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How to Stop Turning U.S. Corporations into Tax Exiles

nytimes.com

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Re: How to Stop Turning U.S. Corporations into Tax Exiles

#61

Post by [deleted] »

mschuster91 wrote: post #19
pzone wrote: post #6

Earlier quoted context omitted.

No, actually what you're saying is a pile of crap. The only irresponsible ones in this situation are the members of Congress. The United States is not immune to economic forces, yet for years despite all the evidence to the contrary they've been in utter denial about this. All they have to do is pass a simple bill to make the US tax code work the same way as it does in every other god damn country in the world, then…

> No, actually what you're saying is a pile of crap. In Germany, our constitution says in §14.2: "Eigentum verpflichtet. Sein Gebrauch soll zugleich dem Wohle der Allgemeinheit dienen.", translated roughly to "Ownership creates duties. Its use shall be for common welfare." For me, looks like the failure is in the US constitution which does not focus on the common good.

[deleted]

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#62

Post by paulddraper »

rmc wrote: post #30
apsec112 wrote: post #10

Earlier quoted context omitted.

"Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes." "Over and over again courts have said that there is nothing sinister in so arranging one's affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any…

There's no legal responsibility on me to be nice to my elderly parents either. Doesn't mean it's not The Right Thing To Do.

Read the quote closer. It wasn't just talking about legal responsibility. It was talking about "patriotic duty", "sinister", "public duty", "voluntary", and "morals".

Being mean to your elderly parents conflicts with a few of these ideals.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#63

Post by paulddraper »

king_of_nouns wrote: post #37
DominikR wrote: post #25

Earlier quoted context omitted.

How on earth can this be a law? This is such a broad and general statement that it could be used for whatever reasons to confiscate private property.

Sadly, laws aren't written like executable code. They're something vaguely resembling executable statements that require a lot of judgement by the person (trying to) interpret them to actually get to something that can finally be acted upon. As such, law contains many places (usually preambles and stuff) that are there to just give context and aid the interpreter in filling in the gaps, when he centuries later tries…

"The Constitution, on this hypothesis, is a mere thing of wax in the hands of the judiciary, which they may twist and shape into any form they please."

- Thomas Jefferson

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#64

Post by r00fus »

blisterpeanuts wrote: post #42

Almost more interesting than Icahn's common sense article are the many talkback comments from the New York Times readership, most of whom appear to be bitterly opposed to corporate activity which maximizes profits. Has the NYT become a haven for left wing advocacy, Icahn's capitalistic perspective notwithstanding, whose primary readership are socialists? How much of the country do they represent? I worry about our ec…

Amusingly, I think the non-free-market-uber-alles advocates feel the same way about profit maximization vs. economic prospects for the country.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#65

Post by geomark »

seanmcdirmid wrote: post #55
geomark wrote: post #44

Earlier quoted context omitted.

It's messy and expensive to pay an accountant who knows how to get it right, which makes for a big disincentive to take any work abroad. Small jobs are money losers after accounting and filing costs.

Not just messy, sometimes no one really knows what the rules are since you are trying to reconcile two completely different tax codes.

That's kind of what I meant by messy, so few people know how to resolve the two sets of rules.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#66

Post by geomark »

seanmcdirmid wrote: post #52
geomark wrote: post #41

Earlier quoted context omitted.

Actually, it's been a requirement to file a FBAR for many years if you have a foreign bank account with more than equivalent of US$10,000 in it. So that filing requirement isn't exactly new, just that it's gotten more attention lately and now with FATCA you might not get away with ignoring it. And yes, expats just love that requirement to file a tax return on your world wide income regardless of where it was earned o…

All the Chinese banks I use now want my Social security number! So....remember to file those fbars kids!

I thought China was not going to cooperate with FATCA. Really surprised they would agree to report on bank holdings to the US gov.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#67

Post by seanmcdirmid »

geomark wrote: post #66
seanmcdirmid wrote: post #52

Earlier quoted context omitted.

All the Chinese banks I use now want my Social security number! So....remember to file those fbars kids!

I thought China was not going to cooperate with FATCA. Really surprised they would agree to report on bank holdings to the US gov.

They weren't cooperating until this year. Now they are in full cooperation. It has something to do with fox hunting and the US also agreeing to report Chinese national bank holdings to the Chinese gov.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#68

Post by gozur88 »

pzone wrote: post #15
deciplex wrote: post #12

Is the end to double taxation for the corporate tax only? Human Americans are also double-taxed on income earned abroad.

Yes. The reason is that corporations vote with their feet quite readily, as seen here.

People would vote with their feet, too, except they're heavily penalized for doing so. If you renounce your US citizenship there's a one-time tax of 40% of your all your US assets and the US claims the right to tax you for the next ten years.

Subjects, not citizens.

Re: How to Stop Turning U.S. Corporations into Tax Exiles

#69

Post by eru »

deoptimo wrote: post #50
princeb wrote: post #18

I am trying to think of companies that should rightfully repatriate cash back to the states, and companies that should not. Why is it that it is repulsive that Google or Apple chooses to keep their cash overseas, whereas it is fine for Budweiser to do so (ignoring magnitudes for a second)? Because AB Inbev is Belgian? This is a difficult example for me to think of, because the US is one of the interesting countries w…

As an alternate hypothetical, lets imagine that every multinational happens to be related to a large number of subsidiaries in the Cayman Islands, Bermuda, Singapore, and Luxembourg. Furthermore, suppose that three quarters of all world-wide corporate profits happen to be booked in these four countries with a minuscule population. Clearly there would be a problem. So long as there is "greyness" in the allocation of p…

Perhaps the solution is not to tax profits then, but find something that's easier to grasp and define?
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