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Related: Editorials & Other Articles, Issue Forums, Alliance Forums, Region ForumsUS taxpayers could end up covering Apple's back taxes in Ireland
https://www.yahoo.com/finance/news/us-taxpayers-could-end-covering-000000874.htmlBut Apple may get reimbursed for all of that by an unlikely benefactor: the US taxpayer. Its extremely possible the US taxpayer will have to pay this bill, says Stuart Gibson, a former government tax official whos now editor of Tax Notes International. For every dollar in tax Apple has to repay in Ireland, they may get to reduce their US tax bill by $1....
The commission acted, however, because Apple and a few other multinationals, such as Starbucks (SBUX), Amazon (AMZN), McDonalds (MCD) and Alphabet (GOOGL), have been extremely aggressive at tax arbitrage, which is basically the practice of assigning profits to lower-tax nations, even if the revenue being taxed wasnt earned there. Ireland has played the same game, lowering its corporate tax rate from 32% in the late 1990s to a mere 12.5% today, one of the lowest rates of any developed nation. That has made Ireland an offshore hub for many multinationals, especially tech firms, which can benefit from the way Ireland treats intellectual property. The comparable US rate is 35%.
The European Commission claims that Apples financial maneuverings allowed it to pay a tax rate of .005% on a large portion of foreign income, derived not just from Ireland but from much of the world, other than the United States. Apple CEO Tim Cook fired back in a blog post, saying we never asked for, nor did we receive, any special deals. The courts will now decide, and in the twisted logic of foreign tax schemes, American taxpayers have reason to hope Apples Irish loophole remains open.
MADem
(135,425 posts)and simplistic. It rarely gets hacked because no one of influence uses it!
I resent paying for that crap, really....with their "Apple Store" and "Apple Tunes" and proprietary garbage.
What kind of stupid company changes the chargers from year to year? I have three devices that all use the same generically shaped charger. That makes sense to me. APPLE doesn't.
Warpy
(111,137 posts)Fuck that shit. I'd rather see them go out of business than pay one dime for those workplace abusers/tax dodgers.
Apple is one of the worst for that.
KamaAina
(78,249 posts)They have a separate dodge for that, a subsidiary called Braeburn Capital (cool! another variety of apple, just like Macintosh! ), HQ'd just up the road in Reno, 'cause Nevada has no corporate income tax. Its staff of four (!) ensures that all profits are somehow routed through it. Meanwhile, we can still barely afford to pay for basic social safety net services.
63splitwindow
(2,657 posts)The statement, For every dollar in tax Apple has to repay in Ireland, they may get to reduce their US tax bill by $1 is interesting. If Apple had been paying that Irish tax over the past 10 years, would they have likewise received US tax credit all along the way?
Travis_0004
(5,417 posts)Yes.
Its really no different than working across state lines. I work in state A and live in state B (assume the 2 do not have a recprical agreement). I file a non resident return for the state I work in, and pay all the tax I owe.
Then I file a resident return in my home state. I calculate my tax liability, but take a dollar for dollar credit against any taxes paid to state A.
If state A charges me 500 more in tax, I'm going to pay 500 less in tax to state B.
There is a foreign tax credit for individuals as well, but people probably have more experience dealing with taxes across state lines than they do other countries.
moondust
(19,958 posts)U.S. taxpayers should always have to foot the bill for private sector tax evaders that get caught, especially for the ones who have already screwed U.S. taxpayers by moving overseas to avoid paying U.S. taxes.
Adrahil
(13,340 posts)That analysis is incomplete. They only get a tax reduction if the foreign tax is paid on income that would be otherwise taxed int he U.S. This income is parked overseas to avoid U.S. tax liability, so this won't happen.
Though, of course, any charge to Apple is eventually paid for by customers. I bet they pay FAR less than the "bill."
Initech
(100,034 posts)muriel_volestrangler
(101,265 posts)So, no, this won't affect the amount of tax they pay in the USA.
I didnt hear it. But if anybody said that, they dont know what theyre talking about. Let me explain what goes on with our international taxes. The money thats in Ireland that hes probably referring to is money that is subject to U.S. taxes. The tax law right now says we can keep that in Ireland or we can bring it back. And when we bring it back, we will pay 35 percent federal tax and then a weighted average across the states that were in, which is about 5 percent, so think of it as 40 percent. Weve said at 40 percent, were not going to bring it back until theres a fair rate. Theres no debate about it. Is that legal to do or not legal to do? It is legal to do. It is the current tax law. Its not a matter of being patriotic or not patriotic. It doesnt go that the more you pay, the more patriotic you are.
And so what weve said we think its fine for us to pay more, because right now were paying nothing on that and we leave it over there. But we like many, many other companies do wait for the money to come back.
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How long are you willing to keep unrepatriated income overseas?
Honestly, I believe the legislature and the administration will agree that its in the best interest of the country and the economy to have tax reform. So I dont think I have to make that decision. Im optimistic that it will take place next year.
https://www.washingtonpost.com/classic-apps/stepping-out-of-steve-jobss-shadow-tim-cook-champions-the-promise-of-apple/2016/08/12/fadb6c26-59cd-11e6-831d-0324760ca856_story.html?wpisrc=nl_draw2&wpmm=1
Of course, Cook goes on to lie that Apple didn't get a special deal. They did:
(The representative of Irish Revenue) pointed out that in the proposed scheme the level of fee charged would be critical. (The tax advisors employee representing Apple) stated that the company would be prepared to accept a profit of $30-40m assuming that Apple Computer Ltd. will make such a profit. (The computer industry is subject to cyclical variations). Assuming that Apple makes a profit of £100m it will be accepted that $30-40m (or whatever figure is negotiated) will be attributable to the manufacturing activity. However if the company suffered a downturn and had profits of less than $30-40m then all profits would be attribitable (sic) to the manufacturing activity. The proposal essentially is that all profits subject to a ceiling of $30-40m will be attributable to the manufacturing activity.
(The representative of Irish Revenue) asked (the tax advisors employee representing Apple) to state if was there any basis for the figure of $30-40m and he confessed that there was no scientific basis for the figure. However the figure was of such magnitude that he hoped it would be seen to be a bona-fide proposal.
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And whether it relates to the 1991 deal or the 2007 deal, which also put a cap on the companys taxable profits in Ireland, EU investigators havent seen an analysis explaining how those caps were reached, but they suspect that the justification isnt related to the actual economic value produced by the subsidiary.
http://qz.com/273631/how-apple-got-its-2-tax-rate-in-ireland/
Much of Apple's profits in Ireland were assigned to a 'head office' that literally does not exist, and so weren't taxed:
When it came to tax, each operated in much the same way. The rulings of 1991 and 2007 meant that almost all profit was allocated to a head office which had no employees or premises and existed only on paper.
Officials examined head office board minutes that suggested teleconference meetings went on for no more than 20 minutes and that nothing more than cash management and the allocation of dividends was discussed. The particular advantage of the structure was that the head office was considered stateless for tax purposes, with no tax to be paid anywhere on profits attributed to it.
Citing figures released by the US Senate, the commission said ASI recorded a 16bn profit in 2011. All but 50m of the profit was allocated to the head office, and Apple paid 10m tax in Dublin on that. The tax rate on the 16bn profit was in effect 0.05 per cent in 2011 and the rate in effect declined to 0.005 per cent in 2014 even as profits grew.
http://www.ft.com/cms/s/0/cc58c190-6ec3-11e6-a0c9-1365ce54b926.html?siteedition=uk