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Old 2013-05-22, 10:10   Link #28521
willx
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Age: 31
^ I sometimes forget, living in the bubble that I do, that most people are generally unaware about how corporate taxation and repatriation works.
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Old 2013-05-22, 10:13   Link #28522
ArchmageXin
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Quote:
Originally Posted by willx View Post
^ I sometimes forget, living in the bubble that I do, that most people are generally unaware about how corporate taxation and repatriation works.
Care to enlighten us?

Or, be specific on if you are on pro or ant tax on this matter.
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Old 2013-05-22, 10:49   Link #28523
Ledgem
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Quote:
Originally Posted by willx View Post
^ I sometimes forget, living in the bubble that I do, that most people are generally unaware about how corporate taxation and repatriation works.
People may be unaware of how it actively works, but they have an expectation of how it should work. Those expectations are not unrealistic. I hear a lot of people in the financial sector speak of financial rules and operations as if they're some intrinsic property of the world, similar to gravity or the structure of DNA. It strikes me as little more than shifting responsibility, or engaging in immoral acts with a sense of justification behind it. These are human-made rules and regulations, and humans act around them.
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Old 2013-05-22, 10:51   Link #28524
SaintessHeart
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Quote:
Originally Posted by willx View Post
^ I sometimes forget, living in the bubble that I do, that most people are generally unaware about how corporate taxation and repatriation works.
You might want to highlight the misconceptions other have before they bring out the gullitone.

That is called insurance, right? /人◕ ‿‿ ◕人\
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Old 2013-05-22, 10:53   Link #28525
willx
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I am neither pro-or-anti, it's more again of people properly understanding how international corporate structures work. You're absolutely right on your interpretation but the news and how people understand it is basically skewed. That said, I make no claim there are no questionably legal shenanigans going on, but even without creative accounting the "average person" is woefully underinformed about the most basic corporate taxation matters. @ArchmageXin -- I believe you more than get it, I'm basically thinking about the broader population that is opinionated but sadly remains largely ignorant.

Here's an example with GE -- everyone remember the "GE pays zero taxes" news article that was floating around a couple of years back? Here's a "factcheck" on it: http://www.factcheck.org/2012/04/war...pays-no-taxes/

This is where people get confused on multiple levels:
Premise: GE is a U.S. company, if I look at their profit, cash, etc. Why does their tax rate look so low compared to the U.S. corporate tax rate?
Ergo: GE is scamming us! Damn corporate thieves!

Reality:
1) GE is an international business with both U.S. and international operating subsidiaries and holding companies
2) What the above means is that GE has "U.S.Co" "AsiaCo" "EuropeCo" and many many many more subdivisions. Each of these units generates profits at it's operating corp levels. The U.S. tax rate on profits may be ~20% (nominal 35%, avg. effective ~12%) but what about tax rates in Ireland? Rest of the world? http://en.wikipedia.org/wiki/List_of...s_by_tax_rates
3) Keep in mind taxation is only on profits. So what about government granted tax deductions? Depreciation of assets? Issuing debt to buy back stock and pay dividends (interest is paid out of pre-tax income, so it reduces profits)?
4) Go read ArchmageXin's post: http://forums.animesuki.com/showthre...25#post4690725

So, when people think about taxation of international businesses, they need to think about operations divided by jurisdiction and effective local tax rates. Tax treaties only factor in when funds are repatriated (as you mentioned previously) and as long as those funds are never sent back to U.S. "ParentCo" then that doesn't matter.
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Old 2013-05-22, 12:12   Link #28526
AnimeFan188
Senior Member
 
Join Date: Jan 2008
Stockholm riots challenge image of happy, generous state:

"Hundreds of young people have torched cars and attacked police in three nights
of riots in immigrant suburbs of Sweden's capital, shocking a country that has
dodged the worst of the financial crisis but failed to defuse youth unemployment
and resentment of asylum seekers.

