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Like Apple, Google & Yahoo also avoid taxes by way of Ireland - Page 2

post #41 of 133
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Originally Posted by ankleskater View Post


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.

 

Look at somebody like former Vice President Cheney. He left his role as CEO of Haliburton. He, however, had lots of stock in the company. Once VP, he influenced policy to invade Iraq and give Haliburton very valuable contracts. Once you are super wealthy, power and status is more alluring. Further, you can use that power to make yourself even more wealthy. There are endless tales of people being appointed to various government positions only to use their power there to secure great positions afterwards. 

post #42 of 133

But we don't have good roads, good schools or decent public safety net systems in place, so what good are our taxes? There is nobody in this country that can say our monies are being put to not only good use or even proper use.

post #43 of 133
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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%.

 

Actually by definition double is twofold an amount or twice the original sum. Since you seem to be big at picking at nits today it would be more accurately described as being taxed again on the same profit. It really has nothing to do with whether you think Apple has "paid significant tax already".

 

Multiple entities taxing the same profit is quite common. In the US most states have a state income tax as well as the federal income tax we all have to pay (I happen to live in one of a couple that doesn't). Most are not to thrilled by this either but they do have a choice, to do something about the tax code. or just to pay it, or move to some state that does not have an income tax.

post #44 of 133
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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%.

 

Actually, Apple has paid significant tax already ....6 Billion dollars, soon to be 7 Billion. All to the good old US government. They are said to have paid almost 3% of the governments collected taxes. Not too shabby. What the government wants is to be able to tax Apple on it's worldwide profits (stuff not sold in USA). What Apple has done is to create a holding company to collect after tax profits from all over the world (minus the Americas) and put it into this Irish holding company to manage their investments. The profits on their investments is taxed by the US and paid by Apple. Apple are duty bound to their shareholders to maximize profits and minimize expenses. Taxes are an expense. Apple is only doing what they should rightfully be doing. You want to blame someone, blame the government that wastes so much money and mismanages the system and just keeps the printing presses rolling to cover up their mistakes (and handing out $$ to their friends and lobbyists.) It's a broken system, folks. It needs to be overhauled, if it isn't too late, already.
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post #45 of 133
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Originally Posted by Evilution View Post

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.

Considering the evidence Apple is "unique" in that it uses fair tactics that don't funnel money from the US to the cayman Island and other places commonly used by politicians and mobsters.

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post #46 of 133
Quote:
Apple has real operations, in real places, with Apple employees selling real products to real customers. We not only comply with the laws but we comply with the spirit of the laws. We don't move intellectual property offshore and use it to sell products back in the U.S. Our foreign subsidiaries pull 70% of our cash because of the rapid growth of our international business. We use this money to finance construction of Apple retail stores around the world and fund production of products. It would be very expensive to bring that cash back to the United States. Unfortunately the tax code has not kept up with the digital age. We are handicapped in relation to our foreign competitors who do not have such constraints on the free movement of capital.
 
- Apple exec to Senate Committee

 

Apple doesn't move IP offshore. Apple's competitors (particularly Samsung) probably pay far far less tax on earnings on US soil because they are foreign.

 

This whole argument is whether the US taxman is entitled to tax income from overseas earnings which were already taxed once, whether 2% in Ireland, or 20% as in the UK.

post #47 of 133
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Originally Posted by newbee View Post

Actually, Apple has paid significant tax already ....6 Billion dollars, soon to be 7 Billion. All to the good old US government. They are said to have paid almost 3% of the governments collected taxes. Not too shabby.What the government wants is to be able to tax Apple on it's worldwide profits (stuff not sold in USA). What Apple has done is to create a holding company to collect after tax profits from all over the world (minus the Americas) and put it into this Irish holding company to manage their investments. The profits on their investments is taxed by the US and paid by Apple. Apple are duty bound to their shareholders to maximize profits and minimize expenses. Taxes are an expense. Apple is only doing what they should rightfully be doing.You want to blame someone, blame the government that wastes so much money and mismanages the system and just keeps the printing presses rolling to cover up their mistakes (and handing out $$ to their friends and lobbyists.) It's a broken system, folks. It needs to be overhauled, if it isn't too late, already.

It's sad that this needs to get explained again and again. Watching Cook patiently explain to McCain over and over what should be obvious was more stressful than teaching my grandmother how to use any modern technology.

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post #48 of 133
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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.

