carnegie

nubus said:

AppleInsider said:

It is unclear exactly why Apple wants to sell bonds and raise cash, especially since its Q2 2025 results revealed it had $28 billion in "cash and cash equivalents," along with other assets. 

Apple must borrow in the US as profits are cash is kept offshore to avoid contributing to the US. It has caused a significant financial leverage and it makes borrowing more expensive for Apple. The alternative would be to pay taxes in the US.

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. 

As a non-US citizen, how do Executive Orders work?  Are they not binding?  For example, the issue of birthright citizenship is a hot button topic which from my understanding is protected by the 14th Amendment.  Can an executive order just overturn that even though it's in the Constitution?

Nope. Many of Trump's executive orders were actually illegal. An executive order is kind of like a promissory note that conveys the intentions of the administration. They are binding for federal employees and offices, but can't go beyond that and can't violate the constitution. The orders can later be considered by Congress and the Supreme Court if they need further legislation to make them more official, or if they need to be blocked.

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.

You need to do some more research and look into what 'US jurisdiction' means. Might want to look up supreme court precedent while you're at it. You are welcome.

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.

I don't think Wes is the one that needs to look up US jurisdiction. 

I would encourage you to look deeper into that issue. If someone sneaks into your house, does that mean you're obligated to make them part of your family and give them your resources? The 14th amendment was created to grant citizenship to former slaves during the Reconstruction. 

The text of the 14th Amendment is quite unambiguous,

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.

Trump's Eos can't get around the 14th Amendment. HOWEVER Trump and his cronies can work to get SCOTUS to repeal Amendments (and add new ones). Trump and his cronies can also do what they've already done, which is bully people who fear for their life, livelihood, and/or stock value into making decisions that are not good for the nation, as well and look the other way when states do something that's Federally illegal in a Red state (or when a Blue state needs assistance). Right now he's trying to get a bishop to apologize for asking everyone to be accepting of minorities... ya know, Jesusy shit.

SCOTUS can't repeal amendments or otherwise amend The Constitution because, you know, the process for that is laid out in The Constitution and doesn't involve SCOTUS. But, if the corrupt ring wing of SCOTUS wants to rule that an executive order that effectively amends the The Constitution is lawful, go right ahead, because target number 1 for the next Democratic president will be to issue an executive order that effectively repeals the 2nd Amendment and they'll have cleared the way.

Translation: End birthright citizenship via this avenue and we're coming for your guns, all of them.

You are correct. I did misspeak on how Amendment are added and removed. Thank you for the correction.

Right now the super majority is 2/3rd of Congress. What is needed to change the percentage of votes needed?

On 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.

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?

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.