On Tuesday night, a police station in the Jakobsberg area in northwest Stockholm
was attacked, two schools were damaged and an arts and crafts centre was set
ablaze, despite a call for calm from Prime Minister Fredrik Reinfeldt."

See:

http://news.yahoo.com/stockholm-riot...151945567.html
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Old 2013-05-22, 12:26   Link #28527
zarqu
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Join Date: Nov 2009
Location: On the corner
Age: 24
These riots are bad, but it's not like attacks against the police are rare: only last year there were 51 attacks against the police. Systematic stone throwing, driving over them, shooting at them and threatening officers.

http://www.aftonbladet.se/nyheter/article16819471.ab Article in Swedish, I translated the parts I posted.

Some pics showing how many suburbs, exactly, are in question:
Images
Sorry; dynamic content not loaded. Reload?

edit: Oh, one police interviewed in the article I linked (not just an officer, in a chief position [don't know how to translate his title]) suspects that there are criminal groups behind these riots who recruit youths to their ranks, but the officials don't know who they are or how they operate.

Last edited by zarqu; 2013-05-22 at 12:38.
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Old 2013-05-22, 12:56   Link #28528
ArchmageXin
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Join Date: Mar 2008
Quote:
Originally Posted by willx View Post
I am neither pro-or-anti, it's more again of people properly understanding how international corporate structures work. You're absolutely right on your interpretation but the news and how people understand it is basically skewed. That said, I make no claim there are no questionably legal shenanigans going on, but even without creative accounting the "average person" is woefully underinformed about the most basic corporate taxation matters. @ArchmageXin -- I believe you more than get it, I'm basically thinking about the broader population that is opinionated but sadly remains largely ignorant.

Here's an example with GE -- everyone remember the "GE pays zero taxes" news article that was floating around a couple of years back? Here's a "factcheck" on it: http://www.factcheck.org/2012/04/war...pays-no-taxes/

This is where people get confused on multiple levels:
Premise: GE is a U.S. company, if I look at their profit, cash, etc. Why does their tax rate look so low compared to the U.S. corporate tax rate?
Ergo: GE is scamming us! Damn corporate thieves!

Reality:
1) GE is an international business with both U.S. and international operating subsidiaries and holding companies
2) What the above means is that GE has "U.S.Co" "AsiaCo" "EuropeCo" and many many many more subdivisions. Each of these units generates profits at it's operating corp levels. The U.S. tax rate on profits may be ~20% (nominal 35%, avg. effective ~12%) but what about tax rates in Ireland? Rest of the world? http://en.wikipedia.org/wiki/List_of...s_by_tax_rates
3) Keep in mind taxation is only on profits. So what about government granted tax deductions? Depreciation of assets? Issuing debt to buy back stock and pay dividends (interest is paid out of pre-tax income, so it reduces profits)?
4) Go read ArchmageXin's post: http://forums.animesuki.com/showthre...25#post4690725

So, when people think about taxation of international businesses, they need to think about operations divided by jurisdiction and effective local tax rates. Tax treaties only factor in when funds are repatriated (as you mentioned previously) and as long as those funds are never sent back to U.S. "ParentCo" then that doesn't matter.
^_^ Master level tax class I slept through....

To summarize for various people who don't understand taxes.

Bob Corp has a office in China. It made $100.

Bob Corp has a office in America. It made $10.

Bob get his U.S Tax paid come tax time, 30% of the $10, so he pay $3. His actual profit is $110, so it look like he paid only 2% tax (TAX CHEAT!!!!). But in reality, the $100 is in China.

If Bob ever need the $100 and ask China to pay it back, he would need to pay $30 at that time.

The problem in the end, is Bush opened the floodgates in 2004(?) where he enacted an Tax holiday. Which allow oversea corps to pump a huge ton of dollars into their own coffers (You can debate how good that was for the U.S economy).

So now, like little kids, International Corp is waiting for the next time an U.S President give in to allow International Corps to bring money home to "help the economy"

Guess what is Apple asking?

