Facebook tax court trial begins over Ireland offshore deal • Hacker News Board

Re: Facebook tax court trial begins over Ireland offshore deal

#321

Post by animalnewbie » Thu, Feb 20, 2020, 8:56 AM UTC

jedberg wrote: post #320

banads wrote: post #305

Earlier quoted context omitted.

If you think that's new, you're obviously not aware of the history. How would you compare and contrast the corruption and lack of consequences of say, the Iran Contra conspiracy, to Trumps scandals? Just to throw you a bone, you'll notice that AG Barr was involved in the pardons resulting from the Iran Contra affair as well.

This President just learned he is immune to consequence. He’s not familiar with history.

Only you are smart enough to know everything. Not the dude who beat 16 establishment Republicans including Jeb!, and Hillary "it's my turn" Clinton who steamrolled Sanders with her establishment clout.

Re: Facebook tax court trial begins over Ireland offshore deal

#322

Post by andrewprock » Thu, Feb 20, 2020, 3:07 PM UTC

JumpCrisscross wrote: post #261

andrewprock wrote: post #258

Earlier quoted context omitted.

This literally sounds like apples and apples to me, unless you really think "cloud computing" occurs in space or something. If the servers are in Ireland, then their physical assets are offshore.

> If the servers are in Ireland, then their physical assets are offshore This is correct. But the fraction of assets which are physical are high for Halliburton and low for Facebook.

Data is a physical asset. I'm pretty sure that is their largest asset class.

Re: Facebook tax court trial begins over Ireland offshore deal

#323

Post by SilasX » Thu, Feb 20, 2020, 5:01 PM UTC

gamblor956 wrote: post #314

AnthonyMouse wrote: post #312

Earlier quoted context omitted.

> Was that an actual market transaction where the seller got the highest price they could, and said price was evaluated by the buyer against alternatives? No, of course not. Why not? The San Francisco office doesn't have any monopoly over the contractor. It doesn't have anything the Ireland office wants that nobody else could provide. So what is it doing that justifies it receiving a significant premium? > You can on…

You keep trying to make logical arguments about a very small portion of the entire transaction without looking how that transaction relates to much larger business concerns. The law, tax, business, and reality doesn't work that way. They make policy based on a view of the entire forest, not on the gnarls in a single tree branch. Territory matters when you're talking about taxing value creation. It always has. If you'…

You must have the patience of a saint, to untangle and address the parent's arguments.

Re: Facebook tax court trial begins over Ireland offshore deal

#324

Post by dodobirdlord » Thu, Feb 20, 2020, 5:13 PM UTC

james1071 wrote: post #69

dodobirdlord wrote: post #57

Earlier quoted context omitted.

Corporations are just bundles of stuff that people own. They have legal personhood as a convenient legal fiction because it would be obnoxious if all of the owners had to get together to sign things, and they have rights because people don't lose any of their individual rights just because they happened to form a corporation together. But at the end of the day, bundles of stuff. Economists seem to be broadly in agree…

Maybe I am wrong on this, but I doubt that you have studied economics or have any idea what economists think. The people that you are talking about are effectively lobbyists - policy entrepreneurs is the phrase, who appear in the media advocating for policies that benefit their clients.

Feels like an aggressive response to what I said. Feel free to look it up, the statement is noncontroversial. There are regularly conducted surveys of the field that include questions on this topic.

Re: Facebook tax court trial begins over Ireland offshore deal

#325

Post by dodobirdlord » Thu, Feb 20, 2020, 5:20 PM UTC

dnautics wrote: post #65

dodobirdlord wrote: post #57

Earlier quoted context omitted.

Corporations are just bundles of stuff that people own. They have legal personhood as a convenient legal fiction because it would be obnoxious if all of the owners had to get together to sign things, and they have rights because people don't lose any of their individual rights just because they happened to form a corporation together. But at the end of the day, bundles of stuff. Economists seem to be broadly in agree…

What about the inverse. What if individuals didn't pay an income tax but corporations did, kind of as a "user fee" for the privilege of having limited liability.

Mostly because corporations are pretty different from people. They can own each other, buy and sell each other, split in two or be combined, etc. And they they can deduct business expenses in ways that people can’t deduct living expenses, because we rationally recognize that corporations mostly have lower profit margins than the tax bill would be on total revenue (and some always will at any tax level).

Re: Facebook tax court trial begins over Ireland offshore deal

#326

Post by SkyBelow » Thu, Feb 20, 2020, 10:21 PM UTC

harryh wrote: post #311

SkyBelow wrote: post #302

Earlier quoted context omitted.

And just like the real person cannot get a write off for things required to live or things that make them more attractive on the market, neither should businesses. If I have to pay taxes on the income I spent to repaint my house, why shouldn't a business have to pay taxes on the revenue they spent to repaint their building?

Because of this: https://news.ycombinator.com/item?id=22370387

Wouldn't the costs be updated to reflect the difference in profit margins. If the tax is 10%, then in cases where the profit margin is razor thin prices would rise by about 10%, but life would otherwise keep on going. If an entire industry would die from such, then doesn't that mean that currently tax payers are subsidizing that industry to keep it alive by having uneven taxes, if the standard of equal taxes is the purposed change?

Re: Facebook tax court trial begins over Ireland offshore deal

#327

Post by harryh » Fri, Feb 21, 2020, 12:03 AM UTC

SkyBelow wrote: post #326

harryh wrote: post #311

Earlier quoted context omitted.

