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Facebook tax court trial begins over Ireland offshore deal

reuters.com

211–220 of 333 posts

Re: Facebook tax court trial begins over Ireland offshore deal

#211
post #110

Doesn't almost every multinational use this arrangement, commonly known as the Double Irish? Why is Facebook getting called out specifically? Surprised the article doesn't mention this. https://en.wikipedia.org/wiki/Double_Irish_arrangement#Multi...

The double Irish is no more. Perhaps FB has been slow to restructure, or resistant.

Re: Facebook tax court trial begins over Ireland offshore deal

#212

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…

>unfounded speculation It's not unfounded in the days of pardons to political donors, political donations to jury members, and firing of whistleblowers and witnesses. You are allowed to assume bad faith when the entity has time and time again showed bad faith. This is suppose to be one of the detriments to acting in bad faith time and time again.

> the days of pardons to political donors, political donations to jury members, and firing of whistleblowers and witnesses

How long have we been in these "days," would you say?

Re: Facebook tax court trial begins over Ireland offshore deal

#214

Surely this is more about political coercion than tax? 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? Especially considering all the other political reprisals and pardons that are in the news, following the impeachment acquitta…

Does the US administration have the authority over the IRS to file and pull the suits at their will?

No. That won't stop accusations of influence however. Each side believes that when the other side is in the White House they use the IRS to go after political enemies. Republicans particularly were very loud in accusing Clinton and Obama of using the IRS to go after people and groups. For example:

https://en.wikipedia.org/wiki/IRS_targeting_controversy

Re: Facebook tax court trial begins over Ireland offshore deal

#215
Does anyone else feel weird to be rooting for the IRS?

We tend to get smashed if they suspect our deductions was only 85% kosher. Facebrick, goog, apple, amazon, yeah. Focus there and everywhere there are overseas tax-dodges with high priced lawyers and accountants.

Re: Facebook tax court trial begins over Ireland offshore deal

#216
post #184

Earlier quoted context omitted.

Here's the million/billion/trillion dollar question: how much is a brand worth? Clearly it is worth something. Facebook can do the most inane thing, but if they put their brand on it then it will have some value. To me this is the flaw in corporate taxation. I don't think you can ever work around this as long as you allow free trade. It just makes sense to tax them in other ways instead and perhaps simply get rid of…

That is the tough bit for sure in trying to tell up front if an IP transfer is just a setup for tax avoidance. You can tell after the fact though just by seeing how much the company claims it's worth to use. A VAT style tax probably solves that right? It doesn't care how much money you actually make so you can't slip profits out the back door as costs.

How well would VAT work for services like this?

If facebook.fr sells adverts to (say) local realtors, and spends a lot of that on its own people, servers, etc, is VAT collected on the entire sales price? (I'm really asking, I don't know how this works.)

Completely agree that for physical goods, collecting tax where they are physically sold to end-users sounds like a great way of avoiding this game of deciding which branch of a company made the profit.

Re: Facebook tax court trial begins over Ireland offshore deal

#217

Surely this is more about political coercion than tax? 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? Especially considering all the other political reprisals and pardons that are in the news, following the impeachment acquitta…

Does the US administration have the authority over the IRS to file and pull the suits at their will?

The IRS is a part of the Dept. of Treasury, which is run by Steven Mnuchin, a member of Donald Trump's cabinet.

Re: Facebook tax court trial begins over Ireland offshore deal

#218

People looking at their personal income tax return: Woah, this is more complicated than I expected - should probably pay a professional accountant to sort this out for me People reading news articles like this: Look at these stupid professionals arguing about how international tax law in the $XB range when one side is so obviously wrong, and the correct outcome is really straight forward.

[deleted]

Re: Facebook tax court trial begins over Ireland offshore deal

#219

Earlier quoted context omitted.

If a professional accountant told my buddy to do one weird trick to completely eliminate the lion's share of his tax liability, and he did it, and then the IRS went after him, I'd feel entirely comfortable judging both my buddy and his accountant, even if I didn't know the precise details.

Then you'd be judging a lot of people wrongly, because that sort of thing happens all the time for entirely legitimate reasons. For example, at various points there have been federal tax credits for installing solar panels on your house or buying certain types of green cars. For a lot of people the credit would exceed their federal tax liability for the year. You're prepared to send them all to jail for that without…

I think by implying that the IRS went after them, the "weird trick" was not as legal as previously anticipated, despite being guidance from a professional.

Appealing to popularity wouldn't make it anymore legal than appealing to professionalism.

Re: Facebook tax court trial begins over Ireland offshore deal

#220

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-…

>"Especially considering all the other political reprisals and pardons that are in the news"

What news are you talking about? Whatever news you're watching is only giving you one perspective on events, so this "observation" is not helpful on its own.

The rest of your comment is similarly rooted in assumptions and speculation borne out of a hostile media's interpretation of recent events, so the conclusions you're reaching are built on a far less sturdy foundation of "evidence" than you may think.

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