Overseas cash restricts Apple's options for reallocating capital

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  • Reply 61 of 99
    robbyx wrote: »
    Because the US government is a big greedy inefficient beast with an insatiable appetite. They *deserve* a cut of everything!
    actually US corporate taxes are the lowest among large developed countries
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  • Reply 62 of 99
    ksecksec Posts: 1,569member
    Again, Apple needs to think about how to use those money to its advantage and invest in things that is safe and grows, no matter it is bonds or what sort. I dont want it to return the cash to me. Apple should very much think for itself.

    The US Currency is pretty low ( comparatively ), using the $100B Foreign Cash to Buy a 10 Year US Treasury Bonds would yield a yearly additional of $2B Cash. ( Correct me if i am wrong here ). Which Could have used to lower the production cost of its Mac Product, iCloud improvement or what other things that brings "value" to its Apple Product Users.

    Or what others solution. I think dividends, brings back cash are just for short term investors.

    And that is the thing that if Steve Jobs is still here it wouldn't have happen, he would properly RDF any stupid so called analysts and Hedge Funds manager into heaven.
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  • Reply 63 of 99
    melgross wrote: »

    Ah, let's guess; the corporation? It's certainly not the executives.

    Wrong answer.
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  • Reply 64 of 99
    melgross wrote: »
    All online purchases should be taxed? What about offline then?

    Obviously, you are a leftie (nothing wrong with that at all) and are concerned perhaps more with issues of equity as opposed to efficiency, but do you realize that it is the most regressive form of taxation?! I.e., the poor pay more as a share of their income than the rich?

    I agree, the rich should be paying much more. It isn't fair to burden the poor with taxes that hit them much more than do the same taxes on the rich. What needs to be u derstood is that wealth is more of a trickle up than trickle down economic situation. The rich always make their money off the poor, but the poor never make money off the rich. Glad you finally understand that!

    'Finally understand' what? What do you think I did not understand before, and when/where did I express that lack of understanding? Moreover, are you implying I am anti-poor and pro-rich or pro-poor and anti-rich? Or pro both? Anti both?

    Simply put, what the heck are you talking about!? Are you sure you're responding to the right person?

    I was just making a simple point about the regressivity of the sales tax, man, that's all.
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  • Reply 65 of 99
    hmm wrote: »
    Sales tax is regressive in itself, however it's a poor justification for the split between BM and online retailers.

    I agree with that. But I happen to think that both are regressive, and that's all I was pointing out.

    I also think that there's absolutely nothing wrong with someone being a leftie or a rightie or in the center (where I happen to think I am). I only brought that up in the context of the traditional arguments about equity versus efficiency, and the views of the left versus the right on that argument -- i.e., someone concerned with issues of equity should be railing against all forms of regressive taxation, rather than attempt to justify it on the basis of 'two wrongs make a right.'
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  • Reply 66 of 99

    Quote:

    Originally Posted by Frood View Post


     


     


     


    Even more so than R&D and marketing- Apple doesn't make a whole lot of money in France.  They also make next to nothing in 'profits' in the US.


     


    Apple's Irish subsidiary has China build iPhones for them for $250.  Apple Ireland sells these to their Dutch subsidiary with 'IP rights' for $650.  The Dutch subsidiary sells it back to the Irish subsidiary for $650.  The Irish subsidiary deposits the profit in a Bank in the Bahamas.  Apple's Irish subsidiary then sells the phone to the US Apple for $650.  Apple US then sells it in their stores to US customers for $650.  Since they paid $650 for it they made $0 in profit in the US.


     


    Reality:


    The transactions are all on paper.  Apple HQ in the US drives design and orders.  The phones ship straight from China to the US.  The phones are sold in the US by hard working people who generated the wealth to buy the phones in the US.  As soon as they buy the phone, the wealth they spent to purchase it is gone from the US economy, no taxes paid.  Blech.


     


    So the problem the e16 posted isn't right.  The problem isn't that Apple isn't paying taxes on phones they sell in France.  The problem is they aren't paying taxes on the phones that are sold in the US- which by and far are the majority of their profits.


