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Apple must pay 13B euros in back taxes, EU's top court rules

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Re: Apple must pay 13B euros in back taxes, EU's top court rules

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> Apple, however, said in a statement: "The European Commission is trying to retroactively change the rules and ignore that, as required by international tax law, our income was already subject to taxes in the US." My understanding is that the U.S.A. double-taxes both corporations operating abroad, as well as it's own expats. If this is true, then it's quite the remark to say _the country you're actually in_ is the o…

Expats aren’t double taxed but you need to file tax returns to offset taxable income that’s already been taxed. There are specific agreements to avoid double taxation but it’s unclear/unlikely the IRS are just going to hand back money Apple already paid (it likely falls outside of what’s required in those international agreements). Companies, and people, make decisions based on the tax laws of the day eg deciding to…

> If they can do it to Apple, why not to regular citizens?

The regular citizen doesn't debate-ably owe billion in taxes.

Sure, maybe if you're a centi-billionaire the Winds of Winter might change.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#412
post #327

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It's simple, EU law says Apple had to pay taxes at that time. Apple's ignorance of EU law is not an excuse, this doesn't work for individuals, why should it work for big multinational companies? Ireland doesn't have the power alone to overturn these kinds of laws, unless, of course, they decide to leave EU. Apple's decision to put their trust completely in Ireland officials and sidestep the EU is their own mistake. R…

In the case of conflicting laws, who prevails? If the Irish pass a law that Apple can not pay certain taxes, does that not override EU law? Usually in cascading situations, the more local entity wins, n

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Re: Apple must pay 13B euros in back taxes, EU's top court rules

#413

Earlier quoted context omitted.

Those numbers are not directly comparable. GDP is a measure of added value, not spending. Public sector spending may be ~50% of the GDP, but private sector spending is something like ~200%, making public sector ~20% of the total.

Interesting. I always think private spending is GDP - public spending. Can you share where you get this numbers?

Total spending is not something that gets reported very often. I've seen the numbers for Finland but not for other countries. In the US, consumer spending seems to be ~70% of GDP, but I can't find any numbers for business spending.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#414

Earlier quoted context omitted.

This isn’t the full story though, because there is also the foreign tax credit. If your US taxes are lower than your foreign taxes (which they will be if eg you live in Europe) you won’t pay US tax: https://www.irs.gov/individuals/international-taxpayers/fore...

There are myriad cases where this is not true, the details of how these tax credits are structured can lead to significantly adverse outcomes. It is quite possible to pay more taxes in aggregate than either country separately.

It is certainly possible, but also implies a complex mix of different income types and very specific national pairing.

The usual case where there is a tax treaty is that the expat pays taxes at the rate of the country in which they work. It's really that simple for most people.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#415

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Universal healthcare and welfare systems aren’t free.

The welfare systems (in Europe at least) don't work. They work if you're old right now, but once the young people of today become old they won't get anything meaningful out of it. At least that's the impression I have and everyone else my age has. And healthcare is unavailable anyway. Several month long waits to see a specialist.

I know multiple people whose cancer was successfully cured (or, at least, treated) in the healthcare system you can "unavailable". The systems in Europe typically focus more efforts on critical care (like cancers), and less so on mere annoyances, hence the queues for non-critical stuff. Compare that with the US, where for a sizable portion of population, treating their cancer leads to being bankrupt and homeless.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#416
post #337

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its complex.. The USA has FEIE, (no federal taxes the first $120k/yr), but not all states (like Cali) honor that and may still charge you state income tax. and FEIE doesn't exempt you from self-employment taxes. and doesn't exempt non-earned income (dividends, etc.). Americans can come out ahead (if they earn less than $120k/yr and live in a 0% tax country). But a non-American (like Canadian) doing the samething, wou…

> but not all states (like Cali) honor that and may still charge you state income tax Whoa, so before moving to a low tax country you should move to a state that is not insane for a while and then move abroad? Crazy.

Yes, but from reading it sounds like California is a bit of a poison pill and will go at length to try and say you still live there. I've read of cases where even living in another state for 6+ months, drivers license moved over, no property in California, wasn't enough.

Not sure how they get away with it really, small volume I guess.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#417
post #349

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So how come the US has worse health outcomes?

Worse in some ways, better in others. The USA generally has higher 5-year cancer survival rates, and shorter waits for specialist visits and advanced imaging procedures. Of course there's a high variance in outcomes based on location and affluence.

> shorter waits for specialist visits and advanced imaging procedures

Those are not health outcomes, but merely services KPAs. The KPAs may be better, because a portion of population can't afford the services, so they don't have to be serviced at all.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#418
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post #130

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>there is a rich person on the end of it with the loan as an asset earning interest. About half of treasuries are held by the Fed or foreign investors which largely means other governments and foreign companies. Most of the rest are owned by pension funds, banks, local government, insurance companies, etc.

>> there is a rich person on the end of it with the loan as an asset earning interest. > About half of treasuries are held by the Fed or foreign investors which largely means other governments and foreign companies. Most of the rest are owned by pension funds, banks, local government, insurance companies, etc. So what? That doesn't mean you shouldn't think about it in terms of a rich person, like the GP suggests. The…

There is no such slippery-ness or slippage. The system is fundamentally assessable with basic accounting and Econ 101. No, the 401k is not a coup. No, class-warfare advocates cannot fundamentally create value, improve the economy, or the better state of individual well-being—-either temporarily or permanently—-by wealth transfer, and their efforts typically result in gross infringement of human rights. Typically in history these wealth transfers have greatest negative impact against the middle- and lower- tiers of wealth. The study of the encomiendas in Columbia is perhaps somewhat insightful.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#419
post #296

Earlier quoted context omitted.

Expats aren’t double taxed but you need to file tax returns to offset taxable income that’s already been taxed. There are specific agreements to avoid double taxation but it’s unclear/unlikely the IRS are just going to hand back money Apple already paid (it likely falls outside of what’s required in those international agreements). Companies, and people, make decisions based on the tax laws of the day eg deciding to…

> Expats aren’t double taxed but you need to file tax returns to offset taxable income that’s already been taxed. This is not correct, it is only practically true in trivial cases. Excess taxation is a very real pain point for Americans living overseas, never mind the other indefensible things the US government does to its expats like FATCA. Many types of income cannot be offset nor or they covered by tax treaties. E…

Can you give more specifics?

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#420

Earlier quoted context omitted.

You Seen knowledeble on this topic. What do you think of the numerous Deutsche Bank and Lufthansa aids?

I don’t think Deutsche Bank has ever received direct state aid, they’re quite proud of that fact. Though they have benefitted indirectly when institutions that owed Deutsche Bank money received state aid. Lufthansa did receive state aid during the pandemic. This is currently under investigation as the EU’s approval was annulled by an EU court: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_...

To be clear: Germany also heavily subsidized a lot of other large companies, especially in the automotive industry during the pandemic but the politicians involved were mostly smart enough to hide this behind grants with tailor-made requirements that only incidentally happened to perfectly match those companies and few else.
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