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As Apple holds $138B overseas, US Senate considers one-time tax break for repatriating cash - Page 2

post #41 of 102
Quote:
Originally Posted by anantksundaram View Post
 

Quit the political nonsense. It's largely the Democrats that are against the repatriation tax holiday.

 

were that true, the republican-controlled congress would have passed it into law, wouldnt they? didnt happen. 

 

theyre both the same, they both want green.

post #42 of 102
I believe they should set up a pretty simple formula that companies can look for long term.

First the 35% tax should be lowered by overseas income taxes. If the overseas rate is 20% then the US rate should be 15% for earnings in that overseas company. To make it simpler, allow companies to deduct overseas income taxes from the US taxes on those incomes - but not from the companies' tax on US generated income.

That will basically give companies a fast break - unless those companies pull all profits into a tax haven and pay no taxes on overseas income. Or US income shifted overseas.
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post #43 of 102
Quote:
Originally Posted by zoetmb View Post
 

If you're talking about personal taxes, you can have a simplified tax system but still have progressive rates.   Those who propose a flat tax or two rates, as you have, usually have in mind having poorer people pay much higher taxes.   That's inherently unfair as poorer people spend much more of their income (frequently 98% of their income) on the basic necessities of life:  shelter, food, clothing, medical and transportation to school or work.  

 

In ZoetWorld, you would have a one- or two-page tax form, eliminating all schedules.   You take your gross income from all sources (including dividends, capital gains, interest, pensions, etc.).   You eliminate all deductions except medical, education and pre-tax 401Ks.   Social Security income would only be taxed when it exceeds what you put in.   You still have five rates.    (In fact, with proper electronic reporting from the income sources as well as medical and education expenses, you wouldn't even need to file.   The IRS could collect this information, subtract how much you paid whether in payroll taxes or quarterlies, and either refund the overage or send you a bill.)  

 

Small business taxes should be simplified as well, but since it could never be as simple as personal taxes, personal taxes should be tackled first.  

 

But it will never happen.   Everyone is too hung up on the deductions that they take, even if their new tax bill would be the same or lower than it is today (and at the very least you'd save either accountant or software fees).   So homeowners would fight to keep the mortgage interest deduction.   Families would keep to fight dependent deductions.   Investors would fight to keep the lower rates on capital gains.   The accountants lobby would fight to kill any simplification at all as they have a vested interest in a very complex tax system.   Etc.  

 

I'll buy a ticket to ZoetWorld....much better system than what we have now. BTW, simplified/flat/two-tier tax systems usually have a 'rebate.' The taxes don't kick in until some agreed upon amount that basically exempts the poor from paying in. I'm not as knee-jerk sensitive to killing any idea because it will kill off the poor amongst us. There will always be programs and healthy debate about what to do about any system that increases hardship on those on the lower spectrum.

 

Because our ideas basically remove political favors from the tax code, I think simplification faces an uphill climb.

post #44 of 102
Quote:
Originally Posted by MacVicta View Post

Is this before or after the Republicans impeach President Obama over Benghazi and Berghdahl?

If the Republican party hadn't spent the last 6 years showing an unprecedented level of hostility toward our President, vehemently opposing him at every turn to appease their bloodthirsty base, bipartisan initiatives such as tax reform could've passed long ago. That the American people even consider handing these neanderthals more power in November is frightening.

You could technically say it the other way around.
post #45 of 102
Quote:
Originally Posted by SpamSandwich View Post

Good on Rand Paul for spearheading this, which is not mentioned in this story.

This should be permanent and the tax rate should be 5%.

 

I'm all for it as long as citizens get the same tax rate.

post #46 of 102
Quote:
Originally Posted by SpamSandwich View Post
 
Politicians should be quarantined and prevented from further harming the country.

Politics has been an essential part of the human experience since the beginning of civilization. Society needs governance in order to function. It would certainly work much better if everyone supported the process of governance instead of trying to impede it. 

 

I like Buffet's idea:

BUFFETT: I can end the deficit in five minutes.You just pass a law that says that anytime there’s a deficit of more than 3% of GDP, all sitting members of Congress are ineligible for re-election. Now you’ve got the incentives in the right place.

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post #47 of 102
Quote:
Originally Posted by Farshad Foroudi View Post

Basically Apple is telling the government that we have cheated you out of taxes and now want amnesty.Letting Apple bring home this 138B will not create a single job that they where not already planning on creating. Its great for Apple but whats in it for America?