     


    Apple paid a total rate of 2.3% in taxes.  Apple isn't evil, they are simply maximizing profits.  As stated most every large multinational does it.  Many pay $0 and billions in profits.  The 'perfect loophole' of allowing the money back into the US is a tempting carrot, but disastrous in practice since now every corporation has a 0% effective tax rate by simply offshoring all profits then repatriating them for free.


     


    The problem isn't Apple.  Its our laws and how ineffective they are.  'Lowering the corporate tax rate' is a common buzz phrase, but it is really just an excuse to lower the taxes on wealthy individuals.  No actual corporation pays anything close to the corporate tax rate.  A better fix would be no corporate tax rate (or possibly even personal tax rate)- just have a higher sales tax rate.  Items would be taxed at the point of purchase.  Savers would be rewarded.  Consumers would pay according to how much they consume.  Anything sold by wealth created in the US would result in revenues in the US instead of shipping the money offshore.


    Economists can come up with a much better plan I'm sure :p



     


    Your claim about how very few corporations, if not none, pay much less than the marginal tax rate of 35%. But in using this fact to refute a belief that the United States has the largest corporate tax rate in the world and it should be lowered to make our economy more competitive fails to account for a key fact-HOW corporations end up paying that low tax rate. The MARGINAL tax rate represents the tax rate incurred if a company did absolutely nothing at all to lower its taxes. Corporations have a fiduciary responsibility to shareholders, though, and reducing taxes is a part of that. In order to come up with ways of minimizing taxes, corporations employ and army of accountants and lawyers to comb through the tax code and devise a tax strategy that minimizes the tax bill. 


     


    If the MARGINAL tax rate were lower, corporations wouldn't have to spend money paying accountants and lawyers to reduce their taxes. That money could be used elsewhere. In other countries, the marginal tax rate is lower, meaning that for no effort at all, companies in those countries pay less tax. This is what is meant my economic competitiveness. Taxes increase the cost of doing business relative to other countries. And people like to vilify corporations' tactics such as Apple's by saying that smaller businesses, i.e. the "little guys", are getting the shaft because since they're smaller, they can't take advantage of the loopholes like multinationals, partly because they don't have cash to spend on accountants. Well, if the marginal tax rate were lower, it would level the playing field, because all of a sudden, those lower taxes rates that could only be achieved through some complicated financial acrobatics can now be had with much less effort. 


     

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  • Reply 67 of 99
    robmrobm Posts: 1,068member


    Guys, help an out of towner here.


    What level of tax does an Internet business based in the US attract ?


     


    Sorry for dumb question. Interested.

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  • Reply 68 of 99
    hmmhmm Posts: 3,405member

    Quote:

    Originally Posted by anantksundaram View Post





    Wrong answer.


    This can be argued for every point. Corporations are pieces of paper. You're over simplifying it though, and you don't account for predominantly foreign owned entities. In fact I'm curious how much of Apple is under the ownership of US citizens.


     


    Quote:

    Originally Posted by anantksundaram View Post





    I agree with that. But I happen to think that both are regressive, and that's all I was pointing out.



    I also think that there's absolutely nothing wrong with someone being a leftie or a rightie or in the center (where I happen to think I am). I only brought that up in the context of the traditional arguments about equity versus efficiency, and the views of the left versus the right on that argument -- i.e., someone concerned with issues of equity should be railing against all forms of regressive taxation, rather than attempt to justify it on the basis of 'two wrongs make a right.'




    It frustrates me for the reasons I mentioned. I've known plenty of people who vote Republican. It's just easier to discuss specific topics than wrap an ideology around everything. I've never felt reducing everything to a single dimension was a good way to explore it, and that is what basically happens with the right/left thing. It becomes all about ideology rather than the issues that are supposedly represented.

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  • Reply 69 of 99

    Back on topic...


     


    This AppleInsider article totally missed the mark. But I'll let it slide bc when I read a New York Times blog/article, that missed the mark even more . The WSJ did the best, but put in to fluff. 