Yes and no. The government does support companies via various services such as police etc. And it is not far fetched to say that companies should contribute to the running of the government that creates laws to protect that research

So it is fair to say that yes companies owe something. Is the nature of that something, the math that computes it, what they get out of it for their money that is the real debate at the moment.

The US government should not have a claim in money earned outside of the US I agree. No government should have claim on a cut of funds earned out of their borders anymore than Apple can claim 30% of sales in the Android version of a game because it is also on iOS.

And if the US government created laws that make it legal for Apple to divide up their control into this regions to facilitate that each area gets the legally determined money from sales etc in that area so be it. As Cook said, change the laws. Course Cook etc will fight if its too greedy but at least the government would be doing something other than saying 'we know its legal but we still think you shouldn't do it cause you make a ton of money and we want more cause the government is broke'

If a company is doing something nefarious like the IP games Cook says Apple doesn't do to actually 'avoid' taxes, or hiding money from the government and not reporting all US earnings appropriately, that's another game. That is money that the US deserves. Bring out proof Apple is doing this and bring charges. Don't waste tax payer dollars on hearings to play games.

And while they are at it, the government should look at what they are giving for the money they do get. Like the IP situation.

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post #49 of 133
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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.

Yep, you get the government that paid for it. The choice is a bitch though, it's either that or the opposite extreme where you get the government that will shoot you if you don't vote for them. Democracy was a dream the Greeks had.
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post #50 of 133
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Originally Posted by Crowley View Post

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?

Since you admit that you don't know how the system works, why are you blathering about it at all?

And who is to say what a 'reasonable adjustment' is? Obviously, not someone who admits that he doesn't know how the system works.

The issue is far more complicated than you are implying. You are apparently unable to distinguish between income and assets.

Apple pays income tax where the income is earned - which is in compliance with tax laws around the world. If the effective tax rate in Ireland is 2% (or 0.0002%, for that matter), then no one outside of Ireland should have any say in the matter. Each country sets its own tax rates and it's not up to you to criticize them. If they don't want to charge ANY corporate income tax, that's their choice. (By the same token, why aren't you running around protesting that the states that don't charge sales tax are unfair?)

The issue here is what to do about bringing cash into the US which has been earned elsewhere. It's essentially the same as if you buy a truck overseas and ship it here - it's an asset that is being transferred. In some states, you are required to pay sales tax in a situation like that, but not very many. If it's your truck and you bring it here, it remains your truck and you don't have to pay for it again. Similarly, the argument is that if Apple moves an asset (cash) from one place to another, it shouldn't be taxed since they've already paid tax where the asset was earned. Paying income tax again is double taxation. This is, of course, complicated by corporate structures where Apple may also be moving the asset from one entity to another - which can sometimes create tax liabilities. Either way, the argument that income earned in a different country should be taxed at the same rate as income earned in the US is suspect from the start.
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post #51 of 133
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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. 

In the US most of that is on the state level. What is the US government doing in return for the money they have earned. IP protection laws? In theory perhaps but in truth the laws are a mess the legal system slow etc. that someone can be a patent troll legally is horrid. And Cook had no issue pointing this out yesterday

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post #52 of 133
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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. 

 

Russia has contributed Google CEO to US.  

post #53 of 133
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Originally Posted by SolipsismX View Post

It's sad that this needs to get explained again and again. Watching Cook patiently explain to McCain over and over what should be obvious was more stressful than teaching my grandmother how to use any modern technology.

It is fascinating to observe though, the professional politicians doing what they always do. Simply repeating the same lines ad nauseam all the while ignoring what is said to them. It is done by all of them all the time especially for the media who always move and and thank them for their time even though they never got their question answered. It is very rare that an interviewer challenges this, Chris Matthews is one of a few that refuse to take this crap (not selected for his political views here, rather his refusal to take BS from either side). I think this was a healthy experience and possibly a game changer (I hope) as so many people of an above average IQ , Apple enthusiasts 1wink.gif ... saw this in its most naked form and just might wake up and say 'why do we constantly tolerate this?'
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post #54 of 133
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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%.

Show us proof that the money that is going through Ireland was earned in the US or even anywhere that wasn't the EU.

Apple says they pay the appropriate US taxes in US earnings and what goes through Ireland is EU earnings taxed as required by EU laws. It is not a US issue that the EU laws allow them to use a country with a low tax rate nor does it mean that the US government can make claim to the other 34% cause the EU didn't demand it, but that is what their taxes in money transfers between international divisions at full rate is doing. 5% is more like it.