Your cluelessness means I will stop at this point in wasting any effort to reply your post.  Get schooled.

post #48 of 102
What about taxing each corporation as you would an investment at the capital gains rate, but swap the terms?

Repatriate in under a year and you get the (lower) long term rate...over a year and you get the (higher) short term rate.

The rate could vary based on the corporations tax bracket, but minimum should be 5 or 10% so nobody is able to take advantage of the 0% tax in the 10-15% bracket...
http://www.moneychimp.com/features/capgain.htm
post #49 of 102
Quote:
Originally Posted by NolaMacGuy View Post
 

 

were that true, the republican-controlled congress would have passed it into law, wouldnt they? didnt happen. 

 

theyre both the same, they both want green.

You obviously don't know how the American government works. The Republicans do not control congress, they have a majority in the House of Representatives. However they do not have a majority in the Senate. Thus they can not simply "pass it into law". Furthermore even if they did have a majority in both houses of Congress they still can not simply pass a bill into law. The bill would need to be signed by the executive before it becomes law.

 

Reading these posts makes my head hurt, and there are simply too many for me to multi-quote and respond to each one, So I won't. I will however give my viewpoint on our tax system and ideas on reform. As others have mentioned, companies such as Apple have already paid the taxes on the income in the country the income was earned. Any tax on moving those incomes into the US is a deterrent to companies to do so. One of the only things I could see that would spur a company to pay an additional tax on moving those incomes into the US would be if the tax liability would be lower than the interest liability of issuing debt for capital investments.

 

Others have also mentioned a flat tax, two tier tax, etc. While some of these do have merits they also have several challenges that would need to be addressed as well. People have also mentioned a VAT, and continued on with how complex they are. However I believe a pure flat VAT on either side of the equation, and eliminating any other tax would result in the easiest method of taxation. For example applying this on the income side would result in the following:

 

When apple buys the flash memory for the latest iPhone, they pay Samsung $100 for the component and as Apple has not yet added any value they would not pay any tax in the US. They would still end up paying whatever tax they owe in South Korea for that part. However they then buy the sapphire cover from GT Advanced for $100. Apple has still not added any value to that component and as such would not pay any tax on it. In this case though, GT Advanced would pay the tax on the value that was added by their production of the component. The materials and capital used to make the component cost GT Advanced $25 so they added $75 of value by producing the component. Using a flat 10% for simplicity, GT Advanced would then pay $7.50 in VAT on that component. We will move this along by saying the iPhone is made up of only those two components. So Apple has now spent $200 on producing the iPhone. Now they sell that iPhone directly to you for $650. Thus Apple has now added $450 of value by producing the iPhone that you bought. Just as Apple did not pay a tax on the sapphire component, you would not pay a tax on buying the iPhone. Apple however would then pay $45.00 in VAT. Your income, in this example would be just like the sapphire component, and you would pay the tax on the value you produced by working. You would be in this sense a raw resource.

 

The other side of this would be a VAT on expenses. Which is in the end the same thing, it is simply changing who is paying the tax. Using the previous example, when Apple bought the sapphire component from GT Advanced, Apple would pay the $7.50. When you bought the iPhone, You would pay the $45.00 in VAT, however when Apple pays you for your labor, Apple would pay the 10% on the expense rather than you paying it on your income (which is the same number). On the income side you are paying the tax on the value you create, on the expense side you are paying the tax on the value the entity you're buying something from created.

 

-PopinFRESH 

post #50 of 102
Quote:
Originally Posted by sog35 View Post
 
Quote:
Originally Posted by jungmark View Post


No way. Corps should not pay less than the middle class tax payer. 10-15% is more appropriate.

 

That makes no sense.

 

Corps profits are transferred to shareholders.  Those shareholder then pay taxes on dividends and capital gains.  Basically the Corporations tax burden is paid by shareholders.  So why the hell does the Corp need to pay ADDITIONAL TAXES?

That's the most convoluted, twisted-up, BS I've ever heard. Ridiculous.