     


    The whole lawsuit is about the issue of preferred stock being tied to other issues that are being voted on at an upcoming shareholders meeting.


     


    I can't find the wsj article now but basically the there was issue A and issue B. Apple figured the 99% of the people who voted for issue A would also vote for issue B and vice versa. Also 99% of the people voting against issue A would vote against issue B. 


     


    So Apple decided to tie those issues together  and there is one vote, Yes or No, to make the voting forms easier with one check box. 


     


    Then Apple amended that article to include a 3rd issue to be voted on. Maybe bc it was convenient or they wanted it to pass bc the the people who vote yes on issue A and B would also vote for issue C - restricting the Board of Directors from issuing preferred stock without the majority shareholders approval. 


     


    Einhorn's lawsuit is about the inclusion of issue C with the other two issues. He thinks that the vast major that support issues A and B also support issue C or don't care. Issue C is less related to A or B than they are to each other so he is suing to separate issue C, saying it should be voted on by itself. Which on principle I agree with.


     


    WSJ


    "Apple proposed the preferred stock amendment after a broader review of its corporate governance practices and independent of Mr. Einhorn’s proposal, people close to the company said.


     


    If it were to succeed with the proposal, Apple would become an outlier. According to FactSet SharkWatch, 95% of all companies in the S&P 500 have the “blank check” provision for issuing preferred stock without a shareholder vote that Apple is attempting to toss out."


     


    Long story short, Apple wants to become more democratic in regards to its stockholders, restricting actions of its Board of Directors. If the issue passes, unless a majority of shareholders agree, the Board can't do the things that people like Einhorn want without approval by the majority. Why should someone who owns less than 1% of get more influence than the collective 80% ( chose random number )?


     


    This is all about super rich people like Einhorn having more influence and input to get Apples' Board to get what they want and benefit from.....


     


    Apple is trying to support the little guys here, from people with social and political influence like Einhorn. Yet the WSG and NYT never cover that aspect of the story.

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  • Reply 70 of 99
    robmrobm Posts: 1,068member


    I think you posted this in the wrong thread - but your summation is bang on the nail. Nice.


    Maybe a mod can move it to the Einhorn post.

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  • Reply 71 of 99
    philboogiephilboogie Posts: 7,675member
    melgross wrote: »
    philboogie wrote: »
    R&D, Marketing come to mind.

    I don't understand your statement. Those are expenses, subject to tax refunds.

    Yes, and therefore they get taxed on those costs. Employee, material, outsourcing etc. So even though a French guy buying an iPod build by a Chinese person earns the US government some money.
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  • Reply 72 of 99
    My insight.

    The tax on profits coming back into America is part of Washington's imperialistic ways.

    The American owned money overseas spreads the tentacles of American imperialistic ventures far and wide.

    Washington has no desire to bring this money back as it would disrupt this American subversive influences on other nations.

    It is part of the new world order plan.

    Mick
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  • Reply 73 of 99
    jragostajragosta Posts: 10,473member
    philboogie wrote: »
    Yes, and therefore they get taxed on those costs. Employee, material, outsourcing etc. So even though a French guy buying an iPod build by a Chinese person earns the US government some money.

    Companies are not taxed on costs (other than property tax on real estate, of course). They're taxed on profits.

    There IS one unfair element in terms of that topic. Apple pays US tax on US income, China tax on China income, and France tax on France income, etc. Let's say that Apple France buys a phone from Apple China. They pay Apple China a certain amount of money for the phone. They pay Apple US a certain amount of money for their share of marketing, R&D, support, licenses, etc. They then sell the phone in France. Whatever is left over is clearly profit for Apple France and the US government is not entitled to any portion of that.

    HOWEVER, the problem is transfer pricing. How much should they pay Apple China for the phone? How much should they pay Apple US for the IP? By setting those prices, Apple controls which country earns most of the profits - and therefore where most of the taxes will be paid. If the US taxes are very high, for example, they set the IP licensing cost low enough that the US subsidiary doesn't make money and France makes more money - where the taxes are lower.