(Note: This don't explain other weird stuff like maintaining empty offices in Nevada to route their cash needs, but I am not in the Tax prep Industry right now)
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Old 2013-05-22, 13:44   Link #28529
Bri
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Except a clever 'Bob Corp' lowers his profit stateside artificially. The US office didn't make $10, it made a $100. Except $90 is exported as a cost for the the use of IP.

Create a company in Ireland with a few lawyers/accountants as employees. Assign ownership of all patents for a product to the subsidiary. The subsidiary will charge back the parent company for all of the patents and copyrights used in the product. The parent company makes zero profit and the subsidiary makes all of the profit for the company. Pay no tax on your profit because.. hey.. I am paying my fair share of tax on money earned abroad.
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Old 2013-05-22, 14:27   Link #28530
ArchmageXin
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Quote:
Originally Posted by Bri View Post
Except a clever 'Bob Corp' lowers his profit stateside artificially. The US office didn't make $10, it made a $100. Except $90 is exported as a cost for the the use of IP.

Create a company in Ireland with a few lawyers/accountants as employees. Assign ownership of all patents for a product to the subsidiary. The subsidiary will charge back the parent company for all of the patents and copyrights used in the product. The parent company makes zero profit and the subsidiary makes all of the profit for the company. Pay no tax on your profit because.. hey.. I am paying my fair share of tax on money earned abroad.
That is kind of....misunderstood.

Because what this does is putting a billion dollar in Ireland. Gratz. How will you get it back to your shareholders then?

You still have to repatriate it. It is not Tax Free yet. Unless Obama or the next president decide to have a tax holiday.
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Old 2013-05-22, 14:28   Link #28531
ganbaru
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Location: Betweem wisdom and insanity
Petraeus’s role in drafting Benghazi talking points raises questions
http://www.washingtonpost.com/politi...y.html?hpid=z1
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Old 2013-05-22, 14:52   Link #28532
Shay
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Join Date: Apr 2004
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Age: 33
Islamist provoked murder of British soldier in broad daylight...

http://news.sky.com/story/1094380/wo...-terror-attack

Madness!. I am from the UK (Liverpool). I have two young children and i am honestly scared for their future.

The repercussions of this will carry throughout the country.

I can foresee a civil war coming which will be completely mindless as normal Muslims will be forced to protect themselves from angry gangs blaming them for what has happened.

Extremist religion will be the ruin of us all.

I have no answer to this problem which really scary.
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Old 2013-05-22, 15:22   Link #28533
Bri
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Join Date: Jan 2009
Quote:
Originally Posted by ArchmageXin View Post
That is kind of....misunderstood.

Because what this does is putting a billion dollar in Ireland. Gratz. How will you get it back to your shareholders then?

You still have to repatriate it. It is not Tax Free yet. Unless Obama or the next president decide to have a tax holiday.
The Irish tax system has a quirk that allows profits to be send from one Irish company to a second Irish company headquartered in a tax haven at almost no cost. Those reserves can be held there near indefinitely with little to no taxes paid.

As you said they can wait till a tax holiday occurs to bring it back at little cost. So basically they store profits made in the US abroad as reserves. The shareholders will receive less dividends but are compensated by capital gains as the profits are not paid out.
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Old 2013-05-22, 15:23   Link #28534
Haak
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Join Date: Apr 2009
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Age: 23
Quote:
Originally Posted by Shay View Post
http://news.sky.com/story/1094380/wo...-terror-attack

Madness!. I am from the UK (Liverpool). I have two young children and i am honestly scared for their future.

The repercussions of this will carry throughout the country.

I can foresee a civil war coming which will be completely mindless as normal Muslims will be forced to protect themselves from angry gangs blaming them for what has happened.

Extremist religion will be the ruin of us all.