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post #55 of 133
Originally Posted by Crowley 
It's funny how often you resort to the same fallbacks, can't argue, so scream that the opposition has not argument.  It doesn't work that way pal.

 

If you want to have civilised conversation then we can move on, otherwise I'm just going to ignore you.

 

Thanks for giving up. For a second I thought you might have actually been challenged enough to believe what you were saying earlier.

post #56 of 133
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Originally Posted by TBell View Post


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. 

Then I demand my money back. Because where I live the roads are trash, the public schools are a joke (yet I have to pay those taxes despite also paying tuition for private schools) and our public safety system ignores cussing putrid smelling vagrants panhandling in violation of loitering and solicitation laws on a daily basis ten feet from them while they drink their Starbucks. They also don't do anything about drivers holding cell phones in violation of the law, not yielding to pedestrians who have the walk etc. all in front of them

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post #57 of 133
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Originally Posted by Crowley View Post

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.

Why? There's no global tax or government. So why should the US enforce that a company must give up any cut of their income to a government and take what the locals didn't for themselves. If the EU only wants 5% or whatever it is on the money earned in their borders that doesn't given the US a claim to the other 30%. Anymore than if I live in LA for six months and the move to NYC, California has no claim to any of my New York income simply because the tax rate there is less than what I would have paid if I was still living and working in California.

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post #58 of 133
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Originally Posted by massconn72 View Post

Before people in Congress start throwing rocks at Apple, maybe they should ll.

Look at themselves. What legal tricks are they using to not pay every penny they can.

There are a lot of folks that believe that Congress doesn't want to see the tax codes change because they would have to pay more taxes. And they don't want to.

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post #59 of 133
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Originally Posted by charlituna View Post

There are a lot of folks that believe that Congress doesn't want to see the tax codes change because they would have to pay more taxes. And they don't want to.

 

That's what my accountant keeps telling me.

 

He also keep telling me "Obama is hungry."

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post #60 of 133
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Originally Posted by newbee View Post

 

Actually, Apple has paid significant tax already ....6 Billion dollars, soon to be 7 Billion. All to the good old US government. They are said to have paid almost 3% of the governments collected taxes. Not too shabby.What the government wants is to be able to tax Apple on it's worldwide profits (stuff not sold in USA). What Apple has done is to create a holding company to collect after tax profits from all over the world (minus the Americas) and put it into this Irish holding company to manage their investments. The profits on their investments is taxed by the US and paid by Apple. Apple are duty bound to their shareholders to maximize profits and minimize expenses. Taxes are an expense. Apple is only doing what they should rightfully be doing.You want to blame someone, blame the government that wastes so much money and mismanages the system and just keeps the printing presses rolling to cover up their mistakes (and handing out $$ to their friends and lobbyists.) It's a broken system, folks. It needs to be overhauled, if it isn't too late, already.

 

 

That's great.  I don't think anyone is criticising anything about Apple's corporation tax on its profits in the USA.A

 

And I do blame the governments.  I've said more than once that while I don't condone what Apple have set up, I think it's very clever and I don't blame them for doing it.  But they have been allowed to do it via gaps in the international tax system and insufficient regulation of transfer pricing by governments.  If you're going to applaud them for paying so much tax in the USA then can you not see that it is reasonable for citizens of other countries to say "hang on, why not us too?".  And further to that, it is interesting to explore ideas for what needs to be done to prevent it, to Apple's detriment, without seeing such discussions as an attack on Apple itself but as an attack on aggressive tax avoidance in general.

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post #61 of 133
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Originally Posted by charlituna View Post

In the US most of that is on the state level. What is the US government doing in return for the money they have earned. IP protection laws? In theory perhaps but in truth the laws are a mess the legal system slow etc. that someone can be a patent troll legally is horrid. And Cook had no issue pointing this out yesterday

Let's see if we can find a few things that your federal taxes pay for - that benefit companies:

The Federal government:
1. Pays a large part of the cost of educating our kids.
2. Pays a large part of the cost of roads, ports, airports, etc.
3. Pays to defend our country (which is an enormous portion of the total tax revenues). Without a Federal Government, you'd probably be speaking Russian. Or maybe Chinese.
4. Provides the backbone of a banking system which is the envy of the world
5. Provides for rules that regulate pollution, food production, and so on. WIthout the Federal government, you'd probably be sick from pollution and bad food.
6. Invests enormously in technology development. It would be nearly impossible to find any existing technologies that weren't funded, at least in part, by the Federal Government.
7. Patents and other laws which provide for IP protection - which allows companies to profit from their own innovation.

