Apple's $348M Tax Settlement In Italy Bodes Ill For Google, Facebook, Microsoft

Post by HSO » Thu, Dec 31, 2015, 10:26 PM UTC

gozur88 wrote: post #161

HSO wrote: post #127

Earlier quoted context omitted.

> That's how they ended up with $200bn offshore and only $10bn or so in the US. Wrong. They initiated a capital return program a few years ago and ran down their US cash holdings while taking on debt "against" part of their overseas holdings. Once you account for the debt issues, their net cash holdings are a lot lower (though still substantial). Please don't make wild accusations if you don't know what you are talki…

It's not wrong. http://appleinsider.com/articles/15/07/22/as-apples-offshore... They still can't repatriate that money without paying taxes. And as of two quarters ago they still have $200bn offshore and $10bn in the US. That offshore tax horde is still growing and it's still growing as a result of Double Irish flim-flam. Don't accuse other people of not knowing what they're talking about unless you know what you're…

Post by nodamage » Thu, Dec 31, 2015, 10:56 PM UTC

gozur88 wrote: post #170

nodamage wrote: post #169

Earlier quoted context omitted.

I’m only defending my statement that the double Irish arrangement doesn’t work for US sales, and that Apple (US) continues to pay corporate income taxes on the goods they sell to US customers. That Apple uses various tax arrangements to wipe out profits from its international sales is not in question. However, these are sales made by Apple’s foreign subsidiaries to foreign customers. They weren’t moved offshore, they…

Except that isn't actually true. Irish subsidiary revenues include payments from the parent that subtract from recognized US profits of sales made in the US. They're moving profits from US sales to Ireland.

Post by zepto » Fri, Jan 01, 2016, 12:55 AM UTC

gozur88 wrote: post #172

HSO wrote: post #171

Earlier quoted context omitted.

For the record, I said your assertion that Apple's cash position was due to Double Irish tax maneuvers on US income is wrong, and that net cash (once you account for debt issued to pay dividends) is significantly lower, both in absolute terms and in the disparity between overseas and onshore holdings. Before the initiation of the 140bn capital return program, relative balances were less skewed and more reflective of…

You have a talent for seeing the trees and missing the forest. Apple isn't changing anything by borrowing against its foreign cash horde. That just gives it access to the money without having to pay taxes.

Post by gozur88 » Fri, Jan 01, 2016, 1:40 AM UTC

zepto wrote: post #174

gozur88 wrote: post #170

Earlier quoted context omitted.

Except that isn't actually true. Irish subsidiary revenues include payments from the parent that subtract from recognized US profits of sales made in the US. They're moving profits from US sales to Ireland.

No they aren't - this is a false claim which is not substantiated by any of the citations.

Post by jgalt212 » Fri, Jan 01, 2016, 3:14 AM UTC

xixi77 wrote: post #150

jgalt212 wrote: post #147

Earlier quoted context omitted.

My point is what would happen if everyone had the resources and moral turpitude to exploit every possible loophole.

Perhaps the government would then have an incentive to simplify the tax system and eliminate the loophole?