You could ultimately twist that line of "logic" into "there should be no income tax at all".

post #51 of 102
I want a 5% tax rate also.
post #52 of 102
Quote:
Originally Posted by LarryA View Post


Fantasy. There's just no evidence to support that, but there have been plenty of instances where Republicans in congress opposed the legislation that they themselves sponsored because Obama was for it

Wow, your facts are amazing. Also your source, LarryA, is the most vetted and reputable source I've ever seen. /s

post #53 of 102
Quote:
Originally Posted by Farshad Foroudi View Post

Basically Apple is telling the government that we have cheated you out of taxes and now want amnesty.Letting Apple bring home this 138B will not create a single job that they where not already planning on creating. Its great for Apple but whats in it for America?

 

Shouldn't the question be what's right, and not how can we leech off a successful company?  This attitude is disturbing.

 

To paraphrase George F. Will, corporations do not pay taxes.  They collect taxes.  They pass them on to consumers as a cost of doing business.

 

I mean think about it - in a business every expense, including taxes, is what it costs the company to conduct its operations.  Their only source of revenue is from their customers.  It doesn't take a degree in math, economics, or anything else to see that, as Will said, the correct corporate tax rate is 0%.  Maybe if America would do this then businesses themselves would be an import rather than an export for the country.

 

Also, if you're running a business and you have various options for how to structure and locate yourself and you choose anything other than the option that results in the lowest tax burden you are not cheating the government (unless you are breaking the law), you are cheating your stakeholders (and running your business from a mindset that will likely produce a crop of other decisions that will soon put you out of business).

 

Can you provide a reference to a specific part of the tax code which Apple violates?

post #54 of 102
Keep in mind, this percentage is on top of the taxes that were already paid in the jurisdiction in which the profit was earned.

Apple still pays the 35% rate on all income generated within the U.S. and whatever local taxes are required in other countries.

A 0% or other low rate is appropriate for money which has already been taxed elsewhere. Why should the U.S. collect any taxes on a sale of a product made in Europe?

We don't tax European companies that make sales in Europe, so it's a "technicality" on where the corporate headquarters are physically located that determines if they owe U.S. taxes.
post #55 of 102
Quote:
Originally Posted by jlanganki View Post

Keep in mind, this percentage is on top of the taxes that were already paid in the jurisdiction in which the profit was earned.
 

Well that is a nice fantasy. See, there are many convoluted details to the accounting process. I'll only mention one for now. 

 

For example, Apple USA transfers patents to their European corporation in Ireland, then Apple's Italian based sales division licenses these patents at a huge expense. So when it comes time to pay Italy their tax, the sales division claims that they made no profit in Italy because the license fees were so high. In this case, the income never gets taxed at all. Perfectly legal but not at all ethical in my opinion.

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post #56 of 102
This could lead to a massive one-time dividend.
post #57 of 102
A TAX HOLIDAY WAS GIVEN IN 2004 TO AMERICAN CORPORATIONS, NOTHING CAME OF IT THEN AND NOTHING WILL THIS TIME AROUND EITHER JUST ONE MORE SHAM.
post #58 of 102
Quote:
Originally Posted by BobSchlob View Post
 

That's the most convoluted, twisted-up, BS I've ever heard. Ridiculous.

You could ultimately twist that line of "logic" into "there should be no income tax at all".

 

You do know Corporations pass on taxes to the customer?

post #59 of 102

"I'd do a simplified two-tier flat tax. I would be carving into regulations with the aim of getting govt. out of the way of capitalism. No complicated VAT or weird mumbo-jumbo that no one understands. No need for accountants. And, bonus, very difficult to politicize. The labyrinth tax code gives rise to political favors and endless tinkering as one party or another shoves benefits to their base of voters (such as this suggested tax holiday).

 

Get politicians out of it. Make it simple. Then, if it needs adjustment, it's a transparent process. Want to move it from 12 to 13%? Then we have that debate. There is no opaque tinkering with various deductions or special treatment.

 

Simplify. Lower the rates. Broaden the tax base. Get out of the way and watch the economy thrive. A 25 T economy will throw about 5 T into the govt. coffers. Let's aim for growth."