There are many more, but that's a start. Arguing that companies don't benefit from Federal expenditures is just plain absurd.
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post #62 of 133
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Originally Posted by Crowley View Post


That's great.  I don't think anyone is criticising anything about Apple's corporation tax on its profits in the USA.A

And I do blame the governments.  I've said more than once that while I don't condone what Apple have set up, I think it's very clever and I don't blame them for doing it.  But they have been allowed to do it via gaps in the international tax system and insufficient regulation of transfer pricing by governments.  If you're going to applaud them for paying so much tax in the USA then can you not see that it is reasonable for citizens of other countries to say "hang on, why not us too?".  And further to that, it is interesting to explore ideas for what needs to be done to prevent it, to Apple's detriment, without seeing such discussions as an attack on Apple itself but as an attack on aggressive tax avoidance in general.

Still waiting for your evidence that Apple's transfer pricing is unfair. (and why haven't you provided this evidence to the IRS? If you bring evidence of tax evasion to the IRS, you get a share of the tax collected). And if Apple is selling the phones to Apple US at just under the retail price, how did they generate $20 B in profits and $6 B in tax liability?
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post #63 of 133
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Originally Posted by charlituna View Post

 It is not a US issue that the EU laws allow them to use a country with a low tax rate

 

Agreed. It's an EU (and constituent) issue.

 

Tax havens however are a global issue, so I don't think that particular conversation needs to stop at the EU.  Indeed it looks like it'll be a big topic at the G8, which probably means that nothing will happen for about a decade.

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post #64 of 133
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Originally Posted by jragosta View Post


Let's see if we can find a few things that your federal taxes pay for - that benefit companies:

The Federal government:
1. Pays a large part of the cost of educating our kids.
2. Pays a large part of the cost of roads, ports, airports, etc.
3. Pays to defend our country (which is an enormous portion of the total tax revenues). Without a Federal Government, you'd probably be speaking Russian. Or maybe Chinese.
4. Provides the backbone of a banking system which is the envy of the world
5. Provides for rules that regulate pollution, food production, and so on. WIthout the Federal government, you'd probably be sick from pollution and bad food.
6. Invests enormously in technology development. It would be nearly impossible to find any existing technologies that weren't funded, at least in part, by the Federal Government.
7. Patents and other laws which provide for IP protection - which allows companies to profit from their own innovation.

There are many more, but that's a start. Arguing that companies don't benefit from Federal expenditures is just plain absurd.

 

Most of that could (and should) be done privately. Only defense (actual defense) and perhaps some pollution stuff arguably must be done through the government. IP protection is government granted monopoly and, arguably, isn't necessary either.

 

The argument is not "plain absurd."

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post #65 of 133
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Originally Posted by jragosta View Post

Still waiting for your evidence that Apple's transfer pricing is unfair.

 

I'm really not sure how I can providence any evidence better than them paying less than 1% corporation rate on the fortune in the Irish subsidiaries, and a similar effective tax rate throughout the whole of Europe.  It's clear avoidance.

 

If you don't think that's unfair, well that's your call.  I do.  It deprives governments of revenue, creates unfair advantage over competitors, and rewards duplicitous practices.

 


Quote:
Originally Posted by jragosta View Post

(and why haven't you provided this evidence to the IRS? If you bring evidence of tax evasion to the IRS, you get a share of the tax collected)

 

There is no suggestion of tax evasion.  No one has alleged that Apple has done anything illegal.  Besides which, I'm not even sure how I'd do that even if I did have the inclination; I'm not a US citizen.

 

 

Quote:
Originally Posted by jragosta View Post

And if Apple is selling the phones to Apple US at just under the retail price, how did they generate $20 B in profits and $6 B in tax liability?

 

Apple aren't selling the phones to Apple US at just under the retail price.  Not sure what you got that from, but it's not from me, I've never said that.

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post #66 of 133
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Originally Posted by MJ1970 View Post

 

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.