Because of this: https://news.ycombinator.com/item?id=22370387

Wouldn't the costs be updated to reflect the difference in profit margins. If the tax is 10%, then in cases where the profit margin is razor thin prices would rise by about 10%, but life would otherwise keep on going. If an entire industry would die from such, then doesn't that mean that currently tax payers are subsidizing that industry to keep it alive by having uneven taxes, if the standard of equal taxes is the p…

Are you trying to say that tax payers are subsidizing the entire retail industry? No, that is definitely not the case.

Different amounts of value are added at different stages of the product pipeline. These different amounts of value are reflected in different profit margins. Forcing uniformity here via the tax code would be massively distortionary.

Re: Facebook tax court trial begins over Ireland offshore deal

#328

Post by complianceowl » Fri, Feb 21, 2020, 5:03 PM UTC

CodeSheikh wrote: post #208

complianceowl wrote: post #157

Earlier quoted context omitted.

A lot of unfounded speculation in your comment. It seems more politically-motivated than rooted in facts. Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more. Thirdly, as much as I might dislike an administration, I won't take the giant, speculative leap as to assume that I know exactly what they're thi…

I hate to say this but a lot of unfounded speculation in your comment as well. "Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more." Can you back this up with some factual information? Would love to know more about other companies. Thanks.

Just this month, the Department of Justice announced the largest-in-history FCPA case against Airbus, totaling 3.9 billion in fines[1]. The government's agenda is much larger than you're aware of, apparently.

Unfortunately, the media loves to scandalize things, throw out big names, and hype-up news. The problem is when people just take it, run with it, and parrot it back in the public square.

Anytime a company rises to the stature of Facebook, the probability that they will come into the government's cross hairs is much higher.

[1] https://www.natlawreview.com/article/airbus-to-pay-unprecede...

Re: Facebook tax court trial begins over Ireland offshore deal

#329

Post by complianceowl » Fri, Feb 21, 2020, 5:38 PM UTC

riazrizvi wrote: post #198

complianceowl wrote: post #157

Earlier quoted context omitted.

A lot of unfounded speculation in your comment. It seems more politically-motivated than rooted in facts. Secondly, have you done your research? Surely Facebook is not the only company being targeted by the government right now. I can assure you that, surely there are more. Thirdly, as much as I might dislike an administration, I won't take the giant, speculative leap as to assume that I know exactly what they're thi…

I understand that lawyers are taught to think logically and to support their arguments, so I would appreciate your analysis on our exchange, which looks to me like this: MY COMMENT: question / observation / speculation / hypothesis-with-circumstantial-evidence-to-support-speculation / expectation / expectation YOUR REPLY: assertion / speculation question / speculation / assertion personal observation question / self-…

"I genuinely want to do better if I should." I would have to respectfully call you out on that. You're main interest appears more to show how right you, or at least more right.

Also, your breakdown of the encounter is dishonest. You literally said "Surely" it was about political coercion. And you didn't even attempt to mildly address the allegations brought by the government against Facebook. Next time, you might want to use the world "might" or "potentially".

"Amongst all US companies that offshore profits, including the likes of Halliburton, Facebook has been singled out because the US administration wants the company to do it's bidding regarding policy and algorithms for political advertising"

So because other companies do it, it's okay for Facebook to do it -- that's your rationale? Not good, and all I see is a lazy attempt at utilizing "circumstantial evidence" that can't withstand the test of scrutiny. When cracking down on something, the government will almost always start with the big names in the industry to send a message. Why did you overlook that possibility, or why is that possibility less feasible? These are important questions that should've been asked and addressed.

Furthermore, the President has granted somewhere around 25 pardons; about two of those were actually controversial. The rest barely made headlines, and most haven't. You referenced this as part of your circumstantial evidence. Once again, this absolutely doesn't pass the test of scrutiny.

I didn't write your comment -- you did. Which is why I called you out on throwing claims out there, without even the slightest reference to any reasonable evidence. Throwing out overly-confident words and sloppily referencing acquittals, political reprisals, and talking about what you expect to happen is a good representation of an unfounded comment. Airbus just received the largest-in-history FCPA fine by the DoJ, totaling 3.9 billion. Is the President trying to bring them down as well? Maybe to help out Boeing? If I were to say, "Surely this is about helping Boeing", I would need much more than a couple of references to current events.

Lastly, I'm not a lawyer. Good day.

Re: Facebook tax court trial begins over Ireland offshore deal

#330

Post by AnthonyMouse » Fri, Feb 21, 2020, 6:02 PM UTC

jeremysalwen wrote: post #318

AnthonyMouse wrote: post #304

Earlier quoted context omitted.

> Your friend and the tax law are clearly doing what they are clearly designed to do, which benefits not just him but us all. As we know the mortgage interest tax deduction was intended to promote home ownership. A lot of people who would have bought a home anyway then go out and take a bigger home loan in order to use the money they would have put down as principal to e.g. buy a car. The tax provision clearly wasn't…

> The tax provision clearly wasn't intended to promote car ownership, so all of those people should be in jail, right? That's a red herring. Once he receives the money from the tax break (the reward) in exchange for buying a house (the incentivized activity), what he does with that money is completely irrelevant, unless it somehow involves reducing home ownership.

But it wasn't in exchange for buying a house. He was buying the house anyway, what he did was to take out a larger home loan and use the extra money to buy a car.

This is the same general problem as assigning a jurisdiction to profits. Money is fungible. If you take out a $30,000 "home loan" and buy a $30,000 car, did you borrow $30,000 to buy a house or to buy a car? If you pay a million dollars to develop software in the US and then license it for ten million dollars in Europe, do you have a nine million dollar profit in the US or in Europe? Notice how the US is going to want to claim it's in the US and Europe is going to want to claim it's in Europe, and the company is going to want to claim it's wherever the tax rate is lower, but none of that is an answer to the question.