    There are rules that limit transfer pricing so that it's not TOO blatant of a tax avoidance scheme, but the window for allowable prices is very wide and there's a lot of leeway in moving income around simply by changing transfer prices.

    I don't know that there's an easy way around that other than a global taxing agreement which would have more downside the upside.
    robm wrote: »
    Guys, help an out of towner here.
    What level of tax does an Internet business based in the US attract ?

    Sorry for dumb question. Interested.

    Too many variables to answer.

    In the US, there are many types of taxes:
    Federal corporate income tax. Generally based solely on profits - the more profit you make, the more you pay in taxes. This could go as high as 35% of marginal income, but more typically is in the 10-15% range at most.

    Fees:
    You pay fees for specific services. While not taxes, they are payments to the government. For example, you pay fees to register a patent.

    State income tax. Some (but not all) states have income taxes for corporate income. Typically up to about 15%, but most commonly 5-10%

    Property tax. States and localities charge property tax based on the value of the property used.

    Local income tax. Like state and federal income tax, but implemented by specific cities. Not particularly common except a few of the largest cities. Typically a couple percent.

    Employment taxes. Employers pay a portion of the social security and medicare taxes for employees. Something like 8% of employee's gross income.

    Overall, the total corporate tax burden could range from 0% to perhaps 50%. However, almost no one pays anywhere near the maximum. Few companies pay more than about 25-35% for all these taxes combined.

    It's a complicated mess.
    vvswarup wrote: »
    <p style="margin-top:0px;margin-right:0px;margin-bottom:0px;margin-left:0px;padding-top:0px;padding-right:0px;padding-bottom:0px;padding-left:0px;">Your claim about how very few corporations, if not none, pay much less than the marginal tax rate of 35%. But in using this fact to refute a belief that the United States has the largest corporate tax rate in the world and it should be lowered to make our economy more competitive fails to account for a key fact-HOW corporations end up paying that low tax rate. The MARGINAL tax rate represents the tax rate incurred if a company did absolutely nothing at all to lower its taxes. Corporations have a fiduciary responsibility to shareholders, though, and reducing taxes is a part of that. In order to come up with ways of minimizing taxes, corporations employ and army of accountants and lawyers to comb through the tax code and devise a tax strategy that minimizes the tax bill. </p>

    <p style="margin-top:0px;margin-right:0px;margin-bottom:0px;margin-left:0px;padding-top:0px;padding-right:0px;padding-bottom:0px;padding-left:0px;"> </p>

    <p style="margin-top:0px;margin-right:0px;margin-bottom:0px;margin-left:0px;padding-top:0px;padding-right:0px;padding-bottom:0px;padding-left:0px;">If the MARGINAL tax rate were lower, corporations wouldn't have to spend money paying accountants and lawyers to reduce their taxes. That money could be used elsewhere. In other countries, the marginal tax rate is lower, meaning that for no effort at all, companies in those countries pay less tax. This is what is meant my economic competitiveness. Taxes increase the cost of doing business relative to other countries. And people like to vilify corporations' tactics such as Apple's by saying that smaller businesses, i.e. the "little guys", are getting the shaft because since they're smaller, they can't take advantage of the loopholes like multinationals, partly because they don't have cash to spend on accountants. Well, if the marginal tax rate were lower, it would level the playing field, because all of a sudden, those lower taxes rates that could only be achieved through some complicated financial acrobatics can now be had with much less effort. </p>

    <p style="margin-top:0px;margin-right:0px;margin-bottom:0px;margin-left:0px;padding-top:0px;padding-right:0px;padding-bottom:0px;padding-left:0px;"> </p>

    The 35% number is a red herring. Almost no business (certainly few, if any, of the largest businesses) pay anywhere near that amount. It's not uncommon for large, profitable businesses to pay no income tax at all.

    ksec wrote: »
    Again, Apple needs to think about how to use those money to its advantage and invest in things that is safe and grows, no matter it is bonds or what sort. I dont want it to return the cash to me. Apple should very much think for itself.