 

At best, you've engaged in logical inference, not deduction, and an argument by analogy is as weak as the similarities between the situations. Since you've admitted you don't know enough about the Roman Republic or Empire, "to make a particular claim," one would expect that you wouldn't, rather than assert a flight of fancy and wishful thinking as "reasonable". How could it possibly be reasonable if you don't have sufficient knowledge to determine if it's reasonable? Even if you were correct, it would be nothing more than a lucky guess.

post #67 of 133

As Apple pointed out in the hearing, they set up the Irish division back in 1980, and what did not say is why. They did this at the time due to the fact the EU was hitting any product not produced in the EU with a 40% tariff. Apple choose Ireland because the had the unique tax incentive and the fact their unemployment was over 25% at time. Ireland was doing whatever they could to draw manufacturing company to Ireland so Apple jump on the deal. No one in our government was screaming at the EU for their 40% tariff for product made outside the US.

 

Apple had its factory there for a long time, even in the 90's when apple was downsizing and was about to layoff 50% of the workforce at the factory. The PM of Ireland came to Cupertino to visit the then CEO and explain to him what would happen to Apple business in the EU if they continue to layoff worker in Ireland. Needless to say those workers still had jobs, but apple completely shut down the Fremont CA factory, Again no one in our Government both US or CA said a word.

 

Here we are 2013 Apple is still operating the Ireland division, no longer as factory, so they must have stuck another deal with Ireland to shut that down, but according to Cook own testimony they employ 3000 people in Ireland to manage the EU business for them. Various people in the Senate panel keep saying or inferring that the Irish Division was a shell company and no one work there, they kept saying it even after Cooks comment they had 3000 people there. In typical government fashion ignore the facts when they do not back out your conclusions.

 

I have to say the Apple team handle themselves well and the Senator for the most part look like idiots

post #68 of 133
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Originally Posted by MJ1970 View Post

 

Most of that could (and should) be done privately. ...

 

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post #69 of 133
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Originally Posted by anonymouse View Post

 

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post #70 of 133

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Originally Posted by jragosta View Post


Since you admit that you don't know how the system works, why are you blathering about it at all?

And who is to say what a 'reasonable adjustment' is? Obviously, not someone who admits that he doesn't know how the system works.

The issue is far more complicated than you are implying. You are apparently unable to distinguish between income and assets.
 

 

I don't know every detail of the US tax system.  From what I hear I doubt anyone does.   That I admit that i don't know everything is a pretty poor reason to bash down any argument.

 
Thanks for graciously answering my question btw.  Do you know the answer?
 
Quote:
Originally Posted by jragosta View Post

Apple pays income tax where the income is earned - which is in compliance with tax laws around the world. If the effective tax rate in Ireland is 2% (or 0.0002%, for that matter), then no one outside of Ireland should have any say in the matter.  Each country sets its own tax rates and it's not up to you to criticize them. If they don't want to charge ANY corporate income tax, that's their choice. (By the same token, why aren't you running around protesting that the states that don't charge sales tax are unfair?)

 

 

That would be fine if Apple's economic activity was indisputably in Ireland.  The two subsidiaries AOI and ASI that book income for Apple in Ireland have no employees, and exist merely as logical facades to siphon off the illusion of where profits are made, precisely so that Apply can achieve a low tax rate.  That's a misrepresentation of income, so it is very appropriate for other countries to question this arrangement.  Ireland can set it's tax rate wherever it wants, but companies should not be allowed to pretend that things are happening in Ireland just to take advantage of that rate.  That's almost the dictionary definition what they call "a loophole".

 

Also, while Ireland can set its tax laws however it wants, that doesn't mean it gets criticism immunity, and its bizarre rule about only charging corporation tax if the company is "controlled" from domestic territory is frankly bizarre, and clearly Apple has exploited that too.

 

I think states that don't charge sales tax are fine.  Sales tax is a flat tax (or regressive, by some definitions as discussed in another thread).  I prefer progressive ones.

 


Quote:
Originally Posted by jragosta View Post

The issue here is what to do about bringing cash into the US which has been earned elsewhere.
 

Actually I don't think this thread has much to do with repatriation at all, I think it's to do with core problems with Ireland and the EU's tax regime.  Maybe we've been talking at cross-purposes, which is why you seem to have misunderstood some of what I've said?