 

Your sentiment is widely shared by those who are paying the taxes.  The problem is taxation is the power of the government.  The best you can hope for from Congress is a recognition that if they clean up the mess, they can get paid all over for messing it up.  Congress is as self-centered an organization as exists in America.  Many of the individuals in Congress paid huge amounts of their own money to get elected, and or sold their soul to get the money to get elected.  We do not have any honest politicians.  The best we can hope for is enlightened self interest keeps them from killing the goose that lays all the golden eggs.

post #60 of 102
Quote:
Originally Posted by quanster View Post

Why kill the tax rate? Individuals are getting tax on their worldwide earning. It is bullshit that corporations get a tax holiday. When is the last time that individuals get a tax holiday? I am all for tax reform but it should happen to everybody - individuals and corporations alike. Simplify the tax code to a flat tax on all earnings.

 

I'm pro flat tax and tax reform in general, but your first point seems off.

 

I'm not an expert on the U.S. tax system, but in general individuals are subject to tax treaties among industrialized nations (so for example, Canadians can work outside the country and not get double taxed.) In contrast, Apple has already paid taxes on its foreign earnings.

 

Why should it be taxed again on the same money just because it is transferring it from one bank to another?

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post #61 of 102
Quote:
Originally Posted by Danox View Post

A TAX HOLIDAY WAS GIVEN IN 2004 TO AMERICAN CORPORATIONS, NOTHING CAME OF IT THEN AND NOTHING WILL THIS TIME AROUND EITHER JUST ONE MORE SHAM.

 

And THAT is why the rate must be permanently reduced.

Proud AAPL stock owner.

 

GOA

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Proud AAPL stock owner.

 

GOA

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post #62 of 102
Quote:
Originally Posted by LarryA View Post

Really?
For the deaf and blind, then:

Www.allgov.com/news/unusual-news/six-republicans-vote-against-deficit-bill-they-sponsored?news=840267

"senate Republicans Hit an All Time Low Blocking Bill They Unanimously Supported"
Www.politicususa.com/2014/05/17/senate-republicans-hit-time-blocking-bill-unanimously-supported.html

Now, where's the example of the reverse?

POLITICS!!

Btw, didn't John Kerry famously vote for and against the same bill.
post #63 of 102
Quote:
Originally Posted by PopinFRESH View Post

 

Others have also mentioned a flat tax, two tier tax, etc. While some of these do have merits they also have several challenges that would need to be addressed as well. People have also mentioned a VAT, and continued on with how complex they are. However I believe a pure flat VAT on either side of the equation, and eliminating any other tax would result in the easiest method of taxation. For example applying this on the income side would result in the following:

 

When apple buys the flash memory for the latest iPhone, they pay Samsung $100 for the component and as Apple has not yet added any value they would not pay any tax in the US. They would still end up paying whatever tax they owe in South Korea for that part. However they then buy the sapphire cover from GT Advanced for $100. Apple has still not added any value to that component and as such would not pay any tax on it. In this case though, GT Advanced would pay the tax on the value that was added by their production of the component. The materials and capital used to make the component cost GT Advanced $25 so they added $75 of value by producing the component. Using a flat 10% for simplicity, GT Advanced would then pay $7.50 in VAT on that component. We will move this along by saying the iPhone is made up of only those two components. So Apple has now spent $200 on producing the iPhone. Now they sell that iPhone directly to you for $650. Thus Apple has now added $450 of value by producing the iPhone that you bought. Just as Apple did not pay a tax on the sapphire component, you would not pay a tax on buying the iPhone. Apple however would then pay $45.00 in VAT. Your income, in this example would be just like the sapphire component, and you would pay the tax on the value you produced by working. You would be in this sense a raw resource.

 

The other side of this would be a VAT on expenses. Which is in the end the same thing, it is simply changing who is paying the tax. Using the previous example, when Apple bought the sapphire component from GT Advanced, Apple would pay the $7.50. When you bought the iPhone, You would pay the $45.00 in VAT, however when Apple pays you for your labor, Apple would pay the 10% on the expense rather than you paying it on your income (which is the same number). On the income side you are paying the tax on the value you create, on the expense side you are paying the tax on the value the entity you're buying something from created.

 

-PopinFRESH 

 

As long as there is no other Federal taxes, I like the VAT on Expenses! There is less paperwork/oversight/bureaucracy as you are paying on receipt rather than having to show/calculate increase in value. 

 

This will increase the tax burden on those working the system (GE), force those not paying income taxes (those working under the table) to pay into the system, and decrease the cost of doing business for all (no tax accountants, filings, tax attorneys, etc.). So the cost of goods will go down (in a competitive market). Thus the poor, having to pay %5 tax on bread, should be paying that tax on bread that cost less. This will not be realized right away, but as companies decrease their cost of business, they will lower prices (or increase quality) to gain marketshare. 

