carnegie
About
- Username
- carnegie
- Joined
- Visits
- 213
- Last Active
- Roles
- member
- Points
- 3,613
- Badges
- 1
- Posts
- 1,085
Reactions
-
Apple Maps still calls it the Gulf of Mexico, and politicians are upset
Xed said:anonymouse said:Xed said:anonymouse said:SmittyW said:Mike Wuerthele said:SmittyW said:Wesley Hilliard said:canukstorm said:DAalseth said:I wonder if Trump knows it won’t change. He made all sorts of really stupid promises to his supporters. These Executive Orders let him say he followed through, but like his promise in 2016 to ‘bring back coal’ none of them stand a chance in hell of happening. He knows that but he’s just going through the motions. It’s also good misdirection so people talk about this, while he and his crew are doing real damage behind the scenes.For example, his orders about birthright citizenship aren't allowed, period. He can't actually provide amnesty to ByteDance from a law that was passed. And he can't withdraw from the WHO like that. He's being sued already and there are a lot of people on both sides of the isle that are unhappy with the many of the executive orders and what they do. Congress will likely overturn several. We'll see.
Also, that's a shame about the WHO, looks like Tedros is going to have to go back to embezzling funds from the Ethiopian government again. Poor guy.All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
It doesn't say anything about applying only to former slaves. There aren't any restrictions at all such as that their parents are citizens, or even in the country legally. It clearly and simply says, "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States." There's no wiggle room there. The idea that The Constitution can be amended by executive order is a pill too bitter for even the corrupt right wing of SCOTUS to swallow. But, you know, maybe they'll go along, and then the next President (or, who knows, maybe even this one) can simply repeal the 2nd Amendment by executive order.
Translation: End birthright citizenship via this avenue and we're coming for your guns, all of them.
Right now the super majority is 2/3rd of Congress. What is needed to change the percentage of votes needed?
But even when Congress proposes an amendment, that amendment needs to be ratified by 3/4 of the states in order to go into effect. -
Apple must pay EU $14 billion over Ireland tax arrangement
spheric said:radarthekat said: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.
Or am I missing something? -
Apple must pay EU $14 billion over Ireland tax arrangement
https://d18rn0p25nwr6d.cloudfront.net/CIK-0000320193/33ab9a1c-e116-4117-9323-2355cba0fa2f.pdfOn August 30, 2016, the European Commission (the “Commission”) announced its decision that Ireland granted state aid to Apple Inc. (the “Company”) by providing tax opinions in 1991 and 2007 concerning the tax allocation of profits of the Irish branches of two subsidiaries of the Company (the “State Aid Decision”). The State Aid Decision ordered Ireland to calculate and recover additional taxes from the Company for the period June 2003 through December 2014. Irish legislative changes, effective as of January 2015, eliminated the application of the tax opinions from that date forward. The Company and Ireland appealed the State Aid Decision to the General Court of the Court of Justice of the European Union (the “General Court”). On July 15, 2020, the General Court annulled the State Aid Decision. On September 25, 2020, the Commission appealed the General Court’s decision to the European Court of Justice (the “ECJ”) and a hearing was held on May 23, 2023.
On September 10, 2024, the ECJ announced that it had set aside the 2020 judgment of the General Court and confirmed the Commission’s 2016 State Aid Decision. As a result, the Company expects to record a one-time income tax charge in its fourth fiscal quarter ending September 28, 2024, of up to approximately $10 billion, which will increase the Company’s effective tax rate for the quarter. -
Apple must pay EU $14 billion over Ireland tax arrangement
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.
In order to avoid double taxation (and in the case of corporations, essentially triple taxation when earnings are further distributed to shareholders), U.S. tax law generally provides for credits against U.S. income tax liability for foreign taxes paid on given earnings.
Under the Tax Cuts and Jobs Act of 2017, the earnings on which this new Irish tax liability is largely based are deemed repatriated to the parent Apple and U.S. taxes are owed on those earnings. IIRC Apple had previously estimated a tax liability of $30-40 billion-ish based on the TCJA. Because Apple will now have to pay Ireland more taxes on those earnings, it should get a credit against that U.S. tax liability. Apple’s SEC filings reflect that expectation. In essence, the largest effect of this ruling should be that Apple will pay a portion of its taxes to Ireland rather than to the United States.
-
Apple must pay EU $14 billion over Ireland tax arrangement
As I read the decision, the Court of Justice decided sua sponte to issue a final judgment such that the case won't be returning to the General Court for further considerations. Neither the appellant (i.e. the European Commission) nor the intervener (i.e. the EFTA Surveillance Authority) asked for that. They both asked for the case to be referred back to the General Court so that it could consider Ireland and Apple's other grounds from the original appeal. So I think this is a bit of a surprise - not the decisions in favor of the Commission but the decision to issue a final judgment.
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. But in the current ideological environment I'd guess the likelihood of that is small.
EDIT: For some reason the system still won’t let me quote (and post) what I’m responding to.