple's biggest market anymore, more money is earned internationally and this is nothing but logical.

Apple pays taxes where the money was earned and this is also true for using local infrastructures.

 

True enough, though the numbers show that Apple's international effective corporate tax rate is a joke.  A reasonable adjustment would be to allow corporations to pay a top-up tax to the IRS when repatriating, rather than the full 35%, with no allowance for local taxes paid.

 

I'm rather surprised that isn't the way it is already.

 

Question, because I don't know the ins-and-outs of the federal system, does the Federal corporation tax apply after State corporation taxes have been taken, or before or in parallel?

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post #37 of 133
Quote:
Originally Posted by Tallest Skil View Post

 

Again with your made up crap! Double tax implies being taxed twice. That's the definition of the word "double". That you can't wrap your head around the concept that you get to decide neither what is "significant" nor what is an acceptable amount of times to tax someone is YOUR problem.

 

Seriously?  That's a reasonable reaction?  Can you try not shouting through your tears of rage?

 

What are you really angry about?  

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post #38 of 133
Quote:
Originally Posted by Crowley View Post

True enough, though the numbers show that Apple's international effective corporate tax rate is a joke.

 

Yes, we know what your opinion is.

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post #39 of 133

Before people in Congress start throwing rocks at Apple, maybe they should look into Louis Vuitton? Any bags that are left over at the end of the year are burned up, and they take the tax credit. For one thing, they are so way overpriced it is ridiculous, and then they get a tax break because most people aren't stupid enough to pay $2800 for a bag that will be out of style in two years. This just makes me sick that the tax laws in this country allow this to happen. I wish somebody would look into it and fix it. "F" them all.

post #40 of 133
Quote:
Originally Posted by Tallest Skil View Post

 

Again with your made up crap! Double tax implies being taxed twice. That's the definition of the word "double". That you can't wrap your head around the concept that you get to decide neither what is "significant" nor what is an acceptable amount of times to tax someone is YOUR problem.

 

In genuine answer to your bluster.  Double taxation when used in the context of moral hazard implies that there's a danger that companies will be unduly punished.  For them to be unduly punished they must have paid a significant amount of tax in the first place, for any "double" taxation to pose any real impediment.

 

Of course I understand the technical logical meaning of double taxation.  But let's take a look at the real world here.  Double taxation clearly isn't something that threatens to wipe out Apple's profits with two high waves of government profit seizure.  How can I say that?  Because their effective tax rate in Ireland is less than 1%.

 

Now seriously, calm down.

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