 


Quote:
Originally Posted by jragosta View Post

The issue here is what to do about bringing cash into the US which has been earned elsewhere. It's essentially the same as if you buy a truck overseas and ship it here - it's an asset that is being transferred. In some states, you are required to pay sales tax in a situation like that, but not very many. If it's your truck and you bring it here, it remains your truck and you don't have to pay for it again. Similarly, the argument is that if Apple moves an asset (cash) from one place to another, it shouldn't be taxed since they've already paid tax where the asset was earned. Paying income tax again is double taxation. This is, of course, complicated by corporate structures where Apple may also be moving the asset from one entity to another - which can sometimes create tax liabilities. Either way, the argument that income earned in a different country should be taxed at the same rate as income earned in the US is suspect from the start.
 

There are certainly discussions that can be had, but the subsidiaries in Ireland have been set up in a deliberate way so that they don't owe corporation tax to any country.  Apple is effectively channeling profits out of the taxation system.  The threat of double taxation is being used as a weapon to allow zero taxation.  I'm of the opinion that something should be done about that, whether it's in Ireland, the EU or the US.

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post #71 of 133
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Originally Posted by Crowley View Post

I'm really not sure how I can providence any evidence better than them paying less than 1% corporation rate on the fortune in the Irish subsidiaries, and a similar effective tax rate throughout the whole of Europe.  It's clear avoidance.

So you have no evidence that Apple has done anything wrong. They pay the taxes that are required by law. Where is teh tax evasion that you keep claiming?
Quote:
Originally Posted by Crowley View Post

If you don't think that's unfair, well that's your call.  I do.  It deprives governments of revenue, creates unfair advantage over competitors, and rewards duplicitous practices.

The government sets the tax rates. Apple pays the required taxes. How is it unfair or how are they depriving the government of revenues? The only way your argument makes sense is if all the money belongs to the government in the first place and they simply allow Apple to keep some. That's not the way it works.
Quote:
Originally Posted by Crowley View Post

There is no suggestion of tax evasion.  No one has alleged that Apple has done anything illegal.  Besides which, I'm not even sure how I'd do that even if I did have the inclination; I'm not a US citizen.

So you're not a US citizen, you have no idea how the tax laws work, and you are fond of making things up (such as your claims on transfer pricing). So why should anyone believe a word you say?
Quote:
Originally Posted by Crowley View Post

Apple aren't selling the phones to Apple US at just under the retail price.  Not sure what you got that from, but it's not from me, I've never said that.

No? It must have been the other Crowley in post #41 of this thread:
http://forums.appleinsider.com/t/157633/apple-publishes-execs-opening-statements-from-us-senate-testimony/40
"Apple Operations International (Ireland) buys iPhones from Apple, or Foxconn in China at cost. Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price."
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post #72 of 133
Quote:
Originally Posted by Crowley View Post

 

I'm really not sure how I can providence any evidence better than them paying less than 1% corporation rate on the fortune in the Irish subsidiaries, and a similar effective tax rate throughout the whole of Europe.  It's clear avoidance.

 

 

 

 

It is avoidance. However do you think the Irish Government should get 12.5% of Apples ongoing worldwide profits - which may exceed 70% of all profits eventually? Cork isn't a shell company, and has some IP, and some devs - but Cupertino contributes 90%+ of IP. If you are concerned about the US, then the fact that Apple has low payments outside the US means more money can be repatriated. The formula is X-Y where X is the US corporation taxes and Y is taxes already paid worldwide. Who is losing out?

Quote:

 

 

If you don't think that's unfair, well that's your call.  I do.  It deprives governments of revenue, creates unfair advantage over competitors, and rewards duplicitous practices.

 

 

Which Government?

Personally I think that the money should go to where the IP is created but not at the same level as the (absurd) corporation tax which the US applies. 

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post #73 of 133
Quote:
Originally Posted by jragosta View Post


So you have no evidence that Apple has done anything wrong. They pay the taxes that are required by law. Where is teh tax evasion that you keep claiming?

 

I have never, once, ever, claimed Apple engages in tax evasion.  Tax evasion is illegal.  I have repeatedly stated that Apple is acting within the law.  Please read what I'm writing and stop inserting your own words to set up a straw man.

 

 

Quote:
Originally Posted by jragosta View Post

The government sets the tax rates. Apple pays the required taxes. How is it unfair or how are they depriving the government of revenues? The only way your argument makes sense is if all the money belongs to the government in the first place and they simply allow Apple to keep some. That's not the way it works.
 