 

This will also incentivize people to save money, companies to grow their business, and to hire more labor. Let's not forget a huge benefit of decreasing the size of the Federal government and removing a large stick .  

post #64 of 102
Gee, I'm just a layman, but I don't know why Apple would transfer the money to the US even if there were zero taxes.
post #65 of 102
Quote:
Originally Posted by jungmark View Post

No way. Corps should not pay less than the middle class tax payer. 10-15% is more appropriate.
Apple is borrowing at between 2.5% and perhaps 5% to pay for dividends. They would have zero incentive to bring $ to the US for 10-15%. As it is, corps repatriate $ only if they need it to keep the company running or expanding. Apple makes enough in the US + inexpensive borrowing to do this. No need to bring in cash from non-US sales.
post #66 of 102
Quote:
Originally Posted by jungmark View Post

POLITICS!!

Btw, didn't John Kerry famously vote for and against the same bill.

Eh, probably! The show Veep reminds me of his campaign for President. Seemingly no foundation to belief system due to being a slave to public opinion.

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post #67 of 102
Originally Posted by Danox View Post
A TAX HOLIDAY WAS GIVEN IN 2004 TO AMERICAN CORPORATIONS, NOTHING CAME OF IT THEN AND NOTHING WILL THIS TIME AROUND EITHER JUST ONE MORE SHAM.

 

Define "nothing".

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post #68 of 102

One can hope that since Rand and Reid are behind this, Obama won't turn this proposal into a class warfare opportunity. I wish he would have used the bully pulpit to champion companies and the economy and people working hard to become well off. Once the liberal press gets ahold of this, we are going to hear nonstop how poor people pay all the taxes and the rich don't pay their fair share.

post #69 of 102
I believe Ireland has a Corporate Tax Rate of 12.5% (through 2025) which can be applied to offset any taxes due the US IRS in the case of repatriation. In the example of the US determining a 15% tax rate for corporations the already paid 12.5% to Ireland would be credited and the net tax to the US IRS would be 2.5% - so the revenue estimates cited may need to be tempered. The US has one of the highest Corporate Tax Rates in the world (approaching 40% with Federal and State) hence the tax advantaged strategies employed by US corporations. This level of taxation influences the US multi-nationals to export jobs outside of the US to increase after tax profits and share price as a multiple of earnings. Most countries have tax rates between 20-30% - lower the US rates and some of these companies will move operations back to the US since the offshore advantage will be diminished.
post #70 of 102
Quote:
Originally Posted by jungmark View Post

No way. Corps should not pay less than the middle class tax payer. 10-15% is more appropriate.

See my post above. Corps don't pay taxes - they collect them from you.

It's tempting to think of corporations as people, and for some people it's tempting to think of them as rich people who owe others something. When you understand that they're just vehicles for transacting business and that you paid a hidden 35% tax on that iPad you start not wanting to tax yourself as a consumer in such a non-transparent way.
Edited by jinglesthula - 6/11/14 at 6:12pm
post #71 of 102
Quote:
Originally Posted by Danox View Post

A TAX HOLIDAY WAS GIVEN IN 2004 TO AMERICAN CORPORATIONS, NOTHING CAME OF IT THEN AND NOTHING WILL THIS TIME AROUND EITHER JUST ONE MORE SHAM.
Quote:
Originally Posted by Tallest Skil View Post

Define "nothing".
http://www.nytimes.com/2009/06/05/business/05norris.html?_r=0
"...the most detailed analysis of what actually happened — using confidential government data as well as corporate reports — has estimated what happened to the $299 billion companies brought back from foreign subsidiaries. About 92 percent of it went to shareholders, mostly in the form of increased share buybacks and the rest through increased dividends.

There is no evidence that companies that took advantage of the tax break — which enabled them to bring home, or repatriate, overseas profits while paying a tax rate far below the normal rate — used the money as Congress expected.

“Repatriations did not lead to an increase in domestic investment, employment or R.& D., even for the firms that lobbied for the tax holiday stating these intentions..."
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post #72 of 102
Originally Posted by Gatorguy View Post
There is no evidence that companies that took advantage of the tax break — which enabled them to bring home, or repatriate, overseas profits while paying a tax rate far below the normal rate — used the money as Congress expected.

