gatorguy

mongobongo said:

carnegie said:

I suppose the U.S. government could again try to get involved, filing a complaint of some sort, since that's where the money that Ireland will collect will ultimately effectively be coming from. 

How is the money effectively coming from the US government and not from Apple?

He probably wasn't as clear as he intended to be.

Be that as it may, the way Apple devised this, the money in that escrow account never belonged to Apple the US corporation. It was wholly under the control of Apple Sales International, a distinct corporation unto itself, not formed under the laws of the United States and beyond US control. Even if much of the profit from Apple's overseas operations may have been parked in US banks, it was still owned by a foreign company. That's why the scheme was so good.

So the escrow account isn't Apple US money anyway, at least as Apple planned it.

By the way, Google is generally credited with figuring out the tax avoidance scheme. Bad Google. Apple grabbed the basic idea, refined it, added their unique twist, worldwide profit shifting, and a friendly government, and, Voilà, it was nearly perfected before the EU Commission stepped in. 

strongy said:

cropr said:

The title is misleading:  Apple must not pay the amount to the EU, but to the Irish government.     The court has decided that the reduced tax rate  must be considered as illegal government aid to a private company.  This illegal aid must be reimbursed to Ireland.    

Ireland is on apple's side they said as much, i bet you the all the EU wanted was get its hand on all that money at least they don't get any of it.

A large part of Ireland's governing body was never on board with assisting in Apple's tax battle. Read some articles in the Irish Times today for how the government really feels now that the final word is in. 

If you hit a paywall, try this article:
https://www.rte.ie/news/business/2024/0910/1469297-apple-tax-decision-a-big-blow-to-ireland/

9secondkox2 said:

gatorguy said:

9secondkox2 said:

tht said:

9secondkox2 said:

Apple likely moved past the 5g minefield by developing a 6g modem and will license 5g patents for a limited time. 

In 2027, it will be time for a new standard, with 5g having lasted  a year or more longer than 4g as the top dog. 

Can’t wait. Tired of Qualcomm’s tech stifling innovation. 

Kuo is directly saying “5G” modems, and, isn’t 6G still 5 to 10 years out? Then, is there anything interesting with 6G at 500 MHz to 5 GHz frequencies?

For me, I’d like to see more power efficient wireless connections and ubiquitous coverage. Bandwidth isn’t a big feature anymore. So, if Apple can produce highly efficient 5G modems that supports networks everywhere, that’s good enough. 

That’s because he has no other info and apple WAS working on 5g before deciding the patents they bought weren’t doing them any favors. 

Working on developing an all new 5g modem at this point is foolish. That’s not a word to describe apple. Outside of rare misses like the AVP, They’re always looking ahead. “Skating to where the puck will be, not where it has been.” 

Qualcomm has the upper hand with 5g. Apple is moving past them. It’s nearly time for a superior standard anyway. The company that gave us the true personal computer, mainstream GUI, the mouse, airdrop, FireWire, thunderbolt, the smartphone as we know it today, numerous video standards, the first trackpad laptop, the first multitouch mouse with 360 scroll, was integral to the birth of WiFi, mini DisplayPort, Unicode, TrueType, openCL, HLS live streaming, upended the CPU and GPU industries with its own powerful yet efficient silicon, and much more - and is renown for eliminating old, archaic tech that holds the industries back, and makes the most reliable products in the industries it operates in. THIS company? Yeah, they’ll do fine front-running a new, superior communications chip as the standard for the following decade or so. 

No, 6g isn’t 10 years out. By 2027, 5g will have been the top standard longer than 4g was. If anything, 5g has been the top tier too long. The rate of technology improvement should increase, not decrease, and Apple is a company known for pushing the envelope - and sometimes just tearing the envelope up and making a better one. 

Last but not least, you seem to remember that “good enough” is not in Apples vocabulary. They’re more about “insanely great” achievements. 

I'm not sure Apple's intent is what you think it is. A modem yes, but not taking on a 6G standard of their own. 

https://www.lightreading.com/security/apple-google-start-working-on-6g
https://nextgalliance.org/

It’s exactly what o think it is. As part of ieee, Apple has always been about developing things for the hood of people, not just proprietary standards. Universal standards. Working with others to ensure its everything it needs to be is also an Apple hallmark. 

And yet, I don’t hear about any possible standards partner doing the heavy lifting of actually making 6G work. So while there is a brain trust, there is one spearhead actually bringing it to reality. It will take big telecoms like ATT to roll it out and install the tech in transmitters/receivers. Eventually Verizon and everyone else wil be on board too. 

In the end, not only will Apple be a dominant contributor to the standard, they will have the modem tech. It could be that the majority of 6g modems are provided by Apple beyond Apple devices. 

From the brief research I've done, China, and by extension Chinese companies such as Huawei and ZTE, seems to be the dominant contributor to 6G standards. That may be a problem.
https://www.iam-media.com/article/who-will-own-6g-and-the-future?
https://www.rcrwireless.com/20240715/6g/china-claims-world-first-field-test-network-6g-communications

MacPro said:

gatorguy said:

chasm said:

shrave10 said:

If there is a nickname for the tax loop hole called "Double Irish" then they probably did not name it just for Apple's sake.  Likely lots of other companies used the same loophole.  I suspect Apple and Ireland will win the appeal. 

Indeed, other companies did take advantage of the “Double Irish” loophole. As the article mentions, however, Apple didn’t have to follow the “rules” of the Double Irish loophole the same way the other companies had to.

THAT is what might (might!) get them in trouble.

It's not just the "Double Irish" tax scheme that other companies also took advantage of just as you note. It's that Apple demanded, negotiated, and may have been granted a very special version of it, unique tax treatment not made available to any other company. That's what would get them in trouble, and what you might also have been alluding to.

But outside the court, no one yet knows if this is the end of the story or a new beginning. Well, perhaps Apple already knows. 

Something never yet mentioned is that Apple has been allowed to take some money out of that escrow account to pay taxes in other jurisdictions. Not sure why, but it is. Perhaps there are taxes that courts ordered in other countries around the world, but the profits had already been funneled to their Irish subsidiaries? 

You phrase it like Apple did something wrong.  It's common for a large company to negotiate a special tax deal to locate in a particular place, even in the USA. These incentives can take various forms, such as:

Tax Breaks: Reduction or elimination of corporate taxes for a specified period.

Property Tax Abatements: Discounts or exemptions on property taxes to reduce operational costs.

Grants and Subsidies: Financial assistance or direct payments to support infrastructure, hiring, or expansion.

Job Creation Credits: Tax credits tied to the number of jobs the company promises to create.

Infrastructure Improvements: The local government may invest in roads, utilities, or other infrastructure upgrades to support the company’s needs.

Notable examples include Amazon's search for a second headquarters (HQ2), where cities across the USA offered huge incentives, or Tesla's gigafactories in various states where tax deals were central to the final location decision.

No, I feel I'm phrasing it as possible Apple did something wrong, as do some legal experts. But you're phrasing it as it's not possible Apple did anything wrong? 

beowulfschmidt said:

There was zero chance that the EU court was ever going to rule in Apple's favor and forgo that 14+ billion dollars.

One EU court already did side with Apple.