I have no answer to this problem which really scary.
It basically sounds like a bunch of dickheads with machetes. As bad as it is, i don't think it's going to be that much of a big deal considering most have generally associated terrorist attacks to a lot worse stuff.
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Old 2013-05-22, 16:08   Link #28535
Shay
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Join Date: Apr 2004
Location: Liverpool
Age: 33
Quote:
Originally Posted by Haak View Post
It basically sounds like a bunch of dickheads with machetes. As bad as it is, i don't think it's going to be that much of a big deal considering most have generally associated terrorist attacks to a lot worse stuff.
No mate, you don't get it. The fact that this was done in broad daylight by two black dudes born and bred in the uk asking people to film what they are doing while shouting Allah akbah!

And to a British soldier. Do you not think people are not going to react to this? I hope i am over analysing this trust. But i don't think i am...
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Old 2013-05-22, 20:15   Link #28536
JagdPanther
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Quote:
Originally Posted by Shay View Post
No mate, you don't get it. The fact that this was done in broad daylight by two black dudes born and bred in the uk asking people to film what they are doing while shouting Allah akbah!

And to a British soldier. Do you not think people are not going to react to this? I hope i am over analysing this trust. But i don't think i am...
I cannot imagine the reaction if that happened here in the States.

Absolutely sickening.
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Old 2013-05-22, 21:31   Link #28537
kuroishinigami
Ava courtesy of patchy
 
 
Join Date: Jan 2009
Quote:
Originally Posted by Bri View Post
The Irish tax system has a quirk that allows profits to be send from one Irish company to a second Irish company headquartered in a tax haven at almost no cost. Those reserves can be held there near indefinitely with little to no taxes paid.

As you said they can wait till a tax holiday occurs to bring it back at little cost. So basically they store profits made in the US abroad as reserves. The shareholders will receive less dividends but are compensated by capital gains as the profits are not paid out.
That...might work for private-owned company, and even then, the owner of such company might have to think how long they are willing to delay capitilizing on their company profit(assuming the owner are not involved in the company daily operation such as being a CEO).

Basically, what they'll have is a big company with a large profit and capital, yet they receive no real profit(cash for example) out of it at all, and a risk that the capital(and the owner's unrealized gain) might be eroded by operational loss before they manage to cash in the profit. Remember, we're not talking about small piece shareholder who trade their share in the stock market here, we're talkinh about major owner. They might do such trick with part of their company profit, but I'm pretty sure they're not as willing to do that down to the last penny of their profit.
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Old 2013-05-22, 22:49   Link #28538
kyp275
ZA ZOMBIE!!!
 
 
Join Date: Feb 2008
Location: Somewhere in the EVE cluster...
Some people just shouldn't be allowed to have children...

or at least, not allowed to parent them

http://philadelphia.cbslocal.com/201...ed-a-homicide/
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Old 2013-05-23, 00:58   Link #28539
Domonkazu
Senior Member
 
 
Join Date: Mar 2012
Location: Deutschland
Age: 30
Quote:
Originally Posted by Shay View Post
http://news.sky.com/story/1094380/wo...-terror-attack

Madness!. I am from the UK (Liverpool). I have two young children and i am honestly scared for their future.

The repercussions of this will carry throughout the country.

I can foresee a civil war coming which will be completely mindless as normal Muslims will be forced to protect themselves from angry gangs blaming them for what has happened.

Extremist religion will be the ruin of us all.

I have no answer to this problem which really scary.
madness, how could something like this happen in London, one of most developed city??
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Old 2013-05-23, 02:22   Link #28540
Vallen Chaos Valiant
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Join Date: Nov 2004
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Age: 33
Quote:
Originally Posted by Shay View Post
No mate, you don't get it. The fact that this was done in broad daylight by two black dudes born and bred in the uk asking people to film what they are doing while shouting Allah akbah!

And to a British soldier. Do you not think people are not going to react to this? I hope i am over analysing this trust. But i don't think i am...
If anything, this is a blatant attempt to incite retaliations.

Terrorism is like that; it isn't about hurting your enemies, it is about getting your enemies mad and fall down to your own level. And once they are just as bad as you, you win.
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