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U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

nytimes.com

111–120 of 164 posts

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#111
post #80

Earlier quoted context omitted.

It's only as mobile as laws will allow it to be. Sure, it's a leaky bucket, but you don't need to patch all the leaks.

Capital is fully mobile because people are fully mobile.

This is clearly false. Every country has rules and limits about who can enter and what they can do while there; backed by the threat of imprisonment or deportation.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#112

Another attempt to close the loop holes in the US's byzantine corporate tax system doomed to failure. The Treasury Department says as much in the article. A flat corporate rate on income earned, in the US, minus income lost, in the US, equals taxable income, done and fair. If a corporation can't compete in the US without support of its international shell games, then it probably wasn't competitive enough to matter an…

For that matter, there are good arguments to be made to simply eliminate corporate income taxes entirely. After all, any profits ultimately flow to individuals and their individual tax returns. Of course, good luck ever getting that passed politically.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#113
post #44

Earlier quoted context omitted.

Also, the US has one of the highest corporate tax rates in the world. If you can go to Ireland and pay something close to 10%, its a no brainier. The tax rates are pretty crazy in the US if you think about it. A single person small business just getting started still has to pay 33% of their profit even if their profit is $1,000 for the entire year.

I'm not a tax expert but this statement is true if you only look at the statutory corporate tax rate before deductions and tax credits are taken into account. Once those are done and you used a weighted average based on country size, then the US is not that much higher ( http://www.forbes.com/sites/taxanalysts/2015/03/25/the-truth... ). I don't disagree that tax reform is necessary but taxes help pay for the infrastr…

You should probably also count man hours needed to consider deductions, amortization schedules, tax credits etc. Doing corporate taxes is another layer of work that adds a burden to running a business. Simplified tax systems do not have these costs.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#114
post #80

Earlier quoted context omitted.

Capital is fully mobile because people are fully mobile.

Ever try to take twenty thousand in cash through airport security? Here's a secret: Those millimeter wave body scanners are only incidentally for drugs and weapons.

Yeah -- you're right. I was making a different point involving how wealth is built. It takes creative capital. It isn't just money. So stick with an uncompetitive tax system, and eventually the brightest won't end up on your shores, and they'll live, create, and bank elsewhere.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#115
post #64

Earlier quoted context omitted.

(IANATA) If you get tax credits, wouldn't you pay us_tax-foreign_tax if us_tax>foreign_tax ?

Yes, that's my understanding as well (IANATA)! And it's still not double-taxation: if us_tax>foreign_tax, then you pay foreign_tax + us_tax-foreign_tax == us_tax. (Or foreign_tax, if it's greater.) The citizenship taxation system means you can't move away and legally pay LESS taxes than if you'd stayed in the US. But you're welcome to pay more and not have to remit anything extra to the US. ;)

If you pay two taxes instead of one, as everyone else, then it IS double taxation.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#117
post #55

Earlier quoted context omitted.

And the US double taxes their citizens living abroad the same way. As an American making the same money as your non-american co-worker you are left with a lot less just for having a US passport. It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes. Wanna get rid of your US passport? Not before you pay 10 years projected taxes and pay an abhorrent fee. You will also be listed…

> And the US double taxes their citizens living abroad the same way. The tax code has provisions to avoid "double taxes" on foreign income. You file Form 1116 to claim credit for taxes you paid to a foreign country as an offset against your U.S. tax liability.[1] That tax credit is separate from the income exclusion, which excludes the first ~$100k of foreign income from U.S. taxation. Generally, your total tax liabi…

What! How can you not see the injustice in a US expatriate who has not set foot in the US for 20 years paying taxes to the IRS if they earn over $100K and their country of residence has a lower tax rate than America? That is exactly what happens today, no other country does this, and there is nothing just about it!

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#118
post #93

Earlier quoted context omitted.

And the US double taxes their citizens living abroad the same way. As an American making the same money as your non-american co-worker you are left with a lot less just for having a US passport. It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes. Wanna get rid of your US passport? Not before you pay 10 years projected taxes and pay an abhorrent fee. You will also be listed…

"And the US double taxes their citizens living abroad the same way." Except they don't. You have an exemption for foreign income. "It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes." I don't believe this for a second. You would be a US Citizen, therefore you would have stepped foot in US territory.

Just count taxes and countries: a) you pay taxes to one country only - normal taxation; b) you pay same taxes to the country BUT you are also paying additional taxes to US - double taxation.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#119
post #64

Earlier quoted context omitted.

Yes, that's my understanding as well (IANATA)! And it's still not double-taxation: if us_tax>foreign_tax, then you pay foreign_tax + us_tax-foreign_tax == us_tax. (Or foreign_tax, if it's greater.) The citizenship taxation system means you can't move away and legally pay LESS taxes than if you'd stayed in the US. But you're welcome to pay more and not have to remit anything extra to the US. ;)

If you pay two taxes instead of one, as everyone else, then it IS double taxation.

Wikipedia disagrees with you: https://en.wikipedia.org/wiki/Double_taxation

Specifically, double-taxation is when you pay taxes twice on the SAME earnings. Take the example of a US citizen living abroad in a country with lower income taxes. They will have to pay foreign as well as US income taxes: two like, you point out, rather than one. But the IRS agrees that double-taxation is mean, so they give you a foreign tax credit for the tax you've already paid. You pay an amount to the IRS to make up the difference in income tax. If it were double-taxation you would have to pay the full US income tax on the money you earned, after already having paid the full foreign income tax on it as well.

(Note I've been talking about plain-vanilla income, it's a whole new ball-game if you think about other investment income.)

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#120
post #93

Earlier quoted context omitted.

"And the US double taxes their citizens living abroad the same way." Except they don't. You have an exemption for foreign income. "It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes." I don't believe this for a second. You would be a US Citizen, therefore you would have stepped foot in US territory.

Just count taxes and countries: a) you pay taxes to one country only - normal taxation; b) you pay same taxes to the country BUT you are also paying additional taxes to US - double taxation.

No. That's not how it works.
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