    The US Currency is pretty low ( comparatively ), using the $100B Foreign Cash to Buy a 10 Year US Treasury Bonds would yield a yearly additional of $2B Cash. ( Correct me if i am wrong here ). Which Could have used to lower the production cost of its Mac Product, iCloud improvement or what other things that brings "value" to its Apple Product Users.

    Or what others solution. I think dividends, brings back cash are just for short term investors.

    Apple is already investing everywhere that it thinks it can improve products or create value. Getting 2% return isn't going to change that.

    Note also that they can get similar returns by leaving the money overseas.

    The only way that money will be repatriated is if Apple has a major investment in the US that requires it or decides to increase the dividends. Otherwise, bringing the money back to the US makes no sense at all for the reasons given earlier.
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  • Reply 74 of 99
    hmm wrote: »
    This can be argued for every point. Corporations are pieces of paper. You're over simplifying it though, and you don't account for predominantly foreign owned entities. In fact I'm curious how much of Apple is under the ownership of US citizens.

    I was suggesting that most -- if not all -- taxes are paid by you and me. Ultimately, it is all passed though to consumers (through the prices they pay for goods and services) and shareholders (who would otherwise have a claim to the pre-tax rather than after-tax income). Period. I am not taking a stand on whether corporations should be taxed or not, but just saying that it is not some entity that is ultimately independent of us.

    Regarding foreign share ownership, unfortunately, US companies don't have to report that data. (Many European companies do.)
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  • Reply 75 of 99
    melgrossmelgross Posts: 33,717member
    Wrong answer.

    Why do you always give useless answers, as if you actually know why you're talking about, and it is this big secret? If you're so sure of yourself, just come out and explain it. If not, keep quiet.
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  • Reply 76 of 99
    melgrossmelgross Posts: 33,717member
    'Finally understand' what? What do you think I did not understand before, and when/where did I express that lack of understanding? Moreover, are you implying I am anti-poor and pro-rich or pro-poor and anti-rich? Or pro both? Anti both?

    Simply put, what the heck are you talking about!? Are you sure you're responding to the right person?

    I was just making a simple point about the regressivity of the sales tax, man, that's all.

    I took your entire statement into account, beginning with the first sentence, and with the experience of reading, and responding to your many posts over the years.
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  • Reply 77 of 99
    melgrossmelgross Posts: 33,717member
    philboogie wrote: »
    Yes, and therefore they get taxed on those costs. Employee, material, outsourcing etc. So even though a French guy buying an iPod build by a Chinese person earns the US government some money.

    What? You say yes, and then state the opposite. Could you be clearer?

    Apple is a US based corporation. Every product is R&D'd here. It's tested here. Most of, or all of the software is written hers. Most of their property is here. Most of their employees are here. Much of, but only about 40% of their profits are made here, and it's profits that are taxed. Is this a problem for you?
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  • Reply 78 of 99
    melgrossmelgross Posts: 33,717member
    My insight.

    The tax on profits coming back into America is part of Washington's imperialistic ways.

    The American owned money overseas spreads the tentacles of American imperialistic ventures far and wide.

    Washington has no desire to bring this money back as it would disrupt this American subversive influences on other nations.

    It is part of the new world order plan.

    Mick

    It's a silly post, but ok. Most other countries do the same thing.
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  • Reply 79 of 99
    melgross wrote: »
    Wrong answer.

    Why do you always give useless answers, as if you actually know why you're talking about, and it is this big secret? If you're so sure of yourself, just come out and explain it. If not, keep quiet.

    I did. Read.

    It would be equally good if you could follow our own advice.
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  • Reply 80 of 99
    melgross wrote: »
    'Finally understand' what? What do you think I did not understand before, and when/where did I express that lack of understanding? Moreover, are you implying I am anti-poor and pro-rich or pro-poor and anti-rich? Or pro both? Anti both?

    Simply put, what the heck are you talking about!? Are you sure you're responding to the right person?

    I was just making a simple point about the regressivity of the sales tax, man, that's all.

    I took your entire statement into account, beginning with the first sentence, and with the experience of reading, and responding to your many posts over the years.

    Should have seen that knee-jerk tendency for fact-less overgeneralization on your part coming from a mile away.....
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