 

Thanks for that. It proves two things.

 

1. “Not being used as expected” neither means nor implies “not used”.

2. Congress doesn’t have the first clue about how business operates.

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Originally posted by Relic

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post #73 of 102
Rand Paul at it again? I am not American and dont follow America politics much either. But he is the only sane American politician that i know.

I also dont get why it should be a high rate of 10%? Sorry for being naive, but those money were foreign profits why should companies be taxed again when they move those money back?
And if it was just a way to make more tax, shouldn't 5% be fair and enough?
post #74 of 102
Quote:
Originally Posted by ksec View Post

Rand Paul at it again? I am not American and dont follow America politics much either. But he is the only sane American politician that i know.

I also dont get why it should be a high rate of 10%? Sorry for being naive, but those money were foreign profits why should companies be taxed again when they move those money back?
And if it was just a way to make more tax, shouldn't 5% be fair and enough?

Agree on all points.

Proud AAPL stock owner.

 

GOA

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post #75 of 102
Quote:
Originally Posted by ksec View Post

Rand Paul at it again? I am not American and dont follow America politics much either. But he is the only sane American politician that i know.

I also dont get why it should be a high rate of 10%? Sorry for being naive, but those money were foreign profits why should companies be taxed again when they move those money back?
And if it was just a way to make more tax, shouldn't 5% be fair and enough?


5% and 10% aren't actually the effective amounts. The big point there is that they do not account for foreign tax credits. The actual percentage itself is arbitrary anyway. It makes little sense to go by what sounds good. Anyway I hope they don't do this. It just takes attention away from the messed up tax laws for a few more years. If they're forced to address the inherent problems prior to any negotiation, something might actually be done. A couple of the links I like on the 2004 one show up behind pay-walls, but you could google for the WSJ assessment. Its stated purpose was unfulfilled, and we're still left with problematic policy, because the process was merely reset. The other part of it is that just monkeying with the numbers isn't enough, if whatever final rate is not actually enforceable and they are unable to control the effective rate. My other issue is that this doesn't affect companies in an equivalent fashion. It places an enormous divide between small to medium and large companies, as the former cannot afford the accounting staff and lawyers to support such a tax plan. In that sense it contributes to some of our other problems including the nonsense that set up the mortgage crisis (goes back pretty far, Glass-Stieglitz was repealed in the 90s).

 

Quote:
Originally Posted by SpamSandwich View Post
 

 

And THAT is why the rate must be permanently reduced.


I don't think that alone would fix it. Some of the really small countries that lack much in the way of infrastructure can always go lower in an attempt  to grow their financial markets.

post #76 of 102
Quote:
Originally Posted by Tallest Skil View Post
 

 

Thanks for that. It proves two things.

 

1. “Not being used as expected” neither means nor implies “not used”.

2. Congress doesn’t have the first clue about how business operates.

 

As any software programmer knows, the user will always find a way to use software in an unexpected way.  That doesn't imply a lack of knowledge on the part of the programmer, just the impossibility of thoroughly predicting people.

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post #77 of 102

  Quote:

Originally Posted by Tallest Skil View Post
 

 

Thanks for that. It proves two things.

 

1. “Not being used as expected” neither means nor implies “not used”.

2. Congress doesn’t have the first clue about how business operates.

I forgot to address this one. You might want to read a bit more on that. At the time these companies lobbied for the same things suggesting that it would free up funds for infrastructure investments. It's a matter of what they said they would do vs what actually happened. As for Congress, I do not believe their claims of ignorance on most things.

post #78 of 102

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post #79 of 102
It is an excellent question: why does the United States get to tax money coming from sales that happened in other countries? Is there a justification for this other than "just because we can". 
post #80 of 102
Quote:
Originally Posted by jungmark View Post


No way. Corps should not pay less than the middle class tax payer. 10-15% is more appropriate.

 

The average middle class tax payer pays about a 12% effective tax rate.  But if they are married, have kids and own a home with a mortgage, that rate drops to 5% pretty quick. (I'm only talking Federal income tax here.) 

 

Besides, if to add the 5% on top of the foreign tax that Apple already paid, they will end up paying around 10-15% on that money. The same as the middle class tax payer.

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