I am not saying that Apple are acting unfairly.  I have said that they are smart and acting legally, and it is the regulatory situation that is flawed.  Please read what I'm writing and stop inserting your own words to set up a straw man.

 


Quote:
Originally Posted by jragosta View Post

So you're not a US citizen, you have no idea how the tax laws work, and you are fond of making things up (such as your claims on transfer pricing). So why should anyone believe a word you say?
 

The only part of that which is true is that I'm not a US citizen.  I am posting in a thread that is about Ireland and the EU, so I find it passingly relevant.   Please read what I'm writing and stop inserting your own words to set up a straw man.

 


Quote:
Originally Posted by jragosta View Post

No? It must have been the other Crowley in post #41 of this thread:
http://forums.appleinsider.com/t/157633/apple-publishes-execs-opening-statements-from-us-senate-testimony/40
"Apple Operations International (Ireland) buys iPhones from Apple, or Foxconn in China at cost. Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price."
 

See that list there.  See where Apple US is?  I can't, the only listed entities are European and Chinese (Taiwanese specifically).  Please read what I'm writing and stop inserting your own words to set up a straw man.

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post #74 of 133
Quote:
Originally Posted by asdasd View Post

Which Government?
Personally I think that the money should go to where the IP is created but not at the same level as the (absurd) corporation tax which the US applies. 

There's no country in the world that does that. In general, income is taxed where it is earned. That is not always the same as where the IP is created.
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post #75 of 133
Quote:
Originally Posted by MJ1970 View Post

 

Most of that could (and should) be done privately. Only defense (actual defense) and perhaps some pollution stuff arguably must be done through the government. IP protection is government granted monopoly and, arguably, isn't necessary either.

 

The argument is not "plain absurd."

I am curious as to how you see the world run 'privately'. Who would pay for infrastructure and how would the cost be distributed and on what basis. I suspect that taxation will quickly look like a simpler and more equitable way of providing essential services.

post #76 of 133
Quote:
Originally Posted by paxman View Post

Who would pay for infrastructure and how would the cost be distributed and on what basis.

 

Investors and customers of "infrastructure" companies.

 

 

Quote:
Originally Posted by paxman View Post

I suspect that taxation will quickly look like a simpler and more equitable way of providing essential services.

 

Possibly. However this is neither a clear nor a forgone conclusion to the point of claiming that suggesting it is "plainly absurd."

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post #77 of 133
Quote:
Originally Posted by Crowley View Post

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.

Crowly, Again; Seriously!

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post #78 of 133
Quote:
Originally Posted by massconn72 View Post

But we don't have good roads, good schools or decent public safety net systems in place, so what good are our taxes? There is nobody in this country that can say our monies are being put to not only good use or even proper use.

So how do the countries who do have good roads, good education, good transportation, do it?

post #79 of 133
Quote:
Originally Posted by jragosta View Post


Let's see if we can find a few things that your federal taxes pay for - that benefit companies:

The Federal government:
1. Pays a large part of the cost of educating our kids.
2. Pays a large part of the cost of roads, ports, airports, etc.
3. Pays to defend our country (which is an enormous portion of the total tax revenues). Without a Federal Government, you'd probably be speaking Russian. Or maybe Chinese.
4. Provides the backbone of a banking system which is the envy of the world
5. Provides for rules that regulate pollution, food production, and so on. WIthout the Federal government, you'd probably be sick from pollution and bad food.
6. Invests enormously in technology development. It would be nearly impossible to find any existing technologies that weren't funded, at least in part, by the Federal Government.
7. Patents and other laws which provide for IP protection - which allows companies to profit from their own innovation.

There are many more, but that's a start. Arguing that companies don't benefit from Federal expenditures is just plain absurd.

 

Quote:
Originally Posted by hmm View Post


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.

 

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.

 

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. 
 

 

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. 

 

 

And who pays for all of that? The government?

Where do they get their money? From taxpayers?

Who is the largest corporate taxpayer in the US? Apple?

 

So I guess Apple's billions in taxes paid for a nice chunk of all that. More than any of you guys paid to use the same things.


Edited by studiomusic - 5/22/13 at 9:37am
post #80 of 133
Quote:
Originally Posted by SolipsismX View Post


It's sad that this needs to get explained again and again. Watching Cook patiently explain to McCain over and over what should be obvious was more stressful than teaching my grandmother how to use any modern technology.

McCain actually seemed to learn a bit. Levin, however, remained as dense as a stone.

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